IC Submission Template

CONSUMER FINANCIAL PROTECTION BUREAU
REQUEST FOR APPROVAL UNDER THE
“GENERIC CLEARANCE FOR QUALITATIVE CONSUMER EDUCATION,
ENGAGEMENT, AND EXPERIENCE INFORMATION COLLECTIONS”
(OMB Control Number: 3170-0036)

1. TITLE OF INFORMATION COLLECTION:
Protecting Older Account Holders Focus Groups

2. PURPOSE: The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Pub.
L. 111-203) (the Dodd-Frank Act) established the Consumer Financial Protection Bureau (the
CFPB) to regulate the offering and provision of consumer products or services under federal
consumer financial laws. Section 1013(g) of the Dodd-Frank Act established within the CFPB
the Office of Financial Protection for Older Americans (OA), which includes activities designed
to facilitate financial literacy of individuals who are age 62 and older (referred to as “seniors”),
protect them from unfair, deceptive, and abusive practices, and assist them in making future
financial choices.
In order to further this goal, the CFPB seeks to conduct research on effective strategies, tools,
and educational content to assist consumers in making informed financial decisions and to
improve financial education practices.
Specifically, the CFPB Older Americans team is interested in better understanding older
American’s banking needs and preferences. Particularly, the CFPB wants to know what
consumers think about how banks or other institutions can help older consumers avoid financial
exploitation. This data will help the CFPB to encourage financial institutions to offer improved
product offerings and services in order to better protect older consumers in the financial
marketplace.
Understanding consumers’ views about account features will allow the Bureau to refine its
recommendations to financial institutions to help prevent financial exploitation and enable the
Bureau to develop educational materials for consumers. The CFPB’s OA team has contracted
with Fors Marsh Group (FMG) for the focus groups.
3. DESCRIPTION OF RESPONDENTS:
This opportunity is being offered to adults, 62 years and older, living and/or working in the
Arlington, Virginia and one of the following areas: Minneapolis, Minnesota, Denver, Colorado,
Austin, Texas, Phoenix, Arizona, or Las Vegas, Nevada. The locations were chosen based on the
potential number of retirees in the area, the ethnic/racial diversity, the fact that they are not along the
east coast, and the economic diversity of the area. Participants must have a bank/credit union
checking account, be conversant in English, be a diverse mix of gender, age (groups should be a
mix of participants in 60s, 70s, and, if possible, 80s), and household income level. Roughly 25
percent of participants should also be providing assistance with managing finances to an older
relative.

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In order to secure 48 participants for these focus groups, the vendor will screen approximately
150 persons for in-person focus groups in Arlington, Virginia and one of the following locations:
Minneapolis, Minnesota, Denver, Colorado, Austin, Texas, Phoenix, Arizona, or Las Vegas,
Nevada. For the Arlington, Virginia sessions, FMG will contact local FMG panel members with
information and the option to complete the web-based screener to determine if they qualify for
the study. FMG will also post the opportunity to participate through social media channels. For
the focus groups in the second location, FMG will work with a local research facility to contact
their local panel members with the same information and option to complete the web-based
screener that will be provided to individuals in Arlington.
The FMG team and the local team in the selected second city will contact participants who
qualify based on the web-based screener and administer the phone-based screener to ensure they
qualify for participation. During the phone-based screener, the recruitment teams will ask a
series of questions. Depending on the answer he or she receives, the survey will either terminate
or continue until 48 total respondents have been secured to be scheduled for in-person focus
groups.

4. TYPE OF COLLECTION (ADMINISTRATION OF THE COLLECTION
INSTRUMENT):
a.

How will you collect the information? Check all that apply.
[ x ] Web-based or other forms of Social Media
[ x ] Telephone
[ x ] In-person
[ ] Mail
[ ] Small Discussion Group
[ x ] Focus Group
[ ] Other (please explain) __________________________________

b.

Will interviewers or facilitators be used?
[ x ] Yes [ ] No [ ] Not Applicable

5. FOCUS GROUP OR SURVEY:
If you plan to conduct a focus group or survey, please provide answers to the following
questions:
a. Do you have a customer list or something similar that defines the universe of potential
respondents and do you have a sampling plan for selecting from this universe?
[] Yes [X] No [ ] Not Applicable
b. If yes, please provide a description below. If no, please provide a description of how you
plan to identify your potential group of respondents and how you will select them.
FMG will use a process called convenience sampling, and therefore they do not have a
specific pre-determined list of individuals from which to recruit.

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•

For the focus groups that will be held at the FMG offices in Arlington, Virginia, FMG will
contact local FMG panel members with information and the option to complete the inperson web-based screener to determine if they qualify for the study.

•

The FMG Recruitment Team will then contact participants who qualify based on the web
screener and administer the phone-based screener to ensure that they qualify for
participation.

•

The focus groups will be held in one of the following locations: Minneapolis, Minnesota,
Denver, Colorado, Austin, Texas, Phoenix, Arizona, or Las Vegas, Nevada. The locations
were chosen based on the potential number of retirees in the area, the ethnic/racial diversity,
the fact that they are not along the east coast, and the economic diversity of the area. For the
selected location, FMG and the CFPB will select a location and work with a local research
facility to contact their local panel members with the same information and option to
complete the web-based screener that will be provided to individuals in Arlington.

•

The FMG Recruitment Team will work with the local research facility in the second location
to contact participants who qualify based on the web screener and administer the phonebased screener to ensure that they qualify for participation.

•

Respondents are contacted the day prior to the interview to remind them about their
appointment.

• Participants’ information is reconfirmed upon arrival to the session.
Those who participate will be handed the $75 Visa gift card after their participation in the focus
group.
6. INFORMATION COLLECTION PROCEDURES:

Before completing the web-based screener, participants are provided with links to review
the Privacy Act Statement and Paperwork Reduction Act Statements. The Recruitment
Teams will be the only personnel who have access to personally identifiable information
(PII) for purposes of scheduling and providing the incentive for participation. FMG
researchers and CFPB personnel will not have access to respondents’ PII. Participants
will be provided an Information Sheet with a copy of the Privacy Act Statement in
advance of their scheduled interviews. Before beginning the interview, the moderator will
hand participants a hard copy of the Privacy Act Statement, and allow them the chance to
review and ask any questions before continuing. The moderator will verbally explain the
key points of the information found in the Information Sheet. Two of the key points
include participants’ right to refuse to answer any question as well as withdraw from
participation at any time. Participants are also informed in advance that audio of the
session will be recorded. Participants’ names will not be used in any description of
findings or associated with the recordings.
After the moderator summarizes the key points of the information found in the
Information Sheet, the moderator will ensure participants do not have any questions
before proceeding. The moderator will then begin the focus group by asking participants
about their experiences and knowledge of deposit accounts at banks or credit unions. The
rest of the discussion will focus on participants’ specific experiences with financial
exploitation as well as the tools that their financial institutions provide or could provide
to prevent consumers from falling victim to exploitation.

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7. PERSONALLY IDENTIFIABLE INFORMATION:
a. Is personally identifiable information (PII) collected? [ x ] Yes [ ] No
b. If yes, is the information that will be collected included in records that are subject to the
Privacy Act of 1974?
[ X ] Yes [ ] No [ ] Not Applicable
c. Has a System or Records Notice (SORN) been published?
[ x ] Yes [ ] No [ ] Not Applicable
If yes, list the SORN title and FR cite (XX FR XX):.
CFPB.022 – CFPB Market and Consumer Research Records, 77 F.R. 67802
d. If applicable, what is the link to the Privacy Impact Assessment (PIA)?
Consumer Experience Research PIA
https://s3.amazonaws.com/files.consumerfinance.gov/f/201406_cfpb_consumer-experienceresearch_pia.pdf
8. INCENTIVES:
a. Is an incentive provided to participants? [ X ] Yes [ ] No
b. If yes, provide a statement justifying the use and amount of the incentive and the
amount or value of the incentive: $75
Participants will be compensated $75 via a Visa gift card for their participation in the focus
groups. Sessions will last approximately 60 minutes. Participants are encouraged to arrive 10
minutes early to ensure sessions begin as scheduled. Participants may have to travel 30-60
minutes to and from the facility. From past experience, a $75 incentive for a 60-minute session
allows for successful recruitment by increasing the attendance rate while controlling amount of
time required for recruitment. Participants in this age range may also be responsible for
childcare of their grandchildren and therefore may incur the cost of a sitter. When considering
the potential estimated time and cost of participating in this test, such costs as childcare,
transportation, and potential lost wages could result in a high no-show rate. For example,
potential costs for participation include childcare cost of $31, transportation costs of $32, or
potential minimum lost wages of $25 for cost of participation. These are participants’ potential
base costs which does not take into account the amount to incentivize respondents to show and
participate. The basis for our participant cost analysis is outlined below:
•
•
•

Child Care: $31 ($12.5 per hour / per child with up to 1 hour commuting + 1.5 hours at
office for interview = 2.5 hours of child care)
Transportation: $32 (2015 Federal mileage rate of 53.5 cents per mile @ an average of 60
miles).
Minimum Lost Wages: $25 (DC minimum wage of $11.25 per hour x (1 hour commuting
+ 1.25 hours at interview site) = 2.25 hours of potential lost wages). Respondents selected
for this study will be home owners and are likely to have a much higher lost wage cost.
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In summary, given the potential costs of participation, $75 is the minimum incentive necessary to
recruit and retain the desired population. There is also a concern that if the incentive is not
attractive enough to participants, there may be a high no-show rate and the study would need to
be redone in order to obtain quality results. For example, at the $75 incentive level, total
incentives would be $3,600 (48 scheduled participants at $75) verses a study redo at a cost of
approximately $58,460.65. The $75 incentive amount is also the assumed base incentive for
participants in the contract with FMG.

9. ASSURANCES OF CONFIDENTIALITY:
a. Will a pledge of confidentiality be made to respondents? [ ] Yes [ x ] No
b. If yes, please cite the statue, regulation, or contractual terms supporting the pledge.
10. JUSTIFICATION OF SENSITIVE QUESTIONS (if applicable):
11. BURDEN HOURS:
Collection of Information

Web-based Screener
Phone-based screener
Focus Groups
Totals

Number of
Respondents
150
60
48
150*

Frequency

Number of
Responses

1x
1x
1x
/////////////////

150
60
48
258

Response
Time
(hours)
.08
.08
1
//////////////////

Burden
(hours)
12
5
48
65

*Those who participate in the phone-based screener and focus groups are a subset of those who responded to the
web-based screener.

12. FEDERAL COST: The estimated annual cost to the Federal government is $58,460.65.

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13. CERTIFICATION:
CERTIFICATION PURSUANT TO 5 CFR 1320.9, AND THE RELATED PROVISIONS OF
5 CFR 1320.8(b)(3):
By submitting this document, the Bureau certifies the following to be true:
(a) It is necessary for the proper performance of agency functions;
(b) It avoids unnecessary duplication;
(c) It uses plain, coherent, and unambiguous terminology that is understandable to
respondents;
(d) Its implementation will be consistent and compatible with current reporting and
recordkeeping practices;
(e) It indicates the retention period for recordkeeping requirements;
(f) It informs respondents of the information called for under 5 CFR 1320.8(b)(3):
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
(g) It was developed by an office that has planned and allocated resources for the efficient
and effective management and use of the information to be collected;
(h) It uses effective and efficient statistical survey methodology; and
(i) It makes appropriate use of information technology.

CERTIFICATION FOR INFORMATION COLLECTIONS SUBMITTED UNDER A GENERIC
INFORMATION COLLECTION PLAN
By submitting this document, the Bureau certifies the following to be true:
• The collection is voluntary.
• The collection is low-burden for respondents.
• The collection is non-controversial and does not raise issues of concern to other Federal
agencies.
• Information gathered will not be used for the purpose of substantially informing
influential policy decisions.
• The collection is not statistically significant; the results are not intended to be
generalizable beyond the survey population.
• The results will not be used to measure regulatory compliance or for program
evaluation.

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