Supporting Statement A_3170-0038 2016 Renewal 30-day FRN

30-day Federal Register and OMB Review

CONSUMER FINANCIAL PROTECTION BUREAU
INFORMATION COLLECTION REQUEST
SUPPORTING STATEMENT PART A
EVALUATION OF FINANCIAL EMPOWERMENT TRAINING PROGRAM
(OMB CONTROL NUMBER: 3170-XXXX (formerly, 3170-0038)

NOTE TO REVIEWER: We have now streamlined multiple sets of surveys into one set of
survey instruments needed to evaluate multiple versions of the tools associated with the financial
empowerment training program and, therefore, OMB# 3170-0038 no longer needs to be a
generic information collection plan. Accordingly, as with the original Office of Management and
Budget (OMB) approval, we are requesting a standard Paperwork Reduction Act (PRA) approval
for the evaluation instruments included in this PRA renewal request (See OMB Notice of Action
dated August 2, 2013). There is the possibility that revised surveys will be developed to support
revisions to a set of supplemental materials currently in development. We do not anticipate
substantive changes to accommodate these new products, and any new surveys will be submitted
for review should the situation arise.
Additionally, since the Bureau is converting this OMB approval from a generic PRA approval to
a standard PRA approval, OMB has requested that the Bureau obtain a new OMB control
number for these forms. Upon OMB approval of this request, OMB No. 3170-0038 will be
discontinued.
TERMS OF CLEARANCE: OMB provided no Terms of Clearance when it originally
approved this collection of information on August 2, 2013.
ABSTRACT: The Bureau’s Office of Financial Empowerment (Empowerment) is responsible
for developing strategies to improve the financial capability of low-income and economically
vulnerable consumers, such as consumers who are unbanked or underbanked, those with thin or
no credit file, and households with limited savings. To address the needs of these consumers,
Empowerment has developed the Your Money, Your Goals toolkit and training program. These
resources equip frontline staff and volunteers in a range of organizations to provide relevant and
effective information, tools, and technical assistance designed to improve the financial outcomes
and capability of these vulnerable consumers. The Bureau seeks to renew OMB approval to
collect qualitative data related to evaluating the effectiveness of these toolkits, collateral
materials, and training program. The proposed collections will focus on evaluating: (1) Your
Money, Your Goals training practices, toolkit, and collateral materials in enhancing the ability of
frontline staff and volunteers to inform and educate low-income consumers about managing their
finances; (2) and to assess the scope of workshop participants’ use of the resources with the
people they serve. The Bureau expects to collect qualitative data through paper-based and webbased surveys.
A. JUSTIFICATION
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1. Circumstances Necessitating the Data Collection
Under the Dodd-Frank Wall Street Reform and Consumer Protection Act, Public Law No. 111203 (Dodd-Frank Act), including Section 1013(b)(2), CFPB has a mandate to “provide
information, guidance, and technical assistance regarding the offering and provision of consumer
financial products or services to traditionally underserved consumers and communities.” The
CFPB has established the Office of Financial Empowerment to focus on low-income and other
economically vulnerable consumers to help ensure they have access to financial products and
services that meet their needs and to have the knowledge they need to use them effectively. To
fulfill this mandate, Empowerment developed, field tested, and released multiple versions of
Your Money, Your Goals, including toolkits that are specialized for social services programs
(released in 2014), legal aid programs, community volunteer organizations, and worker
organizations (all released in 2015). In addition, Empowerment is currently developing a series
of three guides focused on Native Americans, persons with disabilities, and justice-involved
individuals.
The CFPB is currently collecting data under OMB Control Number 3170-0038 that are
informing revisions and enhancements of the Your Money, Your Goals (YMYG) toolkit and
training program. Through this collection, data will continue to be collected from two sets of
respondents. The first is the group of trainers identified by participating public and private
organizations, some of whom will participate in an initial web-based training and others of
whom will participate in face-to-face training provided by the CFPB’s contractor. The second
respondent group is comprised of frontline staff and volunteers who will participate in
workshops led by these trainers. The primary resources currently used during these trainings are
the Your Money, Your Goals toolkits and will later include a new series of guides and
supplemental materials currently in development.
The information collection is low-burden, voluntary, qualitative, and is not being used to inform
Bureau policy. The objective of this data collection is to provide Empowerment with qualitative
data that will inform continued improvements and revisions to the toolkit, materials, and training
program.
2. Use of the Information
The resources used in this program are designed to enhance the ability of frontline staff and
volunteers to inform and educate low income consumers about managing their finances and
about strategies for making choices among available financial products and services available to
them. Staff from CFPB will use data from surveys of trainers and workshop participants to
collect qualitative input concerning the training practices and resources used in this program. The
results of this analysis will inform the CFPB’s subsequent revisions to Your Money, Your Goals
and the training program. Data that are collected through follow-up surveys will also provide
information about the scope of workshop participants’ use of the training and the materials.
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The pre- and post-training surveys are designed to determine participants’ confidence in
understanding financial topics and providing information to the people they serve. Their responses to
these surveys and the follow-up survey will inform future iterations of the toolkit and training
program.

Supplemental, curated subsets of tools are now in development. As each tool set is projected to have
a limited focus, CFPB may consider adapting the instruments cleared under this ICR for use in
trainings that focus solely on these supplemental materials and training related to them. Survey
responses would, as in the broader program, inform future revision to the tool sets and training. The
CFPB anticipates that revisions to the survey instruments will not be substantive. However, as noted
above, all revisions will be submitted and approved by OMB prior to use.

3. Use of Information Technology
Nearly all of the data for this collection will be collected will be through paper instruments. CFPB
determined that asking trainers and staff and volunteers to submit data through paper instruments
would be less burdensome than asking them to do so electronically prior to and immediately
following a training, primarily because of the respondent burden associated with tracking electronic
responses. The follow-up surveys will be both web-based and paper-based to facilitate participant
response.

4. Efforts to Identify Duplication
Your Money, Your Goals is a financial empowerment toolkit and training program unique to the
CFPB. Consequently, this collection is not duplicative of other government efforts. The CFPB will
continue to monitor research on the topic of training frontline staff and volunteers to ensure that the
techniques used in this data collection are informed by those efforts and reflect current knowledge
and best practices and are not duplicative.

5. Efforts to Minimize Burdens on Small Entities
The data collection is not anticipated to burden small entities because all information collection will
occur from individuals. Further, all instruments have been reviewed and questions in Instrument 3B
regarding perceived usefulness of modules and tools have been removed to ensure that only
necessary data are collected.

6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction
Trainers will complete surveys following their workshops and participants will complete surveys
immediately prior to and following the workshops. In addition, follow-up surveys may be
conducted three and six months thereafter. Less frequent collection would result in a reduced
ability to monitor the quality of the trainings, the perceived impact of the training and toolkit on
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potential users’ ability to discuss financial management topics with the people they serve, and
their actual usage of information and tools with individuals.
7. Circumstances Requiring Special Information Collection
There are no special circumstances. The collection of information is conducted in a manner
consistent with the guidelines in 5 CFR 1320. 5(d)(2).
8. Consultation Outside the Agency
In accordance with 5 C.F.R. 1320.8(d)(1), the Bureau has published a notice Federal Register
allowing the public 60 days to comment on this proposed extension of this currently approved
collection of information. No comments were received in response to this notice. Further and in
accordance with 5 C.F.R. 1320.5(a)(1)(iv), the Bureau published a notice in the Federal Register
allowing the public 30 days to comment on the submission of this information collection request
to the Office of Management and Budget.
9. Payments or Gifts to Respondents
No payments or gifts will be provided to respondents in exchange for submitting data.

10. Assurances of Confidentiality
In the directions for each instrument, respondents will be informed that the data they provide will not
be associated with their organization in any analysis or reports that derive from the data collection.
Each instrument will contain the following statement: “Please note that the Bureau intends to keep
your responses private to the extent permitted by law, and when survey results are reported none of
your answers will be connected to you or your organization.”
This collection is covered by the Consumer Education Privacy Impact Assessment, dated 15
September 2014 and is available on CFPB’s website at
http://files.consumerfinance.gov/f/201409_cfpb_consumer-education_pia.pdf .

11. Justification for Sensitive Questions
This information collection does not include questions of a sensitive nature, such as sexual behavior
and attitudes, religious beliefs, race/ethnicity, disability, social security numbers, or any other matters
generally considered private.

12. Estimated Burden of Information Collection
There are two groups of respondents for this collection: 1) trainers that lead Your Money, Your
Goals workshops for staff or volunteers in social services, legal aid, community, and worker
organizations; 2) participants in those workshops. We anticipate that annually a total of 750
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trainers and 15,000 workshop participants will provide survey responses.
Because many trainers lead more than one workshop annually, we anticipate that a total of 2,000
annual responses to Instrument 2 will be submitted. Therefore, With the exception of Instrument
2, are all one-time data collections. The trainers submit an Instrument 2 form each time they
deliver training. The use of each 3A and B survey instrument occurs only once by each
workshop participant. Burden hours rounded to the nearest whole hour.
The average response time for each instrument is based on users’ experience under the previous
clearance. Hourly rates were calculated using Bureau of Labor Statistics data for median hourly
wages of Training and Development Specialists 1 and for Social Workers, All Other. 2 This
category of Social Workers was chosen because the overwhelming majority of workshop
participants (85%) will come from social services organizations and represent a wide range of
practice specialties.
The burden captured in below in Exhibit 1 includes the burden for the information collected on
the currently approved instruments as well as the projected burden for instruments associated
with planned versions of the YMYG toolkit.
Exhibit 1: Burden Hour Summary
Information Collection
Instrument 1: Train-the-Trainer
Feedback Survey
Instrument 2: Trainer Feedback
Following Usage
Instrument 3A: Your Money,
Your Goals Training, Presurvey (evaluation forms from
frontline staff and community
volunteers)
Instrument 3B: Case Manager
Training, Post-survey
(evaluation forms from
frontline staff and community
volunteers)
Instrument 4: Follow-Up
Survey for frontline staff and
community volunteers
Annual Totals:

No. of
Respondents

Frequency

Annual
Responses

Average
Response
Time
(hours)

Annual
Burden
Hours

Hourly
Rate

Hourly
Costs

750

One-time

750

0.17

128

$27.57

$3,529

750

On occasion

2,000

0.08

160

$27.57

$4,411

15,000

One-time

15,000

0.08

1,200

$28.08

$33,696

15,000

One-time

15,000

0.17

2,550

$28.08

$71,604

15,000

One-time

15,000

0.42

6,300

$28.08

$176,904

15,750*

///////////////

47,750

/////////////

10,338

//////////

$290,144

*Note: Unduplicated count of Respondents.

13. Estimated Total Annual Cost Burden to Respondents or Recordkeepers

1
2

See http://www.bls.gov/oes/current/oes131151.htm. Accessed March 14, 2016.
See http://www.bls.gov/oes/current/oes211029.htm. Accessed March 14, 2016.
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There are no capital/start-up or ongoing operation/maintenance costs associated with this information
collection.

14. Estimated Cost to the Federal Government
The estimated annual cost to the Federal Government of this collection is $65,000.
15. Program Changes or Adjustments
Due to the expanded use of the YMYG toolkits, the program has been expanded and in its steady
state now anticipates that annually 15,000 individuals will participate in YMYG trainings and
complete surveys. This change has resulted in an adjustment of 4,808 hours.
Questions were added to Instrument 4, “Follow-Up Survey for Your Money, Your Goals users,”
in order to better gauge the effectiveness of YMYG materials for uses which resulted in the
estimated response increasing from 10 to 25 minutes, a net program change of 370 hours. Other
revisions to the forms did not result in a net change to the estimated response times.
Exhibit2: Summary of Burden Changes
Total Annual Burden
Requested
Current OMB Inventory
Difference (+/-)
Program Change
Discretionary
New Statute
Violation
Adjustment

Total Respondents
15,750

Annual Responses
47,750

Burden Hours
10,338

Cost Burden (O & M)
$0

7,240
8,510

24,990
22,760

5,160
5,178

$0
$0

370

4,808

Since the Bureau no longer needs a generic PRA approval for the Your Money, Your Goals
evaluation instruments, OMB control number 3170-0038 is being discontinued and a new OMB
control will be assigned upon OMB approval of this renewal request. Additionally, upon OMB
approval of this request, OMB control number 3170-0038 will be discontinued.

The above Summary of Burden Changes is provided so OMB and the public can see the actual
burden changes associated with the Your Money, Your Goals evaluation instruments. However,
since a new OMB control number will be assigned to these collection instruments, a new burden
of 10,338 hours will be inventoried under the new OMB control number.
16. Plans for Tabulation, Statistical Analysis, and Publication
As the program is ongoing, the CFPB anticipates that data collection under this renewal will
begin within one week of OMB approval. CFPB’s contractor will conduct the initial analysis and
summary of the study findings.
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For qualitative, open-ended questions, ICF will conduct a thematic analysis. For closed-ended
questions in which respondents are asked to select one of several different response options, the
contractor will use frequencies and cross-tabulations in its analysis. For questions that ask
respondents to provide a numerical answer, the contractor will calculate frequencies, means,
medians, ranges, and standard deviations.
Information collected provides useful information, but it does not yield data that can be
generalized to the overall population. Information gathered is intended to primarily be used
internally to inform Your Money, Your Goals program development and is not intended for
release except in summary. If this information is shared, the CFPB will indicate the qualitative
nature of the information.
17. Display of Expiration Date
The CFPB plans to display the expiration date for OMB approval of the information collection
on all instruments. Additionally, the OMB number and expiration will be displayed on OMB’s
public-facing docket at www.reginfo.gov.
18. Exceptions to the Certification Requirement
The Bureau certifies the collection of information is consistent with the requirements of 5 C.F.R.
1320.9, and the related provisions of 5 C.F.R. 1320.8(b)(3) and is not seeking an exemption to
these certification requirements.

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