3170-0048 Field Lab GICP SS-A (2018 Renewal) -OMB_CFPB edits

30-day Federal Register Notice & OMB Review Version (2018 Renewal)

BUREAU OF CONSUMER FINANCIAL
PROTECTION PAPERWORK REDUCTION ACT
SUBMISSION INFORMATION COLLECTION
REQUEST
SUPPORTING STATEMENT PART A
GENERIC INFORMATION COLLECTION PLAN FOR STUDIES OF
CONSUMERS USING CONTROLLED TRIALS IN FIELD AND ECONOMIC
LABORATORY SETTINGS
(OMB CONTROL NUMBER: 3170-0048)

Terms of Clearance: The Office of Management and Budget provided no terms of clearance
when it last approved this generic information collection plan in December 2014.
Abstract: Under the Dodd-Frank Wall Street Reform and Consumer Protection Act, the
Bureau of Consumer Financial Protection (Bureau) is tasked with researching, analyzing, and
reporting on topics relating to the Bureau’s mission, including developments in markets for
consumer financial products and services, consumer awareness, and consumer behavior.
Under this generic information collection plan, the Bureau collects data from purposive
samples through controlled trials in field and economic laboratory settings. This research is
used for developmental and informative purposes in order to increase the Bureau’s
understanding of consumer credit markets and household financial decision-making. Basic
research projects will be submitted under this clearance.
1. Circumstances Necessitating the Data Collection
One of the “primary functions” of the Bureau of Consumer Financial Protection (“Bureau”)
as set forth in section 1021(c) of the Dodd-Frank Act is “collecting, researching, monitoring and
publishing information relevant to the functioning of markets for consumer financial products
and services.” Effectively performing that function is integral to assuring that the Bureau
achieves the purposes and objectives set forth in Sections 1021(a) and 1021(b) of the Act.
To that end, section §1013(b)(1) of the Dodd-Frank Act requires the creation of a research
unit whose “functions shall include researching, analyzing and reporting on” a number of topics
including “consumer awareness, understanding, and use of disclosures and communications
regarding consumer financial products or services;” “consumer awareness and understanding of
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costs, risks, and benefits of consumer financial products or services;” and “consumer behavior
with respect to consumer financial products or services.”

Additionally, section 1013(d)(1) established the Office of Financial Education within the
Bureau, which is responsible for “developing and implementing initiatives intended to educate
and empower consumers to make better informed financial decisions.” Section §1013(d)(3)(B)
requires the Office of Financial Education to work with the Office of Research to “conduct
research related to consumer financial education and counseling.” Using empirical evidence and
rigorous research, the Bureau improves its understanding of consumer awareness, understanding,
and behavior in consumer financial markets, and how to empower consumers in their financial
decisions.

The Bureau seeks to use this generic information collection plan to collect data from
purposive samples through controlled trials in field and economic laboratory settings. The
samples will not be designed to be representative of a broader population.
In general, topics that the Bureau is interested in studying include:
• consumer awareness and decision-making, for example, understanding what financial
products or features people are aware of and why they choose one product over
another;
• consumer experiences, characteristics, beliefs, attitudes, and potential risks
to consumers, including traditionally underserved consumers;
• information disclosure and how disclosure may affect behavior; and
• the effect of educational or other interventions on consumer financial behavior
or outcomes.

These topics will usually be in the context of consumer financial product markets,
including but not limited to: mortgages, car loans, student loans, installment loans, small dollar
loans and credit, debit, and prepaid cards. The research will be used for developmental and
informative purposes, but not directly providing a basis for specific policy at the Bureau with
respect to these markets. In addition, research may be related to the Bureau’s mission regarding
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financial education, including evaluating the effectiveness of financial education programs and
understanding financial planning behaviors, including savings, spending, and investing
behavior. The Bureau envisions that the research covered under this generic clearance will be
basic research about consumer credit markets and household finance.

2. Use of the Information
The specific purpose of this generic clearance is to allow the Bureau to better inform
and advance scientific understanding of consumer credit markets and household finance.
The Office of Research envisions a program of data collections, and this generic clearance
will allow it to monitor and research market developments in a timelier manner. In addition,
the Bureau envisions that occasional unique opportunities to answer fundamental research
questions about consumer finance will arise with external collaborators, and this clearance
will allow it to move quickly to take advantage of those situations where the timeline is
further outside our control.
The purpose of research conducted under the expected clearance is not to make particular
regulatory decisions, evaluate specific policies, or substantially inform a rulemaking. Studies
conducted under this generic approval may identify opportunities for enhanced or improved
regulatory or other policy actions; however, as noted, the Bureau will not initiate any policy
changes based solely or primarily on these research projects. Instead, this generic clearance
covers studies with developmental and informative purposes. Research studies under this
generic clearance only include purposive samples that are not designed to be representative of a
broader population.
The Office of Research will continue to monitor research projects to ensure that
projects included under this generic clearance are NOT:
• Nationally representative samples or samples that try to estimate parameters related to
populations of regulatory interest.
• Statistics that are intended to be published to the public as an official government
statistic to be externally valid and representative of a population of interest.
• Research projects intended to inform particular regulatory decisions or developing
or evaluating specific policies (e.g., testing of a disclosure form that is intended to
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later be promulgated in a CFPB rule).

These projects are intended to be internally valid, but not necessarily externally valid.
They are intended to improve our methods and understanding of consumer decision-making.
Research projects under this generic clearance may include pretesting and cognitive
interviewing prior to the data collection. The Office of Research will generally pretest
questionnaires and other user-interfaces to ensure the collection of reliable information while
minimizing respondent burden and costs. Cognitive testing ensures that a question posed to
respondents successfully captures the intent of the question and that it makes sense to
respondents. It can also be used to better understand research results by providing data about
why participants responded to questions the way they did. The Bureau may also rely on
pretesting to ensure that necessary computer hardware and software function appropriately.
This generic clearance will allow the Bureau to conduct data collections that will
achieve our research project goals with the least amount of burden on the public, and while
ensuring strong privacy and data protections throughout these projects. Collections under
this clearance will be limited to situations in which sufficient data do not already exist but
could be collected through data from purposive, non-representative samples.

3. Use of Information Technology
The Bureau will employ information technology as appropriate to reduce the burden of
respondents who agree to participate in its research. Computer-assisted participation will be used
when feasible and appropriate, including online studies. In general, the Bureau intends to
incorporate electronic data-collection techniques whenever possible, particularly since in many
instances they are likely to impose the lowest burden on respondents and may be the most costeffective. However, the extent to which the Bureau will use electronic data collection for a given
project will be determined by weighing several factors, including response rates and costs. For
example, evidence to date suggests that web-only data collections tend to have lower response
rates than surveys conducted by mail or phone. 1 The Bureau expects that the most effective

1

Roger Tourangeau, Fredrick Conrad, and Mick Couper (2013), “The Science of Web Surveys.” USA:

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mode, including mixed-mode combinations, may also vary with the complexity and sensitivity of
the information to be collected.

4. Efforts to Identify Duplication
The Bureau will conduct controlled trials in field and economic laboratory settings to
answer questions that have not yet been satisfactorily addressed in the relevant research
literature. In some cases it will be appropriate to replicate previous laboratory and field studies
within a new population of interest to the Bureau (such as military service members, students,
older Americans, or people who utilize specific financial products), or if a change in market
circumstances suggests that prior research may no longer be applicable. In these cases, the
Bureau will detail the relationship between the proposal and existing studies and will describe
how the data collection supports the Bureau’s mission. A review of the existing relevant
literature will be undertaken before proceeding with a project.

5. Efforts to Minimize Burdens on Small Entities
All of our research projects will be limited to individual consumers, not businesses, so
there will be no impact on small businesses or other small entities.

6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction
The proposed generic clearance will allow the Bureau to collect a variety of types of data
to develop a more complete understanding of consumers’ decision-making regarding consumer
financial products and the characteristics of markets for these products. This knowledge will
improve the Office of Research’s ability to inform the Bureau in developmental and formative
ways.
The ability to collect data through controlled trials in field and economic laboratory
settings allows the Bureau to control both the timing and direction of the research. By contrast,
relying on naturally occurring data would leave the timing, content, and sample population
outside of our control. These research projects allow the Bureau to isolate cause and effect by
using randomization to control for variables that are unknowable or un-measurable in natural
Oxford University Press.

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settings. In addition, these studies may be the best way to explore consumer behavior in novel
environments, such as with emerging financial products.
For these reasons, data collections under this generic are important and valuable to the
Bureau. Without these data collections, the Bureau will not be able to achieve its mission to
understand consumer financial markets, consumer decisions and outcomes in these markets,
and how to improve the effectiveness of information provided to consumers in consumer
financial markets. 2
In addition, Congress has mandated that the Bureau, in consultation with the Financial
Literacy and Education Commission and consistent with the National Strategy for
Financial Literacy, “develop and implement a strategy to improve the financial literacy of
consumers that includes measurable goals and objectives.” (12 U.S.C. 5493 Sec.
1013(d)(1). The CFPB will be unable to carry out this mandate if it does not have
information about consumer experiences navigating the financial marketplace and what
strategies can improve financial literacy. Without periodic information collections on
consumer experiences and best practices in financial education, the Bureau will not have
timely information to adjust its programming to meet consumer needs.
7. Circumstances Requiring Special Information Collection
Most information collections under this generic clearance will require a single interaction
between the agency and respondents, but some information collections could require multiple
interactions. For example, some studies may ask for respondents to return to the lab more than
once, and this could occur within a single quarter. Note that in such cases the respondent would
not typically have any burden beyond that single quarter. The CFPB will work to limit the
burden on respondents and ensure that studies only include repeated interactions when the
additional information gained is anticipated to be substantial and valuable to the study.
Generally, there are no special circumstances. The collection under this generic
information collection plan is conducted in a manner consistent with the guidelines in 5 C.F.R.
1320.5(d)(2).
8. Consultation Outside the Agency
2

Bureau of Consumer Financial Protection Strategic Plan FY 2018 - 2022, Goal 1,
https://www.consumerfinance.gov/about-us/budget-strategy/strategic-plan/

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In accordance with 5 C.F.R. 1320.8(d)(1), the Bureau published a Federal Register notice
(FRN) allowing the public 60 days to comment on this proposed extension of a currently
approved collection of information on October 3, 2017. The Bureau received two responsive
comments regarding this information collection. The first was supportive of the Bureau’s work
presented at a 2016 workshop using data collected by the Bureau. The second commenter
expressed concerns with adding fields to existing forms without first measuring effects.
Renewal of this clearance will allow the Bureau to study generally the effects of regulatory
intervention in the consumer finance market. Further, and in accordance with 5 C.F.R.
1320.5(a)(1)(iv), the Bureau published a notice in the Federal Register on December 29, 2017
allowing the public 30 days to comment to OMB on the submission of this information
collection request.
9. Payments or Gifts to Respondents
In order to support the mission of the CFPB, Bureau researchers are fundamentally
interested in questions such as how consumers use information to make choices and their
behavior in consumer financial markets.
Controlled trials in field and economic laboratory settings are an important tool for
addressing these questions. In experiments, the researcher strips away extraneous features of the
marketplace, leaving only the essence of the economic environment and the institutions that
govern it, placing these factors under the researcher’s control.
To ensure that the behaviors exhibited in these environments relate to behavior in other
settings, the incentives motivating the behavior must be similar. This is difficult to achieve if
subjects are presented with purely hypothetical scenarios since participants’ choices may be
guided by a variety of motivations. 3 For this reason it is standard practice in the sub-discipline
of experimental economics to compensate subjects. 4 Sometimes subjects are paid a fixed
amount for their participation, in essence appreciation for their time, but also additional money
based on their choices in the study. Participants may be paid different amounts depending on

3

Rachel Croson (2005), “The Method of Experimental Economics,” International Negotiation 10: 131-148.

4

Vernon L. Smith (1976), “Experimental Economics: Induced Value Theory,” American Economic Review
66(2): 274-279.

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the actions they take during the study. 5 The Bureau will provide the amount of any proposed
incentive and a detailed justification for each information collection request submitted under
this generic plan.
The Bureau plans to pay no more than $40 per subject for one hour of participation in a
laboratory study, and $50-75 per subject for a 1 ½ to 2 hour focus group session. If the Bureau
plans to exceed these standard rates, the justification will be addressed with OMB on a case-bycase basis.
10.

Assurances of Confidentiality

As applicable, the Bureau shall treat the information in accordance with applicable
federal law, including but not limited to the Bureau’s confidentiality rules, 12 C.F.R. Part
1070, and the federal laws and regulations that apply to federal agencies for the protection
of privacy, confidentiality, security and integrity. To the extent a pledge of confidentially
is provided to respondents of covered studies, the Bureau will accompany such a pledge
with the legal authority and discuss accordingly with the accompanying submission to
OMB.
When collecting information about consumer credit markets, the Bureau recognizes that
there are privacy and data security risks. The Bureau uses best practices of social science
research design to inform the notice and consent vehicles. When required and when practicable,
the Bureau provides notice to individuals that explain how their information will be used
through appropriate vehicles, such as Privacy Notices, Privacy Act Statements or Informed
Consent forms. Such notice is typically made available prior to the collection of information
and explains whether the information is mandatory or voluntary; whether there are any
opportunities to consent to sharing and submission of information; how the information will be
secured and when a System of Records is created under the Privacy Act. In some instances,
research may be based on observations or on information collected directly from a third party,
and notice and consent may not be applicable.
When the Bureau collects information from third parties, commercial sources, and public

5

Colin Camerer and Robin Hogarth (1999), "The Effects of Financial Incentives in Experiments: A Review and
Capital-Labor-Production Framework" Journal of Risk and Uncertainty 19:7-42.

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databases, individuals to whom information may pertain do not have the opportunity to consent
to uses, decline to provide information, or opt out. In such cases, it is those third parties’
responsibility to provide any opportunity that may be required to consent, decline, or opt out of
how their information may be used. As part of the due diligence process, the Bureau reviews
the privacy policies or other public disclosures from the third-parties regarding their use of the
information to verify that there are no contradictions with the research, and the Bureau
encourages the development of notice and consent opportunities.
The Bureau also evaluates the potential privacy risk and harm to individuals of specific
research relative to that authorized purpose, and vets research proposals to ensure that they
serve an authorized purpose.
The information collected under this generic clearance may include direct identifying
personally identifiable information (PII). Typically direct identifying PII consists of
contact information used to facilitate administration of research, and is separated from
response data generated from the research. When the Bureau does use direct identifying
PII in analyses, it does so in order to a) match across datasets; b) update data sets; c)
weight datasets in order to make generalizations regarding a given population; and d)
contact potential recipients of our studies to solicit information on consumer experiences
with consumer financial products and services.
Conducting field and lab studies implicates privacy concerns because a breach of
confidentiality, or re-identification, could result in an individual suffering harm. To reduce the
risk of breaches of confidentiality, the Bureau designs recruitment materials so as not to
disclose sensitive information about those it seeks to recruit, and uses appropriate security
controls to protect information used in research. There is also risk related to misuse of
information collected for research. Misuse might involve secondary types of research that are
incompatible with the purposes of the initial collection, or a use of the information that
individuals do not understand or to which they have not provided consent.
To reduce the risk of misuse, the Bureau minimizes access to PII based on need-to- know
and stipulates, in most instances, that contractors that collect data on behalf of the Bureau
remove or redact all direct identifying PII, as defined by the Bureau’s privacy office, before
transmitting data to the Bureau. Any contractor staff assigned to the project also sign

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confidentiality agreements. When appropriate, research results will be presented in aggregated
form to protect the confidentiality of firms or consumers, and any publicly released version of
data will use disclosure protection techniques (e.g., rounding, imputation, exclusion of some
variables, aggregation of categorical responses) to minimize the risk of releasing personally
identifiable or otherwise sensitive information (12 C.F.R. 1070.40 et seq.). The Bureau treats
the information collected from participating persons and institutions in a manner consistent with
our confidentiality regulations, and all data and analyses are subject to legal and privacy review
prior to their release.
Field and lab research will be conducted consistent with the Privacy Act and the EGovernment Act. The requisite SORNs and PIAs will document the collection, use,
disclosure, and retention of PII; the technical, administrative, and physical controls used to
minimize privacy risks. The SORNs and PIAs will so be updated to reflect any changes. 6
Specific details regarding information handling will be specified in individual submissions
under this generic clearance, but will conform to these broad guidelines.
When collecting information about consumer credit markets, the CFPB recognizes that
there are privacy and data security risks. The Bureau outlines the way it plans to mitigate these
risks when collecting data using this generic clearance later in this supporting statement. 7

11.

Justification for Sensitive Questions

Questions about an individual’s finances, for example how much a person makes or how
much their mortgage costs each month, are commonly considered sensitive.
Nonetheless, the Office of Research must sometimes ask such questions in order to
understand consumer behavior and recognize financial trends and emergent risks relevant to
consumers. The Bureau believes that it is justified in asking these types of sensitive questions
because they are central to our mission.
6

The CFPB has two SORNs that will cover field and lab research: CFPB.021 Consumer Education and
Engagement Records, 77 FR 60382; and CFPB.022 Market and Consumer Research Records, 77 FR
67802.

7

On June 30th 2014, the CFPB published a Privacy Impact Assessment (PIA) for Consumer Experience
Research that covers some of the data that will be collected under this generic clearance. Other PIAs will be
published by the CFPB in the future that will likely cover data collected under this generic clearance as well.
http://files.consumerfinance.gov/f/201406_cfpb_consumer-experience-research_pia.pdf

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In addition, some people may believe that questions about race or other socioeconomic
factors may be considered sensitive. However, the Bureau is mandated to enforce fair lending
laws and focus on the risks to vulnerable populations, including service members, older
Americans, and lower-income consumers. For this reason, the Bureau often needs to ask these
types of sensitive questions. For information collections involving questions of race/ethnicity,
the Bureau will ensure that the OMB standards for Classification of Federal Data on Race and
Ethnicity (Federal Register, October 30, 1997, Volume 62, Number 210, pages 58781-59790)
are followed.
Respondent participation and all activities within the laboratory setting are voluntary, and
subjects will be made aware of this fact. All respondents are free to opt-out of a data collection
at any time and for any reason. Respondent participation in certain field studies that rely solely
on indirect observation may not be voluntary and individual may not receive direct notice. In
such cases, the Bureau does not intend to identify those individuals; uses standard social science
research practices, including use of research review boards, to minimize risks of negative
impacts to the Respondents; and vets field research to ensure they serve an authorized purpose.
The Bureau will ensure that a citation is made to any applicable System of Records Notice
(SORN), and a Privacy Impact Assessment (PIA) in the individual submissions under this
generic clearance and published research.
12.

Estimated Burden of Information Collection

The following tables present estimates of the total number of respondents and burden
hours for proposed collections. The number of respondents and average burden per response
for a specific collection will depend on the methodology used for gathering information. These
estimates, as well as the mix of collection methods used, may be adjusted. Further details on
estimated respondents and burden will be provided in each approval request. The total number
of burden hours estimated under this generic clearance is 38,400 hours.
The Bureau has started various research projects and will likely continue a similar structure
for conducting research over the next three years. Within each project there will probably be
multiple rounds of data collection to thoroughly learn about a topic of interest.

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There will be two styles of economic studies conducted in the lab: individual decision
making tasks and group level interactions. These two types of studies have different time
requirements. Individual tasks typically take less time for participants to complete, allowing the
Bureau to conduct many more of these studies each year. The Bureau has estimated the number
of participants per project and timing requirements on very common practices in the field as well
as specific research ideas. For group level tasks, the Bureau bases its time estimates on our
experiences over the past three years.
A separate line of research concerns economic studies in the field. For these types of
projects, the Bureau will sometimes conduct a short survey in order to choose a subset of
respondents to participate in a much longer data collection (sometimes over the following
months).

Exhibit 1: Burden Hour Estimate for All Data Collections, 3-yr period
Types of Projects

Total

Total

Respondents Hours
Lab Studies

24,600

20,400

Field Studies

18,000

18,000

Total all projects for 3 years

42,600

38,400

Exhibit 1a: Burden Hour Estimate for Economic Studies in the Lab, 3-yr period
Number of

Rounds per

Respondents

Total

Hours per

Total

Projects

Project

per Round

Respondents

Respondent

Hours

3

3

600

5,400

2

10,800

6

4

800

19,200

.5

9,600

Total

24,600

20,400

Exhibit 1b: Burden Hour Estimate for Economic Studies in the Field, 3-yr period
Total Respondents

Number of
Respondents per
Project
12
1,500
Total

Hours per Respondent

Number of Projects

18,000
18,000
12

1
18,000

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For each specific collection request submitted under this generic plan, a detailed estimate of the
burdens of that particular request will be submitted.

13.

Estimated Total Annual Cost Burden to Respondents or Recordkeepers

There will be no capital, operating, or maintenance costs to respondents as a result of
participation in any information collection submitted under this generic clearance plan.

14.

Estimated Cost to the Federal Government

For each data collection that falls under this generic clearance, costs to the Federal
government will be estimated.

15.

Program Changes or Adjustments
Total

Annual

Respondents

Responses

Total Annual Burden

Burden Hours

42,600

42,600

38,400

26,100

26,100

27,000

+16,500

+16,500

+11,400

+16,500

+16,500

+11,400

Requested
Current OMB
Inventory
Difference (+/-)
Program Change
Discretionary
New Statute
Violation
Adjustment

Based on research the Bureau has conducted over the last three years we have better
estimates of what we will pursue in the next three years. The increase in burden is not due to any
new statutory or regulatory requirements.

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16.

Plans for Tabulation Statistical Analysis or Publication

The Bureau’s research projects are intended to expand scientific understanding of
consumer decision-making in financial domains. Research findings will be published as
technical articles that are publicly disseminated as working papers, published in peer- reviewed
journals, or published as Bureau white papers. Collection, analysis, and publication of data will
span the entire period of the anticipated generic clearance. The Office of Research plans to
conduct an ongoing program of research and therefore plans to apply for an extension to the
anticipated generic clearance when it expires.
Because of publication lag, a typical academic journal article is published one or more
years after initial submission. Data collection for a professional publication typically takes at
least three to four months, and in some cases could be longer. Data analysis and article
preparation typically lasts another three to four months. Thus, professional articles in a peerreviewed outlet of any kind are estimated to be published from 12 months to 36 months from
the time that data collection begins. 8 The publication process for Bureau in-house products is
shorter than that for external academic publications.
Research projects submitted under this generic clearance will not be published to the
public as official government statistics that are representative of a broader population. In
particular, these projects will never involve nationally representative samples. Instead,
publications will be along the lines of academic research, exploring consumer decision-making
and behavior.
17.

Display of Expiration Date
The Bureau plans to display the expiration date for OMB approval of the information

collection on all instruments. Further, the OMB control number and expiration date will be
displayed on OMB’s public PRA docket at www.reginfo.gov.

8

P.K. Trivedi (2006), “An Analysis of Publication Lags in Econometrics” Journal of Applied Econometrics 8(1):
93-100.

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18.

Exceptions to the Certification Requirement
The Bureau certifies that this 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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