3170-0048 Field Lab GICP SS-B (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 B
Generic Information Collection Plan for Studies of Consumers using Controlled
Trials in Field and Economic Laboratory Settings
(OMB CONTROL NUMBER: 3170-0048)
1. Describe (including a numerical estimate) the potential respondent universe and any
sampling or other respondent selection method to be used. Data on the number of
entities (e.g., establishments, State and local government units, households, or persons)
in the universe covered by the collection and in the corresponding sample are to be
provided in tabular form for the universe as a whole and for each of the strata in the
proposed sample. Indicate expected response rates for the collection as a whole. If the
collection has been conducted previously, include the actual response rate achieved
during the last collection.
The potential respondent universe will vary depending on the research question
addressed and method of data collection employed. All samples under this generic clearance
will be purposive and non-representative, and not intended to be externally valid or
representative of a broader population.

2. Describe the procedures for the collection of information.
The Bureau plans to gather primary data from purposive samples through controlled
trials in field and economic laboratory settings. The sections below outline the types of data
collections that the Bureau plans to conduct.
Trials may be broadly categorized into laboratory and field settings.
A laboratory setting provides researchers with a high degree of control over the
research environment for a wide range of possible studies. Participants may be placed in
situations that isolate features of economic activity or decision-making to be studied in
detail. The researcher may have them interact to provide insight into how people share
information, solve problems, and make choices in competitive or cooperative environments.
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One advantage of the lab setting is standardization. The researcher can ensure that
participants are given the same instructions, placed in similar contexts, and otherwise treated
the same way. Respondents are often asked to use computer software or online resources in
order to standardize their experience and reduce measurement error in collecting their
responses. Online lab settings are growing in popularity for this reason, and the Bureau may
employ this type of setting for a lab study.
Another benefit of the lab setting is the quantity and quality of possible observations.
Researchers may reproduce events in the lab that occur sporadically or unpredictably in a
real world setting and would otherwise be difficult to observe. A lab setting may also
facilitate collection of data on gaze (enabling inferences about attention) and on reaction
times (enabling inferences about the ease of processing information).
Subjects for lab research are typically recruited using convenience sampling. This
means that lab research samples are not representative of the general population, and
therefore are not useful for estimating specific parameters or the costs and benefits of a
policy. The studies conducted under this clearance are for basic scientific research and not to
generate statistics about a broader population. Although convenience sampling may introduce
selection bias that could limit the applicability of the lab findings to other contexts, in many
cases a laboratory provides a credible economic environment where the results of the study
can be useful for informing hypotheses about behavior outside the lab. For example, if a
laboratory study showed that one information format resulted in decisions different than
another information format, researchers could reasonably expect that the pattern may be
similar among other populations. Although this research will not generate statistics that
would be used to describe population parameters, it can provide a foundation for a scientific
understanding of consumer financial decisions and behavior in consumer financial markets.
A field setting allows researchers to see how economic activity operates in real world
environments. It generally allows for research studies to occur over a longer period of time
than in a lab. Respondents may be recruited from a variety of sources, including through web
panels and existing channels of economic interaction; for example, users of a given financial
product or service. Outcome data generally comes from some mix of existing administrative
sources, which do not burden the participants, and from data collection instruments, such as
surveys, that are designed to gather the minimal amount of additional data required to
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conduct the research.
The Bureau plans to use research studies under the proposed clearance to learn about
behavior in markets and to test research hypotheses. Results and findings from these research
studies are designed to be used for developmental and informative purposes. The CFPB will
not make regulatory decisions solely based on these studies or use these studies to develop or
evaluate specific policies.
Studies will often take the form of a randomized controlled trial (RCT).
Identifying causation is often essential in research to determine the effects on
consumers of a particular factor (e.g.: a financial product, disclosure form, or financial
education training). In observational studies, there is often reason to believe that people who
differ in exposure to the factor of interest also differ in other ways. For example, consumers
who use a particular strategy for managing their finances may, on average, differ in many
characteristics (education, employment status, income, etc.) from those who do not. In such a
case, it would be incorrect to conclude that the financial strategy alone accounted for
differences in outcomes between those who use it and those who do not.
Failing to account for relevant characteristics leads to bias in a researcher’s estimate
of whether a causal relationship exists and how strong or statistically significant it is. Since
many of these characteristics are unobservable to the researcher, observational studies pose
problems for causal inference.
In general, researchers are unable to observe a counterfactual for a given person; that
is, they cannot observe what the outcome would have been if a person not exposed to the
factor had been exposed and vice versa. Randomization of research participants into a
treatment group that is exposed to the factor and a control group that is not exposed or is
exposed to a lesser extent allows the researcher to determine whether the observed outcomes
were caused by the factor.
A randomized controlled trial (RCT) is designed to overcome the selection bias
problem. It uses a control group as a valid counterfactual for the treatment group. For a
sufficiently large sample, the treatment and control groups will look very similar to one
another since no participant characteristics are used in a random assignment, other than in a
stratified approach where they are balanced by construction. This similarity can be verified
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for observable characteristics and safely assumed for unobservable characteristics.
Differences in outcomes observed after comparing treatment and control groups are therefore
attributable to the treatment factor.
3. Describe methods to maximize response rates and to deal with issues of non- response.
The accuracy and reliability of information collected must be shown to be adequate for
intended uses. For collections based on sampling a special justification must be
provided for any collection that will not yield “reliable” data that can be generalized to
the universe studied.
Recruitment of subjects for lab research projects typically involves convenience
sampling, which does not yield a sample that is representative of the general population.
Small-scale field studies by design will include purposive samples and therefore are not
necessarily externally valid beyond the population from which those samples are drawn.
This generic clearance will not be used in cases where it is especially important to be
representative of a specific population (e.g.: all Americans or another population of
interest). These studies will be used primarily for developmental and informative purposes,
and will not be used as the main source for making regulatory decisions or a basis for
specific policy at the Bureau.
4. Describe any tests of procedures or methods to be undertaken.
The Bureau plans to use pretesting and cognitive interviewing to test research
instruments on a small scale prior to their use in full-scale research studies. Respondents will
be debriefed after the pilot to ensure that they understood the instrument, which in turn
ensures that the resulting data collections are effective. These techniques are meant to reduce
the total public burden of the information collection by ensuring that the full study
information collection is optimized.

5.

Provide the name and telephone number of individuals consulted

on statistical aspects of the design and the name of the agency unit, contractor(s),
grantee(s), or other person(s) who will actually collect and/or analyze the
information for the agency.
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The name and telephone numbers of these individuals will be provided in the
clearance request for each specific data collection.
The Office of Research is currently staffed with over twenty employees with PhDs in
social science, who are trained in relevant methods. For any research studies that employ
statistical methods submitted for approval under this generic information collection plan, such
methods will be reviewed by a qualified statistician for scientific rigor; including compliance
with the Office of Management and Budget’s (OMB) statistical programs and standards prior
to submission to OMB.

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