FR1378_20170918_omb

Supporting Statement for the
Surveys of Consumer and Community Affairs Publications and Resources
(FR 1378; OMB No. 7100-0358)
Summary
The Board of Governors of the Federal Reserve System (Board), under delegated
authority from the Office of Management and Budget (OMB), proposes to extend for three years,
without revision, the voluntary generic clearance Surveys of Consumer and Community Affairs
Publications and Resources (FR 1378; OMB No. 7100-0358). The Board uses this collection to
seek input from users or potential users of the Board’s publications, resources, and conference
materials to understand their interests and needs; to inform decisions concerning content, design,
and dissemination strategies; to gauge public awareness of the Board’s publications, resources,
and conferences; and to assess the effectiveness of the Board’s communications with various
respondents.1
The surveys in this collection are used to gather qualitative and quantitative information
directly from users or potential users of Board publications, resources, and conference materials,
such as consumers (consumer surveys) and stakeholders (stakeholder surveys). Stakeholders may
include, but are not limited to, nonprofits, community development organizations, consumer
groups, conference attendees, financial institutions and other financial companies offering
consumer financial products and services, other for profit companies, state or local agencies, and
researchers from academic, government, policy and other institutions. Publications and resources
may include reports and brochures, as well as audio and visual content, whether delivered in
print, online, or through other means.
The frequency of the survey and content of the questions will vary as needs arise for
feedback on different resources and from different audiences. The Board estimates that while the
FR 1378 may be conducted up to 16 times per year, history suggests a lower frequency is more
likely. The annual burden is estimated to be 2,300 hours, based on 16 surveys: 2 quantitative and
4 qualitative consumer surveys, and 6 quantitative and 4 qualitative stakeholder surveys.
Background and Justification
The Board conducts consumer-focused research as well as implements statutory
requirements and facilitates community development. These activities promote a fair and
Certain criteria apply to information collections conducted via the Board’s generic clearance process. Such
information collections shall (1) be vetted by the Board’s clearance officer as well as the Division director
responsible for the information collection, (2) display the OMB control number and respondents shall be informed
that the information collection has been approved, (3) be used only in such cases where response is voluntary, (4)
not be used to substantially inform regulatory actions or policy decisions, (5) be conducted only and exactly as
described in the OMB submission, (6) involve only noncontroversial subject matter that will not raise concerns for
other Federal agencies, (7) include information collection instruments that are each conducted only one time, (8)
include a detailed justification of the effective and efficient statistical survey methodology (if applicable), and (9)
collect personally identifiable information (PII) only to the extent necessary (if collecting PII, the form must display
current privacy act notice). In addition, for each information collection instrument, respondent burden will be
tracked and submitted to OMB.
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transparent consumer financial services market, including for traditionally underserved
households and neighborhoods.
As a part of the Board’s work, the Board shares information on emerging community
development, consumer finance, and consumer compliance issues and trends. The Board also
provides information on community development and stabilization practices from across the
nation and on tools available to practitioners and policymakers to aid local efforts. The Board
reports on findings from (1) outreach, conferences, monitoring efforts, and qualitative and
quantitative data collections; (2) the review of research conducted by outside individuals and
organizations; and (3) applied research using a variety of data sources and methods. The Board
relays this information through the Board’s public website, conferences, printed publications,
and other media—such as podcasts, video, and data visualizations.
The Board uses this collection to seek input from users or potential users of the Board’s
publications, resources, and conference materials to (1) understand their interests and needs; (2)
inform decisions concerning content, design, and dissemination strategies; (3) gauge public
awareness of its publications and resources; and (4) assess the effectiveness of its
communications with various respondents.
Description of Information Collection
The surveys in this collection are used to gather qualitative and quantitative information
directly from users or potential users of Board publications, resources, and conference material,
such as consumers (consumer surveys) and stakeholders. Participation is voluntary.
Publications and resources may include reports, brochures, as well as audio and visual
content, whether delivered in print, online, or through other means. Information gathered may
also include: general input on users’ interests and needs; feedback on website navigation and
layout, distribution channels, or other factors that may affect the ability of users to locate and
access content online; and/or the timing and means of delivery of publications.
Conferences may include events where attendees gather to learn or discuss topics related
to the work of the Board, such as community development, consumer finance, and consumer
compliance issues and trends. Conference material may include the information that is generated
by and distributed to attendees and users during or after the event. Information gathered may also
include: general input on attendees’ and users’ interests and needs; reactions to the topics and
narrative presented; and feedback on event or materials produced from the event such as
conference proceedings, websites, and other online or printed material.
Qualitative surveys may be conducted using data gathering methods such as focus groups
and individual interviews. Quantitative surveys may be conducted online or via mobile device,
by phone, by mail, by other electronic device, or a combination of these methods.
As the Board’s publications and resources continue to evolve, the Board may seek input
from users or potential users of our publications on questions such as
• Was the content relevant and of value?

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•
•
•

•

Was the length and nature of the discussion appropriate and useful for this topic?
How did the reader access the publication or other content—in hard copy distributed at an
event, online, or using a mobile device? If online or through a mobile device, was the
document printed for reading, or read on a tablet other e-reader, or a computer screen?
Could the Board improve the format and appearance of the print or electronic
presentation? Improvements to the format and appearance could include the readability of
type size or of charts and graphs; organization of information; and ease of locating
information through indexing, search tools, and links.
Was the reader able to use the information to inform their work?

For both quantitative and qualitative surveys, the Board may find it beneficial to partner
with a Federal Reserve Bank to develop the instrument, plan the data collection methods, and/or
report the findings. The Board will partner with a Federal Reserve Bank when, for example,
information is specific to regions in which a Federal Reserve Bank may have expertise that
would complement the research of the Board, when conferences are jointly hosted by the Board
and a Federal Reserve Bank, and when resources targeted at consumers (consumer surveys)
and/or stakeholders (stakeholder surveys) are region specific.
Additionally, the Board may choose to contract with an outside vendor to conduct focus
groups, interviews, or surveys, or may choose to collect the data directly. The Board may also
work with outside parties when appropriate to identify potential respondents (e.g., networks of
community groups or researchers) and to collect data.
Time Schedule for Information Collection and Publication
The time schedules for the collection and analysis of data and the distribution of results
for each survey is determined during the planning phase prior to the start of the data collection.
Before a data collection begins, the respondents to that collection would be given an explanation
of the survey’s purpose and how the collected data would be used. Such information may be
provided on the survey instrument or through communication from the Board or a vendor or
partner working with the Board. The Board does not anticipate releasing or publishing the data,
but may share it with Federal Reserve Banks, vendors, or other outside parties that the Board
may collaborate with in producing or disseminating publications, or in evaluating the Board’s
communication efforts.
Legal Status
The Board’s Legal Division has determined that the FR 1378 is generally authorized
under sections 2A and 12A of the Federal Reserve Act. Section 2A requires that the Board and
the Federal Open Market Committee (FOMC) maintain long run growth of the monetary and
credit aggregates commensurate with the economy’s long run potential to increase production, so
as to promote effectively the goals of maximum employment, stable prices, and moderate longterm interest rates (12 U.S.C. 225a). In addition, under section 12A of the Federal Reserve Act,
the FOMC is required to implement regulations relating to the open market operations conducted
by Federal Reserve Banks with a view to accommodating commerce and business and with
regard to the regulations’ bearing upon the general credit situation of the country (12 U.S.C.

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263). The authority of the Federal Reserve to collect information to carry out the requirements of
these provisions is implicit. Accordingly, the Federal Reserve is authorized to collect the
information called for by the FR 1378 by sections 2A and 12A of the Federal Reserve Act.
In addition, the Board is responsible for implementing and drafting regulations and
interpretations for various consumer protection laws. The information obtained from the
FR 1378 may be used in support of the Board’s development and implementation of regulatory
provisions for these laws. Therefore, depending on the survey questions asked, the FR 1378 may
be authorized pursuant to the Board’s authority under one or more of the following consumer
protection statutes:
 Community Reinvestment Act (12 U.S.C. 2905)
 Competitive Equality Banking Act (12 U.S.C. 3806)
 Expedited Funds Availability Act (12 U.S.C. 4008)
 Truth in Lending Act (15 U.S.C. 1604)2
 Fair Credit Reporting Act (15 U.S.C. 1681s(e))3
 Equal Credit Opportunity Act (15 U.S.C. 1691b)4
 Electronic Funds Transfer Act (15 U.S.C. 1693b & 1693o-2)5
 Gramm-Leach-Bliley Act (15 U.S.C. 6801(b))6 and
 Flood Disaster Protection Act of 1973, section 102 (42 U.S.C. 4012a)
The surveys are voluntary. The Board does not consider the information collected on
these surveys to be confidential. Thus, no issue of confidentiality arises.
Consultation Outside the Agency
On February 13, 2017, the Board published an initial notice in the Federal Register (82
FR 10480) requesting public comment for 60 days to extend, without revision, the FR 1378. The
comment period for this notice expired on April 14, 2017. The Board did not receive any
comments. On May 15, 2017, the Board published a final notice in the Federal Register
(82 FR 22332) and the information collection will be extended as proposed.
The Board may collaborate with Federal Reserve Banks, other federal agencies, vendors,
and other outside groups in producing or disseminating publications, and in evaluating the
Board’s communication efforts.

Although the Dodd-Frank Act (DFA) cut back the Board’s authority under the Truth in Lending Act, the Board
retains rule writing authority for implementing regulations with respect to auto dealers (DFA 1100A(7)).
3
Although the DFA cut back the Board’s authority under the Fair Credit Reporting Act, the Board retains rule
writing authority for red flags, address changes, and disposal of records (DFA 1002(12)(F) and 1088(a)(2)(D)).
4
Although the DFA cut back the Board’s authority under the Equal Credit Opportunity Act, the Board retains rule
writing authority for implementing regulations with respect to auto dealers (DFA 1085(3)).
5
Although the DFA cut back the Board’s authority under the Electronic Fund Transfers Act, the Board retains rule
writing authority for interchange fee regulations and authority to implement regulations with respect to auto dealers
(DFA 1075 and 1084).
6
Although the DFA cut back the Board’s authority under the Gramm-Leach-Bliley Act, the Board maintains the
authority to establish appropriate standards for the financial institutions relating to administrative, technical and
physical safeguards for certain customer records and information (DFA 1002(12)).
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Estimate of Respondent Burden
The burden for the FR 1378 collection is estimated to be up to 2,300 hours annually as
shown in the following table. The information collection could involve as many as 16 surveys,
although the surveys may not be conducted that frequently. The burden estimates shown in the
table below are based on the average number of responses anticipated. These reporting
requirements represent less than 1 percent of total Federal Reserve System paperwork burden.
Estimated
Annual
average hours
frequency
per response

Number of
respondents

FR 1378
Consumer surveys
Quantitative surveys
Qualitative surveys
Stakeholder surveys
Quantitative surveys7
Qualitative surveys8

Estimated
annual burden
hours

1,000
50

2
4

0.25
1.5

500
300

800
50

6
4

0.25
1.5

1,200
300

Total

2,300

The estimated cost to consumers for participating in these surveys is $20,800, while the
estimated cost to stakeholders is $82,350. Accordingly, the total cost to respondents is estimated
to be $103,150.9
Sensitive Questions
Respondents may be asked to provide information on their age and gender; information
on race, if needed, would be collected under guidelines issued by the OMB. Such information
might be needed in a survey to assess the extent to which a sample of respondents reflected
views from different demographic groups in the population.

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Of these respondents, 250 are considered small entities as defined by the Small Business Administration (i.e.,
entities with less than $550 million in total assets) www.sba.gov/contracting/getting-started-contractor/make-sureyou-meet-sba-size-standards/table-small-business-size-standards.
8
Of these respondents, 40 are considered small entities as defined by the Small Business Administration (i.e.,
entities with less than $550 million in total assets) www.sba.gov/contracting/getting-started-contractor/make-sureyou-meet-sba-size-standards/table-small-business-size-standards.
9
The average consumer cost (for consumer surveys) of $26 is estimated using data from the BLS Economic News
Release (USDL-14-0433) www.bls.gov/news.release/cewqtr.nr0.htm.
Total cost to the public was estimated using the following formula: percent of staff time, multiplied by annual
burden hours, multiplied by hourly rates (30% Office & Administrative Support at $18, 45% Financial Managers at
$67, 15% Lawyers at $67, and 10% Chief Executives at $93). Hourly rates for each occupational group are the
(rounded) mean hourly wages from the Bureau of Labor and Statistics (BLS), Occupational Employment and Wages
May 2016, published March 31, 2017, www.bls.gov/news.release/ocwage.nr0.htm. Occupations are defined using
the BLS Occupational Classification System, www.bls.gov/soc/.

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Estimate of Cost to the Federal Reserve System
The Board may incur costs for contractual services for a firm to implement the data
collection portion of the survey, and for any payment or gift made to respondents for the sole
purpose of increasing response rates. The annual cost to the Federal Reserve System of such
expenses for this information collection is estimated to total up to approximately $300,000,
based on estimates from other surveys.10

10

Cost estimate is based on recent contracting costs for internet panel surveys of consumers, in addition to previous
qualitative consumer testing contracts for disclosure development. Some studies may not involve the use of outside
vendors, and would not incur these contracting costs.

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