FR3073_20170918_omb

Supporting Statement for the
Consumer and Stakeholder Surveys
(FR 3073; OMB No. 7100-0359)
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 Consumer and Stakeholder Surveys (FR 3073;
OMB No. 7100-0359). The Board uses this collection to inform consumer-focused research,
implement statutory requirements, and facilitate community development. The surveys in this
collection inform the Board’s work by identifying emerging risks and providing additional data
on the issues that affect the well-being of consumers and communities and how the financial
services marketplace functions.1
The surveys in this collection gather quantitative and qualitative information directly
from individual consumers or households (consumer surveys) on consumer finance topics. This
collection also gathers quantitative and qualitative information on current and emerging
community economic issues from stakeholders (stakeholder surveys). Examples of stakeholders
include, for example, such organizations as community groups, community development
organizations, nonprofit service providers, faith-based service organizations, public sector
agencies, small business owners, health care organizations, food banks, K–12 public and private
schools, community colleges, community development financial institutions, credit unions,
banks, and other financial institutions and companies offering financial products and services.
While these surveys are ongoing, the frequency and content of the questions may change
depending on economic conditions, regulatory or legislative developments, as well as changes in
technology, business practices, and other factors affecting consumers, stakeholders, and
communities.
The Board proposes to conduct the FR 3073 as needed, up to 30 times per year. The
annual burden is estimated to be 12,000 hours, based on the maximum of 30 surveys: 6
quantitative and 8 qualitative consumer surveys, and 8 quantitative and 8 qualitative stakeholder
surveys.

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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.

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
transparent consumer financial services market, including for traditionally underserved
households and neighborhoods. Data from previous consumer and stakeholder survey efforts
have provided timely information on developments in consumer financial markets, consumer
behaviors, and conditions and emerging risks in communities. Before initiating a new survey, the
Board would determine if the information to be collected is available by other means or sources
within the Federal Reserve System to avoid imposing additional burden on stakeholders.
Consumer Surveys
The Board analyzes emerging issues in consumer financial services policies and practices
to understand their implications for the economic and supervisory policies that are core to the
Board’s functions, as well as to gain insight into consumer decision-making. Consumer surveys
are an important tool for informing understanding of consumer financial decisions and markets,
and the Board has a long history of using surveys to inform its work.2 To augment and
complement existing survey efforts, the Board conducts surveys, such as by utilizing telephone
or internet panels, to explore emerging and current issues with implications for the Board’s
work.3 Telephone surveys are well-known methods of undertaking surveys, while internet panels
are surveyed via the internet using a computer, tablet, mobile phone or other Internet enabled
device. Internet panels provide another avenue for obtaining data on consumer financial topics
that can be more timely and cost-effective than telephone, mail, or in person surveys for some
data collections, in part because baseline information on panel participants (such as age or
homeownership) can aid in identifying potential respondents for a particular study.
The Board believes that quantitative surveys like internet panel surveys may be
complemented by other methods of data collection, such as qualitative surveys using focus
groups and individual interviews (which can provide more in depth information from a smaller
group of consumers, e.g., 10 to 12 consumers in a focus group, or 8 to 10 consumers in
individual interviews).4 This type of collection allows for qualitative research methods to be used
for exploring consumer responses to documents and disclosures, and also for other purposes,
such as for exploring a new topic or an ongoing area of focus in more depth, testing and
2

The consumer surveys conducted under the FR 3073 augment information available from other regularly occurring
surveys, such as the Survey of Consumer Finances (FR 3059; OMB No. 7100-0287), by asking new questions to
expand understanding of a topic, and potentially by providing information between waves of these other surveys.
3
For example, survey findings on mobile banking and payments have been released in reports and publically
available data. See Consumers and Mobile Financial Services 2016, (Washington: Board of Governors, March),
www.federalreserve.gov/econresdata/consumers-and-mobile-financial-services-report-201603.pdf and
www.federalreserve.gov/communitydev/shed_data.htm. Survey findings on the economic well-being of U.S.
households have also been recently released in reports and publically available data. See Report on the Economic
Well-Being of U.S. Households in 2015, (Washington: Board of Governors, May),
www.federalreserve.gov/communitydev/shed_publications.htm and
www.federalreserve.gov/communitydev/shed_data.htm.
4
In the past, the Board has made extensive use of focus groups and interviews for the purpose of developing
consumer disclosures. A number of the studies conducted to inform regulatory development work are available at
www.federalreserve.gov/econresdata/consumerresearch_testing.htm.

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developing the wording of survey questions, and complementing a quantitative survey in a mixed
method research design.
Stakeholder Surveys
In support of the Federal Reserve System’s community development function, the Board
has convened stakeholders, conducted and shared research, and identified emerging issues. In an
effort to increase knowledge related to economic growth and inclusion at the community level,
the Board has surveyed community stakeholders serving low-income consumers and
communities across the country. Community stakeholders often play a central role in sustaining
community economic development in low-to-moderate income locales.
To monitor local economic conditions, the Board has explored ways to tap stakeholder
networks for data. For example, historically the Board has partnered with community-based
nonprofits to collect responses from their affiliates and grantees on a voluntary basis. These
surveys were short (less than nine community economic recovery questions) and included
current and emerging community economic issues ranging from job availability, access to
affordable rental housing, access to credit, and nonprofit organizational capacity to meet
community demands for services.
As with the consumer surveys described above, the Board believes quantitative
stakeholder surveys may be complemented with smaller qualitative surveys, such as focus
groups or interviews with stakeholders. These methods may be useful for exploring a new topic
or an ongoing area of focus in more depth, testing and developing the wording of survey
questions, and complementing a quantitative survey in a mixed method research design. Topics
covered in stakeholder surveys may change over time as market conditions evolve and as
information is needed to address issues of immediate concern arising from Board and
interagency initiatives, economic developments, and requests from Congress. The Board
continues to explore ways to systematically gather micro-data from community stakeholders and
enhance the Board’s ability to use this information to understand regional and macro conditions
and trends.
Description of Information Collection
Consumer Surveys
The consumer surveys gather quantitative and qualitative information directly from
individual consumers or households. Topics explored in quantitative and qualitative consumer
surveys are likely to vary over time, although some topics may be repeated. Surveys relate to
various aspects of consumer financial knowledge, attitudes, and behavior, and inform
understanding of changes in the markets for consumer financial services, including changes
stemming from regulatory or legislative developments as well as from changes in technology and
business practices. Some surveys are needed to address issues of immediate concern, and such
issues may not be anticipated in advance. Examples of topics for consumer surveys include
 use of financial products and services
 use of technology and various service delivery channels

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
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ability to notice, comprehend, and use disclosures
ability to comprehend terms of credit or account agreements
sources and incidence of financial stress, and resources for coping with adverse shocks
behaviors related to searching, shopping, and negotiating for credit or asset purchases
financial planning, borrowing, investment, and insurance decisions
housing and living arrangements
financial knowledge, attitudes, and advice-seeking behaviors
human capital investment decisions and labor market outcomes

For the quantitative consumer surveys, the Board typically contracts with an outside
vendor to collect the data. For surveys administered via an outside vendor, the Board would
design the survey and draft the survey questions in consultation with the vendor. The questions
asked on any given survey are specific to the particular topic of interest. Some questions may be
repeated in subsequent surveys, but others may be asked on a single survey. The firm would be
responsible for testing the survey procedures, following the sampling protocol and conducting
the survey as specified by the Board, preparing data files containing the responses, computing
analysis weights, and documenting all survey procedures. Data editing and analysis of the results
may be conducted either solely by the Board and any research partner or jointly with the firm,
depending on the needs of the project.
The number of respondents to any given survey would vary depending on the purpose of
the survey and the sample size needed to obtain statistically valid results. The Board anticipates
fielding up to two large surveys each year and four medium (in sample size and survey time
length) surveys focused on particular topics for which data needs have arisen.
Qualitative surveys with consumers such as focus groups and interviews, may be
conducted on a variety of topics, either as a standalone study or as a complement to a
quantitative study as a part of a larger project. Formal or informal qualitative surveys may be
conducted by the Board and any outside partners, such as Federal Reserve Banks, collaborating
with the Board. They also may be conducted through a private vendor, which would be chosen in
a competitive bidding process or other acceptable negotiated process.5 The research instruments
may be developed by the Board and any research partner or jointly with the vendor working on
behalf of the Board. As necessary, the vendor may be responsible for testing the study
procedures, following the sampling protocol established by the Board, conducting the study as
specified by the Board, collecting and coding responses, and documenting all procedures. Data
editing and analysis of the results may be conducted by both the Board and any research partner,
by the vendor, or some combination of these depending on the project.
The number of respondents to any given qualitative survey also varies depending on the
purpose of the survey and the number of respondents needed to provide a range of viewpoints.
The FR 3073 enables the Board to conduct up to eight qualitative surveys each year with about
50 respondents per survey. For example, a qualitative survey could include several focus groups
on a particular topic for which data needs have arisen.
5

Contractors used by the Board in the past to conduct qualitative research include ICF International and Rockbridge
Associates, Inc.

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For both quantitative and qualitative consumer 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 a
particular Bank is a topic area expert, has contacts in the region they cover that should be
included in the data collection efforts, and/or has a complementary skillset needed to analyze and
report the data.
Stakeholder Surveys
The stakeholder surveys are used to gather quantitative and qualitative information
directly from stakeholders (stakeholder surveys). All aspects of quantitative stakeholder surveys
are handled in the same manner as consumer quantitative surveys since the only difference
between the two is the respondents targeted. As with the consumer surveys described above,
formal or informal qualitative surveys with stakeholders are conducted by the Board and any
outside partners, such as Federal Reserve Banks, collaborating with the Board. Such surveys may
also be conducted through a private vendor. Examples of topics for qualitative surveys include
 job availability
 access to affordable rental housing
 access to credit
 non-profit organizational capacity to meet community demands for services
 new issues of concern for stakeholders or communities
Such qualitative surveys could also be used for testing and developing the wording of
survey questions and complementing a quantitative survey in a mixed method research design.
The number of respondents to any given qualitative stakeholder survey varies depending on the
purpose of the survey and the number of respondents needed to provide a range of viewpoints.
The FR 3073 enables the Board to conduct up to eight qualitative surveys each year with about
50 respondents per survey. For example, a qualitative survey could include several focus groups
with different types of stakeholders or stakeholders from different areas of the country.
As with the consumer surveys described above, for both quantitative and qualitative
stakeholder 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 a particular Bank is a topic area expert, has
contacts in the region they cover that should be included in the data collection efforts, and/or has
a complementary skillset needed to analyze and report the data. For stakeholder surveys, Federal
Reserve Bank partnerships are especially important to monitor local economic conditions.
Time Schedule for Information Collection and Publication
The time schedules for the distribution of, response to, and collection of data for each
study is determined during the planning phase prior to the distribution of the study instrument.
Before data collection begins, the voluntary respondents to the data collection would be given an
explanation of the survey’s purpose and how the collected data would be used and whether their
responses could be kept confidential. Such information may be provided on the survey
instrument or through communication from the Board or a vendor or partner working with the

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Board. The Board chooses whether to publish the data that it obtains from respondents.
Information from consumer and stakeholder surveys may be cited in published material, such as
staff reports or working papers, professional journals, the Federal Reserve Bulletin, testimony
and reports to the Congress, or other vehicles.
Legal Status
The Board’s Legal Division has determined that the FR 3073 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.
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 3073 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 3073 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 3073 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)6
 Fair Credit Reporting Act (15 U.S.C. 1681s(e))7
 Equal Credit Opportunity Act (15 U.S.C. 1691b)8
 Electronic Funds Transfer Act (15 U.S.C. 1693b and 1693o-2)9
 Gramm-Leach-Bliley Act (15 U.S.C. 6801(b))10 and
 Flood Disaster Protection Act of 1973, section 102 (42 U.S.C. 4012a)
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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)).
7
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)).
8
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)).
9
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).
10
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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Additionally, depending upon the survey respondent, the information collection may be
authorized under a more specific statute. Specifically, the Board is authorized to collect
information from state member banks under section 9 of the Federal Reserve Act (12 U.S.C.
324); from bank holding companies (and their subsidiaries) under section 5(c) of the Bank
Holding Company Act (12 U.S.C. 1844(c)); from Edge and agreement corporations under
section 25 and 25A of the Federal Reserve Act (12 U.S.C. 602 and 625); and from U.S. branches
and agencies of foreign banks under section 7(c)(2) of the International Banking Act of 1978 (12
U.S.C. 3105(c)(2)) and under section 7(a) of the Federal Deposit Insurance Act (12 U.S.C.
1817(a)). Participation in the FR 3073 is voluntary.
The ability of the Federal Reserve to maintain the confidentiality of information provided
by respondents to the FR 3073 surveys will have to be determined on a case by case basis
depending on the type of information provided for a particular survey. Some of the information
collected on the surveys may be protected from Freedom of Information Act (FOIA) disclosure
by FOIA exemptions 4 and 6. Exemption 4 protects from disclosure trade secrets and
commercial or financial information, while Exemption 6 protects information “the disclosure of
which would constitute a clearly unwarranted invasion of personal privacy” (5 U.S.C 552(b)(4)
and (6)).
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 3073. 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.
In developing past surveys, the Board has periodically consulted informally with outside
experts, including staff of other agencies and Federal Reserve Banks, to obtain their input on
topics or questions to explore. While the Board has been responsible for directing surveys
conducted to date, in the future, surveys may be conducted jointly with staff from other agencies
or other outside partners.
Estimate of Respondent Burden
The burden for the FR 3073 survey is estimated to be up to 12,000 hours annually as
shown in the following table. It is anticipated that the information collection would involve as
many as 30 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.

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Estimated
Annual
average hours
frequency
per response

Number of
respondents

FR 3073

Estimated
annual burden
hours

Consumer surveys
Quantitative surveys (medium)
Quantitative surveys (large)
Qualitative surveys

3,000
6,000
50

4
2
8

0.25
0.40
1.5

3,000
4,800
600

Stakeholder surveys
Quantitative surveys11
Qualitative surveys12

1,500
50

8
8

0.25
1.5

3,000
600

Total

12,000

The estimated cost to consumers for participating in these surveys is $218,400, while the
estimated cost to stakeholders is $197,640. Accordingly, the total cost to respondents is
estimated to be $416,040.13
Sensitive Questions
Household respondents might be asked to identify the age and gender of individual
family members; information on race, if needed, would be collected under guidelines issued by
the OMB. Such information might be needed in a survey to analyze the demographic aspects of
consumer finances or businesses (particularly small businesses).
Estimate of Cost to the Federal Reserve System
The Board would incur costs for consulting services when outside expertise is needed on
a project, for contractual services for a firm to implement the data collection portion of the study,
and for any payment or gift made to respondents for the sole purpose of increasing response
rates. If the surveys were conducted at the maximum frequency, the annual cost to the Board of
such expenses for this information collection is estimated to total up to approximately $1.05
11

Of these respondents, 500 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.
12
Of these respondents, 45 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.
13
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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million, based on estimates from other surveys.14

14

Cost estimate is based on recent contracting costs associated with internet panel surveys and stakeholder surveys,
in addition to previous qualitative consumer testing contracts for disclosure development.

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