3170-0051 SS-A Coaches_2018_renewal_OMB_FINAL (Revised)

30-day Federal Register Notice and OMB Review

CONSUMER FINANCIAL PROTECTION BUREAU
REQUEST FOR APPROVAL UNDER FOR –
FINANCIAL COACHING PROGRAM FOR VETERANS AND LOWINCOME CONSUMERS
(OMB CONTROL NUMBER: 3170-0051)

TERMS OF CLEARANCE: Not applicable. The Office of Management and
Budget provided no Terms of Clearance when it last approved this collection of
information in February 2015.
ABSTRACT: In early 2015, the Consumer Financial Protection Bureau (the “Bureau”)
launched a Financial Coaching project to provide direct financial coaching services to
transitioning veterans and economically vulnerable consumers nationwide. In order for the
Bureau to understand whether the program is effective and for the financial coaches to be able to
deliver efficient services and track clients over time, the Bureau needs to take steps to monitor
program performance. This includes collecting administrative data about clients for
programmatic purposes. The information is collected from the coaches and includes a
combination of personal information (basic contact and demographic information), performance
metrics (outputs), client-level outcomes (progress towards financial goals or other relevant
outcomes) and programmatic and organizational outcomes.
The initial information collection request for the administrative data collected by coaches from
financial coaching clients for programmatic and performance monitoring purposes was approved
in 2015 and expires on February 28, 2018. In 2015, the Financial Coaching program was
extended beyond the initial program period and subsequently, this request is for an extension of
administrative data collection. In addition, this information request includes a modification, to
add five questions to the administrative data collection. The five questions are part of the
Financial Well-being Survey, which received approval under OMB Control Number 3170-0063
in order to measure the level of financial well-being of American adults and key subpopulations. This will help us understand the progress clients are making and is also in line with
the Bureau’s overall efforts to be more consistent in the information we are collecting. This
information collection is limited to the collection of administrative data for the purpose of
program management.

JUSTIFICATION
1. Circumstances Necessitating the Data Collection
The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank
Act”), Pub. L. 111-203, established the Bureau to regulate the offering and provision of
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consumer products or services under federal consumer financial laws. Consistent with the
purposes of the Dodd-Frank Act, the Bureau’s mission includes establishing and enforcing
clear, consistent rules for the financial marketplace; protecting American families from unfair
financial practices; and developing and implementing a strategy to improve the financial literacy
of consumers. For additional background on the Bureau, please see
http://www.consumerfinance.gov/the-bureau/.
Additionally, the goals of this project are in line with the individual office mandates of both the
Office of Servicemember Affairs and the Office of Financial Empowerment. The Dodd-Frank
Act assigns the Bureau’s Office of Servicemember Affairs the responsibility to educate and
empower servicemembers and their families to make better informed decisions regarding
consumer financial products and services. Similarly, the Bureau’s Office of Financial
Empowerment seeks to meet the Bureau’s statutory mandate to “provid[e] information,
guidance, and technical assistance regarding the offering and provision of consumer financial
products and services to traditionally underserved consumers and communities.” 1
Because of the scope and size of the program, it is crucial that the Bureau collect data on those
who receive financial coaching services, as part of the Bureau’s program, in order to understand
if the services are working well and how they might be improved upon.
The extended and modified data collection is necessary to help the Bureau and its stakeholders
continue to understand client and program performance, and also to gain insights into how the
program can be improved. The additional financial well-being questions allow the financial
coaching program to use a tested methodology, used across the Bureau, for understanding
consumer financial behavior and progress.
The justification for each survey question is provided in the attached spreadsheet.

2. Use of the Information
The information to be collected will include a combination of client personal information (i.e.,
basic contact and demographic information), performance metrics (outputs), client-level
outcomes related to financial goals, as well as other relevant organization-level outcomes.
The coaches often work with the clients over multiple sessions and their information will be
collected and housed in the client management system that has been in use since the data
collection began. In addition to personal information intended for client management and followup, the coaches are also required to document high-level information about the client’s financial
goals and progress made towards those goals. The coaches will also continue to use the client
data management system to capture the reasons why clients are working with the coach in the
first place (for example, to reduce debt), and progress made towards those goals. Capturing the
1

12 U.S.C. § 5493.

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outcomes from coaching sessions helps the Bureau determine if the sessions, the coach, and
program overall are effective in helping clients achieve their financial goals. The Bureau can
identify and learn from information that is gleaned from the success of clients and coaches. For
example, if one site or coach is particularly effective in working with clients, the other coaches
could learn from this site or person’s processes or techniques.
Common client outcome measures such as income, savings, debt, and credit, will continue to be
collected, based on the stated goals identified by individual clients. Also, a set of standard
outcome measures will continue to be collected from clients across all coaching sites, as well as
outcomes that vary by site and by the types of populations being served. These site-specific
outcomes are based on the existing programs’ service delivery needs and existing systems
and/or processes for collecting and tracking outcomes. In addition, beyond client outcomes, the
Bureau will continue to collect additional information (e.g., from coaches, the delivery
organizations/agencies, etc.) to contribute to its knowledge and understanding of what has been
effective and how to improve the program moving forward. By understanding the macro-level
needs of the clients and coaches, the program can, for example, adjust and respond to training
needs that coaches may have in response to issues that the clients are presenting. The bulk of
the administrative information collected would be at the time of intake and captured in the
client management system. Each time the client meets with the coach, the coach will document
relevant information towards goal accomplishment.
The modification to the data collection will include the addition of five questions from the
Bureau’s Financial Well-being survey. These five questions will be asked in addition to the
existing questions the coaches are approved to ask at intake and in subsequent client check-in
meetings to track client progress.
Client-level raw data is not shared with the Bureau, nor is it shared outside of its contractors and
subcontractors that are charged with data collection and analysis. Directly-identifying
information (e.g., respondent names) is also not made available to the Bureau. The Bureau does,
however, receive and may choose to release de-identified results and aggregated analyses of
those results (such as trends in financial issues) in public reports it will issue. Those results
would be reported in a way that could not reasonably identify any respondent. Veteran-specific
data will not be released to the public.

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3. Use of Information Technology
Although the administrative data will be collected through conversations that coaches have with
their clients, they will be using an electronic client management system to document and report
standardized information about the clients as well as progress towards their goals. While some
interaction between coaches and clients occurs by phone or email, the majority of conversations
between coaches and clients occur in person.
The data is inputted by coaches using laptops that are cyber-security configured and encrypted.
The client-management system is also encrypted. During the first year of implementation, all
Financial Coaches received in-person privacy and records management training from Bureau
staff. Basic tenants of privacy and records management are also addressed during each new
coaches’ on-boarding session and through AFSC’s annual security training and code of conduct
and business ethics training. All financial coaches are required to complete the Bureau’s 2018
annual privacy and records management training by mid-March 2018.

4. Efforts to Identify Duplication
This information collection is an extension and modification of an existing information
collection for a specific Bureau program and is not available from any other source;
therefore, there are no concerns about duplication.

5. Efforts to Minimize Burdens on Small Entities
The Bureau does not anticipate any small businesses being impacted by this collection of
information. The burden is on clients requesting the financial coaching service.

6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction
If the collection is not conducted, the Bureau would not be able to know how the
program is performing, nor would it know how to improve the program moving
forward. The additional questions allow the Bureau to track the program’s progress on
recently developed metrics that are more consistently used across the Bureau and the
wider financial capability and education fields.

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).
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8. Consultation Outside the Agency
In accordance with 5 CFR 1320.8(d)(1), the Bureau has published a notice in the Federal Register
allowing the public 60 days to comment on this proposed new collection of information. Further
and in accordance with 5 CFR 1320.5(a)(1)(iv), the Bureau will publish 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.
The 60-day notice in the Federal Register received ten comments. The comments were reviewed,
and this information collection request was adjusted where appropriate. The comments are
addressed below as they pertain to the information that will be collected as part of the client intake
and case management processes
Comment 1: The comment is from an organization that represents credit unions. The commenter
requests that any data collection efforts from the Bureau do not require an unnecessary
administrative burden on credit unions that employ financial coaches.
The data collection identified in this request does not apply directly to credit unions or any other
outside organizations that employ a financial coach. This request is focused solely on financial
coaches that provide their services as part of the Bureau’s Financial Coaching Initiative, as
subcontractors of the Bureau. Organizations volunteer to host coaches that are part of the Bureau
program, and those coaches collect information as part of their routine work with clients. The
organizations that host coaches are not liable for the data collection identified in this request.
Comment 2: The comment refers to US oil imports abroad.
The Bureau does not have authority to regulate the energy industry. The comment does not apply to
this request.
Comment 3: The comment is from an organization that promotes financial literacy and support
financial coaching. The commenter expresses support for the program and its use of data-driven
strategies.
The Bureau agrees with the commenter that financial coaching is a promising practice that has a
proven positive impact on the finances of participating clients. Information collection allows
financial coaches to continue to track and support the progress of those who take part.
Comment 4: The comment refers to research studies related to drinking water.
The Bureau does not conduct environmental impact studies and does not have the authority over
environmental policy. The comment does not apply to this request.
Comment 5: The comment refers to policies related to the manufacturing sector, particularly
forestry and lumber production.
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The Bureau does not have authority to regulate the lumber or forestry industries. The comment
does not apply to this request.
Comment 6: The commenter expresses support for the Financial Coaching Initiative and asks three
questions related to the request. 1) The commenter requests clarity on why veteran-specific data
will not be released to the public. 2) The commenter asks for more information about the program’s
effectiveness in advertising the program 3) The commenter expresses concern that the
administrative burden indicates a considerable and costly process. The commenter asks if the
estimate includes data collection from the respondents during coaching sessions and if the process
can be automated.
1) The majority of veterans receive coaching services at Department of Labor American Job Corps
sites. The Bureau aligned data collection and disclosure with the host sites’ protocols.
2) The program has never funded advertising activities. The way in which the program receives
clients is by leveraging the trusted relationships and existing work of the host site organizations.
For example, staff at host organizations refer clients in need of financial coaching to the financial
coach. Additionally, the coaches conduct outreach in the communities if they have the capacity to
serve more clients than what the host site organization is providing. In 2015, based from feedback
from the coaches, the Bureau developed (in-house) “marketing material” that the coaches can use
when they conduct their outreach, the flyer is included in this package. The coaches felt this was
necessary for legitimacy and for consistency. In terms of effectiveness, we learn that the host site
referrals and clients own referrals are the most effective ways to let potential clients know about the
program. That said, the coaches appreciate having something that provides them the legitimacy
they have felt they’ve needed, and prevents them from having to invest the time and “reinvent the
wheel” to develop their own outreach materials across all 60 sites. 3) The request has been updated
to reflect the following points. Information collection takes place as part of a regular financial
coaching session. Many of the questions included in the Bureau information request are reflective
of questions that are typical of a coaching engagement. If information collection was automated, for
example, in a digital questionnaire filled out by clients, coaches may still ask these questions as part
of a coaching engagement, increasing the burden on the client. Also, the current process of coach
input of data into a cyber-secure client management system adds a necessary layer of data security.
The Bureau estimates that approximately 7,600 unique clients will take part in the coaching
program each year. The Bureau estimates that each response takes approximately 15 minutes. This
takes into account the fact that not all questions included in this request are applicable to all clients,
and to reduce the administrative burden, coaches have the authority to only ask relevant questions.
In order to reflect the average number of sessions per a client, this has been multiplied by two. This
results in a total of 3,600 hours in a calendar year. This administrative burden is spread across
approximately 60 financial coaches. On average, each coach is responsible for approximately 60
hours of information collection, or approximately 7.5 working days. The Bureau estimates that the
time and cost of information collection from this request is appropriate.
Comment 7: The comment refers to air quality studies and policies and requests a study of specific
agricultural equipment to ensure it meets industry standards and does not cause an undue cost
burden on the agricultural industry.
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The Bureau does not have authority to regulate environmental policy or the agricultural industry.
The comment does not apply to this request.
Comment 8: The commenter refers to regulation of the oil and gas industry.
The Bureau does not have authority to regulate the energy industry. The comment does not apply to
this request.
9. Payments or Gifts to Respondents
No payments or gifts will be provided to respondents for the collection of the administrative data
described in this request.

10. Assurances of Confidentiality
Coaches are trained to omit identifying details when discussing cases and soliciting input from
program leadership. Personally Identifiable Information (PII) that are direct identifiers (e.g.,
respondent names) will stay with the contractor. Coaches are trained to tell clients that neither the
Bureau nor the host site will obtain or access any information that directly identifies participants.
Coaches provide clients with a Privacy Act Statement in hard copy when recruiting individuals to
participate, and before the discussion starts. Further, any resulting reports on the program will
consist only of de-identified results and aggregated analyses of those results that will be reported
in a way that could not reasonably identify any respondent. Coaches are also required to maintain
confidentiality as a part of their Financial Coaching certification. 2

11. Justification for Sensitive Questions
Coaches will collect direct-identifying PII including name and basic contact information to
facilitate participation in the counseling program. Additionally, coaches will collect
demographic data and respondent data (goals, challenges, outcomes information provided by
participants as outlined below) as part of program management efforts. Social Security Numbers
(SSNs) will not be collected as a part of the administrative data collection process, and clients
will not be required to provide SSNs in order to participate in the program. Instead, an
alternative unique identification number will be developed to track coaching clients and service
delivery.
The Bureau has a System of Records Notice (SORN), CFPB.021 – Consumer Education and
Engagement Records (FR 77 FR 60382) in place to account for the collection, use, disclosure,
and destruction of PII as it relates to this project. This project is covered under the Consumer
2

Access the Association for Financial Counseling and Education here: https://www.afcpe.org/resource-center/professionalstandards/standards-of-practice.

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Education Privacy Impact Assessment (PIA)
(https://s3.amazonaws.com/files.consumerfinance.gov/f/201409_cfpb_consumereducation_pia.pdf); and the Market Analysis of Administrative Data Under Research Authorities
PIA (https://s3.amazonaws.com/files.consumerfinance.gov/f/201312_cfpb_pia_admin-dataresearch.pdf) that covers collection of administrative data.
The project will collect and analyze response data provided by participants when coaches ask
questions related to personal financial behavior, such as amount of savings, amount of debt,
spending behavior and other personal financial information if applicable to the client’s goals.
This information is necessary to track clients’ progress towards their identified goals. Such
response data may include sensitive information but will be stripped of direct identifying PII for
analysis purposes. Analysis includes (for example) assessing financial goals, outcomes and
financial behavior relating to participation in the financial coaching program. Because of the
individual nature of the program, the vendor, on the Bureau’s behalf, will need to collect the
sensitive information at the individual level for certain aspects of the program (such as intake for
the client management system). However, where data is being reported, aggregate data stripped
of direct identifiers will be reported wherever possible.

12. Estimated Burden of Information Collection
In Exhibits 1 and 2, we provide estimates of the collection burden on program participants. As of
July 2017, the program has served approximately 600 clients a month during the 2017 calendar
year. Assuming service continues at this rate, the estimated number of clients served annually
will be approximately 7,200. All clients will be walked through their rights under the Privacy
Act, and if the client is asked to complete a brief series of questions for the Client Information
System to provide information for further research.
Using the average federal minimum wage for coaching clients (economically vulnerable and
returning veteran) of $7.25, we then multiply this figure by the number of burden hours for each
of these activities, which generates estimates of the total annual cost burden.
Not all data collection items will be relevant to all clients, and the specific number of
questions that will be asked on any given client will vary based on their specific financial
goals and background. The time burdens in Exhibit 1 reflect an average estimate for each
client. For the modification of the survey, in the form of five (5) additional Financial Wellbeing Survey questions, we estimate about thirty (30) additional seconds per a respondent.
While many clients may come once, the average client meets with the coach approximately 2
times; therefore, the burden is estimated based on an average of two (2) responses per client.
See Exhibit 1 below.

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EXHIBIT 1. ESTIMATE OF ANNUALIZED TIME BURDEN TO RESPONDENTS
Collection of
Information

Number of
Respondents

Number of
Responses
Per

Total Annual
Responses

Respondent
Client
Information
for the
Client
Manageme
nt System
Total:

Average
Burden per

Total
Annual

Response

Burden

(in hours)

Hours

7,200

2x

14,400

.25

3,600

7,200

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

14,400

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

3,600

Average Total annual
hourly wage cost burden
rate 3

$7.25

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

/////

$25,100

$26,100

13. Estimated Total Annual Cost Burden to Respondents or Recordkeepers
There are no other costs associated with this information collection other than what is
discussed above in Item 12.

14. Estimated Cost to the Federal Government
We estimate that the Bureau will need to cover the costs (via the contract) of maintaining a
client management/outcome tracking system in order to be able to collect and report data, as
well as costs associated with the collection, analysis, and reporting of interview and survey
data. The estimated cost for this work is $125,000.

15. Program Changes or Adjustments
This submission to OMB is a request for renewal and modification – adding five
questions from the Financial Well-being Survey (approved through OMB 3170-0063)
to administrative questions for clients. However, since not all questions apply to all
clients, the Bureau does not believe the addition of these questions results in an overall
increase of the average response time.
The original submission included a number of respondents based on projected
estimates of the number of clients that would engage with the program, prior to its
launch. The current request includes a number of respondents that has been adjusted
using actual monthly averages for the year of 2017. This number of respondents is
2,800 less than the original submission. Additionally, the estimated average response
3

While the Bureau does not ask for clients’ income data across the program, the Bureau knows that many of the clients
served by the program are low wage. Therefore, for these estimations we use the federal minimum wage as our
estimate. The source the Department of Labor’s Wage and Hour Division: Wage and Hour Division (WHD):
https://www.dol.gov/whd/minimumwage.htm

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time has been reduced from 30 to 15 minutes. See Exhibit 2.
Exhibit 2: Summary of Burden Changes
Total Respondents
Total Annual Burden Requested
Current OMB Inventory
Difference (+/-)
Program Change
Discretionary
New Statute
Violation
Adjustment

7,200
10,000
(2,800)
0
0
0
0
(2,800)

Annual
Responses
14,400
10,000
4,400
0
0
0
0
4,000

Burden
Hours
3,600
5,000
(1,400)
0
0
0
0
(1,400)

Cost Burden
(O & M)
0
0
0
0
0
0
0
0

16. Plans for Tabulation, Statistical Analysis, and Publication
The Bureau, at this time, plans to publish for stakeholders and the public at least one report
that would provide basic information about the program’s implementation, the types of issues
clients are facing, what their outcomes have been, and general lessons learned to date. All
data would be published in the aggregate. The Bureau does not know, at this time, what the
publication(s) dates would be.

17. Display of Expiration Date
The expiration date will be displayed in OMB’s public docket at www.reginfo.gov. There are no
collection instruments on which to display expiration date. The coaches ask questions found in
the attached spreadsheet in-person and record the information in a data collection system. The
OMB number and expiration date will be displayed in the program brochure given to clients.
18. Exceptions to the Certification Requirement
The Bureau certifies this collection of information is consistent with the requirements of 5 CFR
1320.9, and the related provisions of 5 CFR 1320.8(b)(3) and is not seeking an exemption to
these certification requirements.

PART B: STATISTICAL METHODS
This collection of information does not use statistical methods

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