FR3063_20171213_omb

Supporting Statement for the
Government-Administered, General-Use Prepaid Card Surveys
(FR 3063; OMB No. 7100-0343)
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 Government-Administered, General-Use Prepaid Card Surveys (FR 3063;
OMB No. 7100-0343). This information collection is comprised of the following surveys:
1. The Issuer Survey (FR 3063a) collects data from issuers of government-administered,
general-use prepaid cards including card program information, cards outstanding, card
funding, ATM transactions, purchase transactions, fees paid by issuers to third parties,
interchange fees, and cardholder fees. The Issuer Survey (FR 3063a) is mandatory.
2. The Government Survey (FR 3063b) collects data from state governments, the District of
Columbia, and U.S. territories (collectively “state governments”), and municipal
government offices located within the United States (local government offices) that
administer general-use prepaid card payment programs.1 Data collected from
government offices include program information, the number of cards outstanding, and
funding information. The Government Survey (FR 3063b) is voluntary.
The Board uses data from these surveys to support an annual report to the Congress on
the prevalence of use of general-use prepaid cards in federal, state, and local governmentadministered payment programs and on the interchange and cardholder fees charged with respect
to such use of such cards. The total current annual burden for the surveys combined is estimated
to be 1,750 hours.
Background and Justification
Section 1075(a) of the Dodd-Frank Act requires that the Board provide annually a report
to the Congress regarding the prevalence of the use of general-use prepaid cards in federal, state,
and local government-administered payment programs, and the interchange and cardholder fees
charged with respect to the use of such prepaid cards.2 Section 1075(a) of the Dodd-Frank Act
also provides the Board with authority to require card issuers to respond to information requests
as may be necessary to carry out the provisions of the section.

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The issuer and government surveys request information on all federal, state, or local government-administered
payment programs that provide a general-use prepaid card (or other debit card) disbursement option to payment
recipients. The government survey may be distributed to federal government agencies in addition to state and local
governments, but collections of information from federal government agencies are not subject to the Paperwork
Reduction Act and, thus, are not included in this discussion. U.S. territories include American Samoa, Guam,
Midway Islands, Northern Mariana Islands, Puerto Rico, and U.S. Virgin Islands.
2
See 15 U.S.C. 1693o-2(a)(7)(D).

Description of Information Collection
The FR 3063 comprises two surveys: (1) the Issuer Survey (FR 3063a) and (2) the
Government Survey (FR 3063b). A general description of these surveys is provided below.
Issuer Survey (FR 3063a)
The issuer survey is mandatory for depository institutions that issue general-use prepaid
cards for federal, state, or local government-administered payment programs. The survey
requests information on cards associated with accounts domiciled in the United States, the
District of Columbia, and U.S. territories.
The current survey collects information on government-administered payment programs
for which the depository institution is the issuer of general-use prepaid cards. The survey
collects program information aggregated to the jurisdiction level (a separate questionnaire is
provided for federal programs and state/local programs).3 The cards issued pursuant to
government-administered payment programs may be either reloadable or non-reloadable.
The current issuer survey comprises eight sections:
I.

Program Information: Respondents report information on card programs
covered in their response including the number of programs, the name of the
programs, and the name of the sponsoring government agencies.
II.
Card Funding: Respondents report information on the number of cards
outstanding and the value of funds loaded into prepaid card accounts.
III.
Cash Withdrawals: Respondents report information on ATM and over-thecounter (OTC) at-bank cash withdrawals.
IV.
Purchase Transactions: Respondents report information on the volume and
value of settled purchase transactions.
V.
Fees Paid by Issuers: Respondents report the value of fees paid by issuers to
third parties for cash withdrawals.
VI.
Issuer Revenue: Interchange Fees: Respondents report information on
interchange fee revenue received on settled purchase transactions.
VII. Issuer Revenue: Cardholder Fees: Respondents report information on fees
assessed to cardholders, including purchase transaction fees, ATM fees, OTC
fees, account servicing fees, routine monthly fees, customer service inquiry fees,
overdraft fees, penalty fees, and all other cardholder fees.
VIII. Issue Revenue: Other: Respondents report information on revenue received
from sources not covered in other sections of the survey.

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A program’s jurisdiction is determined by the government agency that administers the program. For example, a
program is considered state/local if it is administered by a state government agency even if the program is federally
funded.

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Government Survey (FR 3063b)
The government survey is voluntary for state and local government offices that use
prepaid cards to disburse funds to payment recipients. The survey collects information about the
prevalence of use of general-use prepaid cards in federal, state, and local governmentadministered payment programs. The current government survey comprises three sections:
I.

II.
III.

Government-Administered, General-Use Prepaid Card Program
Information: Respondents report information on the government-administered
payment programs covered in the response, sponsoring government agencies, the
jurisdiction of the agencies, geographic areas in which prepaid cards have been
issued, card issuing banks, the type of payment programs, the number of
recipients receiving payments (by any payment method), and the number of
recipients receiving payments by prepaid cards.
Number of Cards: Respondents report information on the number of cards
outstanding at year-end.
Funds Disbursed to Payment Recipients: Respondents report information on
the value of funds loaded into prepaid card accounts and the value of all funds
paid by other payment methods.

Reporting Panel
The Board estimates that there are approximately 25 depository institutions subject to the
requirements of the FR 3063a. The Board also anticipates that the FR 3063b will be distributed
to approximately 75 state and local government offices in the United States that administer
general-use prepaid cards.4
Time Schedule for Information Collection and Publication
The Board is required to provide an annual report to the Congress on governmentadministered, general use prepaid cards. The Board would make the issuer and government
surveys available by mid-February 2018 and would request that the surveys be submitted to the
Board within 60 calendar days.
Legal Status
The Board’s Legal Division has determined that both the issuer survey and the
government survey are authorized by subsection 920(a) of the Electronic Fund Transfer Act,
which was amended by section 1075(a) of the Dodd-Frank Act (15 U.S.C. 1693o-2). This
subsection requires the Board to submit an annual report to Congress on the prevalence of the
use of general-use prepaid cards in Federal, State or local government-administered payment
programs and the interchange transaction fees and card-holder fees charged with respect to the
use of such general-use prepaid cards (15 U.S.C. 1693o-2(a)(7)(D)). It also provides the Board
with authority to require issuers to provide information to enable the Board to carry out the
4

FR 3063b Survey Glossary of Terms - United States: The states, territories, and possessions of the U.S., the
District of Columbia, the Commonwealth of Puerto Rico, or any political subdivision of any of the foregoing.

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provisions of the subsection (15 U.S.C. 1693o-2(a)(3)(B)). The obligation of issuers to respond
to the issuer survey (FR 3063a) is mandatory. However, the obligation of state governments and
local government offices to respond to the government survey (FR 3063b) is voluntary.
All of the information collected on the government survey and a limited amount of
information collected on the issuer survey is publicly available, and thus, is not accorded
confidential treatment. However, most of the information collected on the issuer survey is not
publicly available and may be kept confidential as explained herein. Data collected by the issuer
survey may be kept confidential under exemption (b)(4) of the Freedom of Information Act
(FOIA), which exempts from disclosure “trade secrets and commercial or financial information
obtained from a person and privileged or confidential” (5 U.S.C. 552(b)(4)). Such data may be
kept confidential under exemption 4 if the release of data would cause substantial harm to the
competitive position of the issuer. For example, certain issuer survey responses would likely
contain information related to an organization’s revenue structure and other proprietary and
commercial information and the release of such information would cause substantial harm to the
competitive position of the issuer and could therefore be kept confidential under exemption 4.
Consultation Outside of the Agency
On June 5, 2017, the Board published an initial notice in the Federal Register
(82 FR 25801) requesting public comment for 60 days on the proposal to extend, without
revision, the FR 3063. The comment period for this notice expired on August 4, 2017. The
Board did not receive any comments. On September 7, 2017, the Board published a final notice
in the Federal Register (82 FR 42347), and the information collection will be extended as
proposed.
Estimate of Respondent Burden
The current annual reporting burden for the FR 3063 surveys is estimated to be 1,750
hours as shown in the following table. The Board estimates that approximately 25 depository
institutions would take, on average, 25 hours each to complete the proposed issuer survey. In
addition, the Board estimates that approximately 75 state and local government offices would
take, on average, 15 hours each to complete the proposed government survey. These reporting
requirements represent less than 1 percent of the total Federal Reserve System paperwork
burden.

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Estimated
Annual
average hours
Frequency
per response

Number of
respondents5

FR 3063
Issuer Survey
Government Survey

25
75

1
1

Total

25
15

Estimated
annual burden
hours
625
1,125
1,750

The total cost to the public (issuers and governments) for these surveys is estimated to be
$96,075.6
Sensitive Questions
This collection of information contains no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Cost to the Federal Reserve System
The current annual cost to the Federal Reserve System for designing the surveys,
contacting the respondents, and compiling the information is estimated to be around $103,000.7

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Of these respondents, one respondent is considered a small entity 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/makesure-you-meet-sba-size-standards/table-small-business-size-standards.
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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.t01.htm. Occupations are defined using
the BLS Occupational Classification System, www.bls.gov/soc/.
7
Total cost to the Federal Reserve System was estimated using the following formula: (estimated staff time of 1000
hours, multiplied by average hourly rate of $50) plus estimated information technology costs of $53,000.

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