FR3033_20200416_omb

Supporting Statement for the
Census of Finance Companies and Survey of Finance Companies
(FR 3033p and FR 3033s; OMB No. 7100-0277)
Summary
The Board of Governors of the Federal Reserve System (Board), under authority
delegated by the Office of Management and Budget (OMB), has extended for three years, with
revision, the Census of Finance Companies and Survey of Finance Companies (FR 3033p and
FR 3033s; OMB No. 7100-0277). The FR 3033 information collection (the quinquennial)
consists of the Census of Finance Companies (FR 3033p), which the Board revised, as well as
the Survey of Finance Companies (FR 3033s), for which the Board has not revised at this time.
The Census of Finance Companies (FR 3033p) is the first part of a two-stage survey
series, which has been conducted at a regular five-year interval since 1955. The FR 3033p is a
census survey designed to identify the universe of finance companies eligible for potential
inclusion in the FR 3033s and to enable the stratification of the sample for a more statistically
efficient estimation. The FR 3033p gathers limited information including total assets, areas of
specialization, and information on the corporate structure of the companies. The second part of
this information collection, the Survey of Finance Companies (FR 3033s), collects balance sheet
data on major categories of consumer and business credit receivables and major liabilities and is
used to gather information on the geographic scope of the company’s operations and loan and
lease servicing activities.
The Board revised the FR 3033p to improve the accuracy of information collected to
determine whether a company meets the definition of a finance company and to make minor
modifications to the survey design. The Board did not revise the FR 3033s at this time. The
current estimated total annual burden for the FR 3033 is 9,800 hours, and would decrease to
6,024 hours. The adopted revisions would result in a decrease of 3,776 hours. The survey form
and instructions are available on the Board’s public website at
https://www.federalreserve.gov/apps/reportforms/default.aspx.
Background and Justification
Since June 1955, the Board has surveyed the assets and liabilities of finance companies in
five-year intervals. For purposes of this survey, finance companies were defined as companies
whose largest portion of assets is made up of consumer or business loans or leases excluding
commercial banks, cooperative banks, investment banks, savings banks, savings and loan
institutions and industrial loan corporations or their subsidiaries. Through 1975, all known U.S.
finance companies were surveyed. To reduce reporting burden, in 1980 the survey was split into
an extremely brief screening survey, which has been sent to all likely finance companies that
operate in the United States and its territories and possessions, and a longer survey, which has
been sent to a stratified random sample of identified finance companies. In 2005, the definition
of finance company was revised to include companies whose largest portion of assets was made
up of real estate loans; as a result, mortgage companies became eligible to participate in the

survey. In addition, the survey was revised to instruct finance companies to include the assets
and liabilities of their mortgage company subsidiaries.
In 2010, the quinquennial underwent a major revision. The title of the FR 3033p was
changed to “Census of Finance Companies” to stress that every response is important. Several
questions on the census were modified to allow the Board to make the determination of whether
a company is a finance company rather than asking whether it meets the definition. Similarly, the
title of the FR 3033s was changed to “Survey of Finance Companies”. Revisions to the FR 3033s
included reordering assets and liability data items from most liquid to least liquid, asking
additional detail on assets and liabilities, adding a section to gather information on servicing
activities and geographic distribution of the company’s activities, and creating a clearer
distinction among the broad balance sheet data items, detailed loan and lease data items, and offbalance-sheet securitization data items. The respondent panel sizes for both questionnaires were
increased, and the Board implemented a web-based survey option.
The Board has used the quinquennial survey data to benchmark monthly data series on
major assets and quarterly data series on liabilities of finance companies developed from the
monthly Domestic Finance Company Report of Consolidated Assets and Liabilities (FR 2248;
OMB No. 7100-0005), which is collected from a smaller sample of companies. These data are
used in internal analysis and are reported to the public in two monthly statistical releases, the
Finance Companies (G.20) and the Consumer Credit (G.19), as well as the quarterly Financial
Accounts of the United States (Z.1) release. As with many data series based on a fixed sample,
errors of estimation tend to increase over time and thus require periodic correction. These errors
reflect the evolution in the financial markets as new companies enter the market and market
shares change and the deterioration of the monthly sample panel as respondents close, merge or
otherwise leave the panel.
In addition to benchmarking the Flow of Funds data, information from the quinquennial
survey also provides the Board with an opportunity to learn about an important part of the
financial system. Finance companies are a key supplier of credit to households and businesses,
holding or managing about 13 percent of total consumer credit outstanding and a significant
share of the short- and intermediate-term business finance market. The business and consumer
credit holdings of finance companies are key elements of domestic nonfinancial debt, which is
monitored by the Board and the Federal Open Market Committee (FOMC) in the implementation
of monetary policy.
Description of Information Collection
FR 3033p
The FR 3033p is a census survey designed to identify the universe of finance companies
eligible for potential inclusion in the FR 3033s and to enable the stratification of the sample for
more statistically efficient estimation. The FR 3033p currently comprises 11 questions to assess
the company’s asset size, level of loan and lease activity, company structure, and licensing
authority.

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FR 3033s
From the universe of finance companies identified by the FR 3033p, a sample of finance
companies will be invited to fill out FR 3033s. From these finance companies, the FR 3033s
survey collects balance sheet data on major categories of consumer and business credit
receivables and major liabilities. In addition, the survey may be used to gather information on
topics that are pertinent to increasing the Federal Reserve’s understanding of the finance
companies.
Respondent Panel
Currently, the Board is in the process of identifying the potential universe of finance
companies. There is no national registry of finance companies to serve as the list frame for the
FR 3033p. In 2015, a list frame (which includes companies that are likely to be finance
companies) was obtained primarily from Dun and Bradstreet (D&B), Avention, and to a lesser
degree from other sources. Although these data vendors attempted to consolidate subsidiaries to
the highest level within any given corporate structure, responses to the census revealed their
algorithm was not adequate. Furthermore, there were a substantial number of the census forms
returned by the post office as undeliverable. The Board is currently working to identify the
vendor(s) with the best coverage of companies that are likely to meet the definition of a finance
company.
For the nation as a whole, the Board estimates up to 40,000 companies that, based on
results from the 2015 census, may meet the requirements for forming the list frame. In addition,
the Board may use Home Mortgage Disclosure Act (HMDA) data to identify additional
mortgage lenders that may meet the FR 3033p definition of a finance company. As in the past,
the Board proposes to contact all companies identified as likely finance companies with the
exception of companies that file the Financial Statements of U.S. Nonbank Subsidiaries of U.S.
Holding Companies (FR Y-11; OMB No. 7100-0244). The Board would mail census forms to up
to 40,000 companies. This is in line with the 2015 census in which approximately 37,000
censuses were mailed. Once the companies return the census, the Board would determine the
panel of respondents for inclusion in the FR 3033s.
If the census fails to achieve an 80 percent response rate, the Board will conduct a
nonresponse bias study1. In 2015, the census had a response rate of 32 percent, excluding the
postal returns. The Board is uncertain of likely response rates for the 2020 census but is basing
its burden estimates on a response rate of 30 percent. Thus, the Board is planning for the
nonresponse bias study, described below.
In an effort to improve the response rate for the census, which has been trending lower in
the past two decades, the Board is planning to conduct census mailings based on experience from
other surveys. The current plan includes a pre-survey notification letter, initial mailing, a secondwave mailing of the entire survey package to nonrespondents 15 days after the previous mailing,
1

See Office of Management and Budget Standards and Guidelines for Statistical Surveys, September 2006,
https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/assets/OMB/inforeg/pmc_survey_guidance_2006.pdf.

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and a postcard reminder sent to nonrespondents approximately 10 days after each wave of
mailing. The Board believes that these measures should bolster response rates. The adoption of a
web-based survey, which was inaugurated in 2010, is also expected to have positive effects on
response rates.
To cope with the expected level of nonresponse to the census, the Board also intends to
select a subsample of nonrespondents for further follow-up with phone calls. Comparison of the
characteristics between this subsample and the general population would form the basis for the
nonresponse bias study for the census and consequently serve to shape the design of the sample
for the FR 3033s. The Board, along with Federal Reserve Banks, anticipate following up with
4,000 nonrespondents for the census.
Revisions to the FR 3033p
The Board revised the FR 3033p to improve the accuracy of identifying finance
companies, improve response rates, and simplify the form overall; the FR 3033s was not revised
in this submission. The FR 3033p revisions, which are effective for the May 2020 survey date,
include:
 Revising the questionnaire title to “2020 Census of Finance Companies and Other
Lenders” for clarity. Responses from past rounds of surveys indicated that some
respondents might not view themselves as finance companies, even though they are likely
to be a target of interest by the survey definition.
 Revising general instructions at the beginning of the survey for clarity.
 Renumbering questions as needed to conform to revisions and to improve clarity, as a
result the FR 3033p will have seven questions instead of eleven.
 Clarifying the “No” option in question 1 to read “My company or I do not make loans or
leases (in person or online)” so that an early exit is offered to recipients who have likely
received the survey form by mistake.
 Revising the “Other” option in question 1 to have two choices: “Sold” and “Not in
business”.
 Simplifying question 3 to a yes/no question.
 Revising the wording in question 4 to read “Business loans and leases” and “Consumer
loans and leases”. Definitions for these terms are incorporated into the answer choices.
 Deleting question 5. This question asks about the types of credit or financing that a
company offers. It has five parts with multiple choices available for selection. This
question was first added to the 2015 census and the responses showed little value. The
burden seems relatively high, especially given the lack of value.
 Revising old question 11 and renumbering as 7. Explicit categories for contact
information are created, such as name of person completing the survey and title of the
person. City, state, and zip code information are asked in separate categories.
 Adding a check box at the end of the questionnaire to offer respondents an opportunity to
receive the results of the survey. This is a way to encourage participation and improve
survey response.

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Time Schedule for Information Collection
The Board conducts the quinquennial every five years. First, the FR 3033p census would
be sent out to respondents as a pretest to establish the respondent universe and inform the exact
questions of the FR 3033s. The FR 3033s survey is sent out to the respondents identified in the
FR 3033p one year later. Conducting the census less frequently would not provide the Board
with timely enough information to accomplish its goals and support the Board’s mission. The
first step of conducting the FR 3033p allows the Board to select more appropriate respondents
for the FR 3033s and ultimately benchmark the monthly Domestic Finance Company Report of
Consolidated Assets and Liabilities (FR 2248; OMB No. 7100-0005).
Public Availability of Data
The Board has used the quinquennial survey data to benchmark monthly data series on
major assets and quarterly data series on liabilities of finance companies developed from the
FR 2248, which is collected from a smaller sample of companies. These data are used in internal
analysis and are reported in aggregate format to the public in two monthly statistical releases, the
Finance Companies (G.20) and the Consumer Credit (G.19), as well as the quarterly Financial
Accounts of the United States (Z.1) release.
Legal Status
The FR 3033 is authorized pursuant to sections 2A and 12A of the Federal Reserve Act
(FRA). Section 2A of the FRA requires that the Board and the 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 long-term interest rates (12 U.S.C. § 225a). Under section 12A of the FRA,
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 their bearing upon the general credit situation of the country (12 U.S.C. § 263).
Information collected from the FR 3033 is used to fulfill these obligations. The FR 3033 is
voluntary.
The information collected pursuant to the FR 3033 is confidential pursuant to
exemption 4 of the Freedom of Information Act (5 U.S.C. § 552(b)(4)), which protects “trade
secrets and commercial or financial information obtained from a person and privileged or
confidential.”
Consultation Outside the Agency
For the renewal of this information collection, the Board consulted with OpenCorporates,
Competiscan, Zoominfo, Melissa Data, and Infogroup to identify companies as potential
respondents for the census.

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Public Comments
On January 16, 2020, the Board published an initial notice in the Federal Register
(85 FR 2740) requesting public comment for 60 days on the extension, with revision, of the
FR 3033p and FR 3033s. The comment period for this notice expired on March 16, 2020. The
Board did not receive any comments. On April 13, 2020, the Board published a final notice in
the Federal Register (85 FR 20496).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 3033 is 9,800
hours, and would decrease to 6,024 hours with the adopted revisions. The total number of
respondents including those that will respond to the nonresponse follow-up for the FR 3033p is
based on an estimated response rate of 30 percent of 40,000 potential respondents and a lower
response rate of 20 percent of 4,000 nonrespondents selected for follow-up, which equals 12,800
respondents. The response rate of 30 percent was based on the 2015 FR 3033p actual response
rate of 32 percent. As there are no changes being proposed for the FR 3033s at this time, the
burden will stay the same. These reporting requirements represent less than 1 percent of the
Board’s total paperwork burden.
Estimated
number of
respondents2

FR 3033
Current
FR 3033p
FR 3033s

Estimated
Estimated
Annual
average hours annual burden
frequency
per response
hours

16,000
1,200

1
1

0.5
1.5

8,000
1,800
9,800

12,800
1,200

1
1

0.33
1.5

4,224
1,800
6,024

Total
Proposed
FR 3033p
FR 3033s
Total
Change

(3,776)

2

Of these respondents, it is anticipated that 11,500 FR 3033p respondents and 1,150 FR 3033s respondents would
be considered small entities as defined by the Small Business Administration (i.e., entities with less than $600
million in total assets), https://www.sba.gov/document/support--table-size-standards. There are no special
accommodations given to mitigate the burden on small institutions.

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The estimated total annual cost to the public for the FR 3033 is $565,950, and would
decrease to $347,886 with the adopted revisions.3
Sensitive Questions
These collections of information contain no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System for collecting and processing this
information collection is $536,300.

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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 $20, 45% Financial Managers at
$71, 15% Lawyers at $70, 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 2019, published March 31, 2020, https://www.bls.gov/news.release/ocwage.t01.htm. Occupations are defined
using the BLS Standard Occupational Classification System, https://www.bls.gov/soc/.

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