FR1378_20201023_omb

FR1378_20201023_omb.pdf

Surveys of Consumer and Community Affairs Publications and Resources

OMB: 7100-0358

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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 authority
delegated by the Office of Management and Budget (OMB), has extended for three years,
without revision, the 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. 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 estimated total annual burden for the FR 1378 is 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, 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.

Certain criteria apply to information collections conducted via the Board’s ad hoc 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 a 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 sensitive 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 the OMB.
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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 information from users or potential users
of Board publications, resources, and conference material.
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 related
to such publications and resources may include: general input on users’ interests and needs; the
relevance of the content; feedback on website navigation and layout, distribution channels, or
other factors that may affect the ability of users to locate and access content online; feedback on
the length and nature of the discussion; 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 materials may include the information that is
generated by and distributed to attendees and users during or after the event. Information
gathered related to conference materials may 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.
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

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and a Federal Reserve Bank, and when resources targeted at consumers and/or stakeholders are
region specific.
Additionally, the Board may choose to contract with an outside vendor, selected through
a competitive bid, 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.
Respondent Panel
The FR 1378 panel comprises individuals, businesses, non-profit institutions, government
entities, and other Board stakeholders.
Time Schedule for Information Collection
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.
Public Availability of Data
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 FR 1378 is authorized by sections 2A and 12A of the Federal Reserve Act (FRA).
Section 2A of the FRA 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
the 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(c)). The information collection under the FR 1378 is used to fulfill
these obligations.
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

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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),
 Fair Credit Reporting Act (15 U.S.C. § 1681s(e)),
 Equal Credit Opportunity Act (15 U.S.C. § 1691b),
 Electronic Funds Transfer Act (15 U.S.C. §§ 1693b and 1693o-2),
 Gramm-Leach-Bliley Act (15 U.S.C. § 6801(b)), and
 Flood Disaster Protection Act of 1973, section 102 (42 U.S.C. § 4012a).
Survey submissions under the FR 1378 are voluntary. The information collected under
the FR 1378 is not confidential.
Consultation Outside of the Agency
There has been no consultation outside of the Federal Reserve System.
Public Comments
On May 11, 2020, the Board published an initial notice in the Federal Register
(85 FR 27740) requesting public comment for 60 days on the extension, without revision, of the
FR 1378. The comment period for this notice expired on July 10, 2020. The Board did not
receive any comments. On September 17, 2020, the Board published a final notice in the Federal
Register (85 FR 58056).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 1378 is 2,300
hours. The information collection could involve as many as 16 surveys, although the surveys
may not be conducted that frequently. The burden estimates are based on the average number of
responses anticipated. These reporting requirements represent less than 1 percent of the Board’s
total paperwork burden.

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Estimated
number of
respondents

FR 1378
Consumer surveys
Quantitative
Qualitative
Stakeholder surveys
Quantitative2
Qualitative3

Estimated
Annual
average hours
frequency
per response

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 total annual cost to consumers (individuals) for participating in these
surveys is $21,600,4 while the estimated total annual cost to stakeholders (institutions) is
$86,625.5 Accordingly, the estimated total annual cost to the public for the FR 1378 is $108,225.
Sensitive Questions
Respondents may be asked to provide information on their race, which, if needed, would
be collected under guidelines issued by the OMB, age, and gender. 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.
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.6
2

Of these respondents, 250 are 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 entities.
3
Of these respondents, 40 are 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 entities.
4
The average consumer cost of $27 is estimated using data from the BLS Economic News Release (USDL-20-0300)
https://www.bls.gov/news.release/archives/cewqtr_02202020.htm.
5
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, http://www.bls.gov/news.release/ocwage.t01.htm. Occupations are defined
using the BLS Standard Occupational Classification System, http://www.bls.gov/soc/.
6
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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