FR3073_20201024_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 authority
delegated by the Office of Management and Budget (OMB), has extended for three years,
without revision, the 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 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 conducts the
FR 3073 as needed, up to 30 times per year. While the Board estimates that while FR 3073 may
be conducted up to 30 times per year, history suggests a lower frequency is more likely.
The estimated total annual burden for the FR 3073 is 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.

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 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 sensitive 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.
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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). 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
developing the wording of survey questions, and complementing a quantitative survey in a mixed
method research design.
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),
http://www.federalreserve.gov/econresdata/consumers-and-mobile-financial-services-report-201603.pdf and
https://www.federalreserve.gov/consumerscommunities/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 2018, (Washington: Board of Governors, May),
https://www.federalreserve.gov/consumerscommunities/shed_publications.htm and
https://www.federalreserve.gov/consumerscommunities/shed_data.htm.

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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,
 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,

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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, and
human capital investment decisions and labor market outcomes.

For the quantitative consumer surveys, the Board typically contracts with an outside
vendor, selected through a competitive bid, 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 vendor, 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.4 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.
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
4

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

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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, and
 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.
Respondent Panel
The FR 3073 panel comprises individuals and Board stakeholders.
Time Schedule for Information Collection
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.

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Public Availablity of Data
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 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 FR 3073 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 3073 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 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),
 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 3073 are voluntary.
The ability of the Board 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

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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
In developing past surveys, the Board has periodically consulted informally with outside
experts, including staff from 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.
Public Comments
On July 21, 2020, the Board published an initial notice in the Federal Register
(85 FR 44078) requesting public comment for 60 days on the extension, without revision, of the
FR 3073. The comment period for this notice expired on September 21, 2020. The Board did not
receive any comments. On October 14, 2020, the Board published a final notice in the Federal
Register (85 FR 65044).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 3073 is 12,000
hours. 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 the Board’s total paperwork burden.

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Estimated
number of
respondents

FR 3073

Estimated
Annual
average hours
frequency
per response

Estimated
annual burden
hours

Consumer surveys
Quantitative (medium)
Quantitative (large)
Qualitative

3,000
6,000
50

4
2
8

0.25
0.40
1.5

3,000
4,800
600

Stakeholder surveys
Quantitative5
Qualitative6

1,500
50

8
8

0.25
1.5

3,000
600
12,000

Total

The estimated total annual cost to consumers for participating in these surveys is
$226,800,7 while the estimated total annual cost to stakeholders is $207,900.8 Accordingly, the
total annual cost to the public for the FR 3073 is $434,700.
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

5

Of these respondents, 500 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.
6
Of these respondents, 45 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.
7
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.
8
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/.

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million, based on estimates from other surveys.9

9

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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