Emergency Memo

DEPARTMENT OF THE TREASURY
WASHINGTON, D.C. 20220

TO:

Alex Goodenough
Office of Information and Regulatory Affairs
Digitally signed by
Ryan A. Law
Date: 2020.11.25
11:00:36 -05'00'

FROM:

Ryan Law
Deputy Assistant Secretary
Office of Privacy, Transparency, and Records

SUBJECT:

Justification for Emergency Processing: Online Research Survey to Solicit
Customer Experience Feedback for Treasury Retail Investment
Manager (TRIM); OMB Control No. 1530-NEW

Pursuant to the Office of Management and Budget (OMB) procedures established at 5 CFR
1320.13, the Department of the Treasury (Treasury) requests emergency processing of an
Information Collection Request for online research surveys to solicit customer experience
feedback for Treasury Retail Investment Manager (TRIM).
Chapter 31 of Title 31 of the United States Code authorizes the Secretary of the Treasury to
prescribe the terms and conditions, including the form of issue, of United States Treasury
certificates of indebtedness. Currently, securities are issued via the TreasuryDirect system, an
electronic process for selling/issuing, servicing, and making payments on or redeeming U.S.
securities.
The current version of the TreasuryDirect system was launched in 2002. The system is outdated
and ineffective at allowing the U.S public to purchase Treasury securities such as Treasury Bills
directly from the U.S. government. It is believed that this ineffectiveness has driven current
customers to seek alternative mechanisms, such as third-party brokerage firms, to purchase
investment products, including Treasury bills, often incurring fees. Buying directly from the US
Treasury is free. TreasuryDirect is also setting on aging infrastructure and the Bureau of the
Fiscal Service is working to replace TreasuryDirect by introducing the Treasury Retail
Investment Manager (TRIM) as part of a strategy to reach new customers, develop new and
innovative product delivery streams and increase the number of available product offerings. This
research is essential to inform the development of the new mission-critical TRIM system.
OMB approval to conduct the TRIM research is needed prior to the normal time periods
established in 5 CFR 1320.10. Any delay in conducting our quantitative and qualitative analysis
for our retail customers will cause a day for day delay to the Bureau’s Enterprise Priority to
replace Treasury Direct with a modern system and experience. In addition to schedule delays, it
will also increase the cost to our investment as we will need to potentially renegotiate our
contracts.

The Treasury has conducted initial qualitative research approved under OMB Clearance No.
1530-0023 to solicit customer experience feedback for Treasury Retail Investment Manager
(TRIM).
Additional phases of research are necessary to deliver a research-led approach to drive a
customer-centric TRIM product, brand and digital experience strategy, while helping guide an
enterprise-wide customer experience approach across Fiscal Service. The timing of the research
and the launch of the new product does not allow for public comment prior to conducting
additional research.
Additional information will enhance the research and information gathered to date by including
insights into the drivers of consumer saving and investment behavior for both customers and
potential customers of TRIM. Feedback on customer experience will allow Treasury to move
forward with further development of the TRIM system without risk of performing rework which
would be even more costly to the government. Launching a sub-par product would negatively
affect the public perception of current and potential customers and lead to a potential loss of
funding from the public segment that uses Treasury products.
Because of the enterprise priority and immediate need to launch the new system, the Department
of the Treasury requests emergency processing and approval on November 25, 2020 for the
additional research. Supporting documentation and sample instruments will be provided for
OMB review but Treasury requests a waiver from the requirement to publish notice in the
Federal Register seeking public comment during review due to the short turnaround needed for
approval.