Supporting Statement

BUREAU OF CONSUMER FINANCIAL PROTECTION
REQUEST FOR APPROVAL UNDER THE
“GENERIC INFORMATION COLLECTION PLAN FOR THE COLLECTION OF
QUALITATIVE FEEDBACK ON
THE SERVICE DELIVERY OF THE CONSUMER FINANCIAL PROTECTION
BUREAU”
(OMB Control Number: 3170-0024)
1. TITLE OF INFORMATION COLLECTION: Feedback on the Use of the Your Money,
Your Goals Toolkit
2. PURPOSE: This survey will collect information about people’s use of the Your Money, Your
Goals toolkit. The Bureau created the toolkit—and continually updates it—for social services
organizations interested in integrating financial empowerment activities into their work with
clients. For the past several years, the Bureau has selected annual cohorts of organizations to
receive training and technical assistance focused on how to integrate Your Money, Your Goals
tools into the services they offer. These trainings follow a train the trainer model, with the
Bureau holding initial trainings in each selected community. Individuals who attend these initial
trainings then go on to train others, thereby multiplying the number of consumers that Your
Money, Your Goals reaches. In some cases, the Bureau deviates from this model and offers
trainings directly to frontline staff.
The survey described in this submission will gather information about attendees’ perceptions of
the trainings, quantify what share of training participants go on to use the toolkit with clients,
and explore what factors aid and impede its use. Intended survey respondents include people
who attend the train the trainer workshops as well as individuals who attend subsequent
trainings. The survey contains different sections to assess the toolkit’s use by trainers and by
frontline staff who work directly with clients. The survey will be fielded to approximately 1,500
individuals who attend train the trainer workshops led directly by the Bureau or subsequent
trainings. Ultimately, this survey will support the Bureau’s understanding of how people
integrate Your Money, Your Goals into a variety of settings, information that will be used to
improve the materials, trainings, and technical assistance.

3. DESCRIPTION OF RESPONDENTS: Individuals trained to use or trained to train others to
use Your Money, Your Goals will be surveyed. Most of these individuals are staff at social
services organizations.

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4. TYPE OF COLLECTION (ADMINISTRATION OF THE COLLECTION
INSTRUMENT):
a.

How will you collect the information? Check all that apply.
[X] Web-based or other forms of Social Media
[X] Telephone
[ ] In-person
[ ] Mail
[ ] Small Discussion Group
[ ] Focus Group
[ ] Other (please explain) __________________________________

b.

Will interviewers or facilitators be used?
[ ] Yes [X] No [ ] Not Applicable

5. FOCUS GROUP OR SURVEY:
If you plan to conduct a focus group or survey, please provide answers to the following
questions:
a. Do you have a customer list or something similar that defines the universe of potential
respondents and do you have a sampling plan for selecting from this universe?
[X] Yes [ ] No [ ] Not Applicable
b. If yes, please provide a description below. If no, please provide a description of how you
plan to identify your potential group of respondents and how you will select them.
Respondents will be recruited from a list of individuals who complete sign-in sheets at Your
Money, Your Goals training events. All individuals who sign in at these events will be
contacted to participate in the survey.
6. INFORMATION COLLECTION PROCEDURES:
Please summarize the procedures that will be used to collect data from respondents.
Respondents will receive an email inviting them to participate in the survey. The email
survey invitation and reminder text are included with this submission. In this email, there
will be a link and a unique identifier that will allow the respondent to enter the survey
website. Respondents who do not reply to the initial email invitation or up to two followup email invitations will receive a phone call inviting them to participate in the survey. A
script for that phone call is included with this submission. In the phone call, respondents
will also be provided the web address and their own unique identifier. Those who choose
to enter the survey will first see an informed consent page that advises respondents of
their right and the confidentiality of their responses. After consenting, respondents will
enter an online survey. The informed consent text and survey text are included with this
submission.

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7. PERSONALLY IDENTIFIABLE INFORMATION:
a. Is personally identifiable information (PII) collected? [X] Yes [ ] No
b. If yes, is the information that will be collected included in records that are subject to the
Privacy Act of 1974?
[X ] Yes [ ] No [ ] Not Applicable
If Yes, describe what PII will be collected and why it is needed and how it will be
used.
The researchers will use PII from Your Money Your Goals sign-in sheets collected at the
trainings to send survey invitations and reminders. Information contained on those sign-in
sheets include names, email addresses, and telephone numbers. This information is necessary to
identify individuals who have been trained to use Your Money, Your Goals and will be used to
contact potential respondents. PII will also be needed to facilitate incentive fulfillment. PII will
not be used for any purposes other than sending the invitations and fulfilling the incentives.
To add anonymity to the collected data, the researchers will assign each record a unique random
PIN. This PIN will be used to ensure each survey is completed only once and facilitate the
tracking of completion progress. Throughout the survey-fielding period the research contractor
will handle incentive processing for completed surveys utilizing the PII provided. PII will be
transfered using a secure transfer method such as SFTP or HTTPS. Study contractors will store
data password protected servers with hard drives that utilize FIPS 140-2 standard encryption in
a locked server room. Access to files, both internally and for transfer, is granted to only those
user accounts with a project requirement for access.
PII will be stripped from all files used to analyze the data, and at the conclusion of the study all
PII will be sanitized off servers using Department of Defense sanitization standard DoD
5220.22-M which overwrites all addressable locations with a character, its complement, then a
random character. Once this data has been sanitized there will be no way to link the collected
data to the original PII.
The collection instrument collects demographic data, but it is not required to participate in the
survey.

c. Has a System or Records Notice (SORN) been published?
[ ] Yes [ ] No [X ] Not Applicable
If yes, list the SORN title and Federal Register (FR) citation
Title: ________________________________________________________
__ FR ________________________.
d. If applicable, please provide a link to the Privacy Impact Assessment.
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8. INCENTIVES:
a. Is an incentive provided to participants? [ ] Yes [X] No
b. If yes, provide a statement justifying the use and amount of the incentive and the
amount or value of the incentive: $_ __________.
9. ASSURANCES OF CONFIDENTIALITY:
a. Will a pledge of confidentiality be made to respondents? [ ] Yes [ X] No
b. If yes, please cite the statue, regulation, or contractual terms supporting the pledge.
10. JUSTIFICATION OF SENSITIVE QUESTIONS (if applicable): N/A
11. BURDEN HOURS:
Collection of Information

Survey

Totals

Number of
Respondents
1,500
1,500

Frequency

Number of
Annual
Responses

1x
///////////////

1,500
1,500

Average
Response
Time
(hours)
.42
///////////////

Burden
(hours)

We have assumed a total response time of 25 minutes. This includes 15 minutes to respond to the
survey as well as 10 minutes to read recruiting emails or for recruiting phone calls.
12. FEDERAL COST: The estimated annual cost to the Federal government is $__270,415__.

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13. CERTIFICATION:
CERTIFICATION PURSUANT TO 5 CFR 1320.9, AND THE RELATED PROVISIONS OF
5 CFR 1320.8(b)(3):
By submitting this document, the Bureau certifies the following to be true:
(a) It is necessary for the proper performance of agency functions;
(b) It avoids unnecessary duplication;
(c) It uses plain, coherent, and unambiguous terminology that is understandable to
respondents;
(d) Its implementation will be consistent and compatible with current reporting and
recordkeeping practices;
(e) It indicates the retention period for recordkeeping requirements;
(f) It informs respondents of the information called for under 5 CFR 1320.8(b)(3):
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
(g) It was developed by an office that has planned and allocated resources for the efficient
and effective management and use of the information to be collected;
(h) It uses effective and efficient statistical survey methodology; and
(i) It makes appropriate use of information technology.
CERTIFICATION FOR INFORMATION COLLECTIONS SUBMITTED UNDER A GENERIC
INFORMATION COLLECTION PLAN
By submitting this document, the Bureau certifies the following to be true:
• The collection is voluntary.
• The collection is low-burden for respondents.
• The collection is non-controversial and does not raise issues of concern to other Federal
agencies.
• Information gathered will not be used for the purpose of substantially informing
influential policy decisions.
• The collection is not statistically significant; the results are not intended to be
generalizable beyond the survey population.
• The results will not be used to measure regulatory compliance or for program
evaluation.

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