3170-0082 (Behavioral Biases in the Use of Unsecured Credit) Supporting Statement

Generic Information Collection Plan for Foundational Research About Consumer Credit Markets and Household Financial Decision-Making(OMB Control Number: 3170-0082)

PART A. GENERAL INFORMATION

1. Title of the Information Collection (Study): Behavioral Biases in the Use of Unsecured Credit

2. Study Abstract: The CFPB’s Office of Research seeks to better understand consumer decision-making and psychology surrounding unsecured credit, a segment of consumer credit that is regularly used by consumers. This project asks how credit availability, type, and framing may influence consumers’ hypothetical decision-making behaviors or intentions related to credit products. Specifically, we will ask in an online survey study (1) how the framing and amount of an available credit limit influences decision-making, and (2) whether any effects of framing or amount are robust across credit types and shopping modalities (e.g., in-app shopping through financial service providers).

3. Type of Collection:

1. Will there be an informed consent? [X ] Yes [ ] No [ ] N/A

Explain why or why not an informed consent is being used.

Informed consent will be used to explain the rights of the participant, and how their data will be collected, protected, and used so that the participant can make a fully informed choice about their participation in the study.

2. How will you collect the information? (Check all that apply)

[ ] Cognitive Laboratory Study [ ] Pilot Testing

_[ X ] Other, Explain [Online survey study]

3. Will interviewers or facilitators be used? [ ] Yes [ X ] No [ ] N/A

4. Personally Identifiable Information:

1. Is personally identifiable information (PII) collected? [] Yes [x] No

1. If yes, describe what PII collected, why it is needed and intended uses.

2. If Yes, is the information that will be collected included in records that are subject to the Privacy Act of 1974? [] Yes [ ] No [x ] Not Applicable

1. If Applicable, has a System or Records Notice (SORN) been published?

[] Yes [ ] No

2. If Yes, provide SORN title and Federal Register citation for the SORN _____

Title: ____ ____________________.

3. 1. Has the Privacy Impact Assessment (PIA) been published?

[x] Yes [ ] No [ ] Not Applicable

2. If Yes, provide link to Privacy Impact Analysis (PIA). If No, please describe that status of the PIA: https://www.consumerfinance.gov/f/201412_cfpb_market-research-in-the-field-v1.pdf

PART B. JUSTIFICATION

1. Purpose of the Study and Intended Uses of the Data:

The CFPB’s Office of Research seeks to better understand consumer decision-making and psychology in the use of unsecured credit. This research builds on the Bureau’s interest in credit services and credit utilization, and past research on factors that influence consumer decision-making and well-being. The findings will improve the Bureau’s understanding of consumer decision-making and use of credit products, including new practices and emerging trends in the marketplace.

The results from this study may be used as the subject of a published research report, peer-reviewed journal article, or other research deliverable. They will also help inform the topics and questions for future research. These results will not be used as the sole basis for any decision-making related to rulemaking or other policy agendas, but we do intend to share the results with other Bureau offices including Markets and Regulations. These results are not intended to generalize to broader populations.

2. Payments or Gifts (Incentives) to Respondents:

Study participants will each receive a fixed incentive, determined and delivered by CFPB’s vendor. This incentive will depend on the length of the study and will average to approximately $10.20 per hour.

3. Assurances of Confidentiality and Justification for Sensitive Questions:

We will provide notice to participants that explain how their information will be used through appropriate vehicles, such as Privacy Notices, Privacy Act Statements or Informed Consent forms. Such notice is made available prior to the collection of information and explains whether the information is mandatory or voluntary; whether there are any opportunities to consent to sharing and submission of information; how the information will be secured, and when a System of Records is created under the Privacy Act.

The study will begin with a privacy notice and an informed consent that broadly explains the purpose of their study and their participation. Participants will be allowed to exit the survey at any time.

4. Estimated Burden of Information Collection:

Information Collection	No. of Respondents	Frequency (Response per Respondent)	Total Annual Responses	Average Response Time (hours)	Total Burden Hours
Study Participants	4,050	1	4,050	.25	1,012.5
Totals:	4,050	1	4,050	.25	1,012.5

$60,453

5. Federal Costs (estimated annual cost to the Federal government):

PART D. 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:

1. It is necessary for the proper performance of agency functions;

2. It avoids unnecessary duplication;

3. It uses plain, coherent, and unambiguous terminology that is understandable to respondents;

4. Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

5. It indicates the retention period for recordkeeping requirements;

6. 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;

7. 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;

8. It uses effective and efficient statistical survey methodology; and

9. It makes appropriate use of information technology.

PART E. CERTIFICATION FOR INFORMATION COLLECTIONS SUBMITTED UNDER A GENERIC INFORMATION COLLECTION PLAN

1. The collection is voluntary.

2. The collection is low-burden for respondents and low-cost for the Federal Government.

3. The collection is non-controversial and does not raise issues of concern to other federal agencies.

4. The collection is not intended to be published to the public as an official government statistic to be externally valid and representative of a population of interest. The results are intended to be internally valid, not necessarily externally valid.

5. Information gathered will not be used for the purpose of substantially informing influential policy decisions.

6. The collection is targeted to the solicitation of opinions from respondents who have experience with the topics or issues being studied.

7. The results will not be used to measure regulatory compliance or for CFPB program performance evaluation.

8. The results are not intended to be generalizable or otherwise draw inferences beyond the survey population.

Revised December 2019