FR1378_20231030_omb

FR1378_20231030_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).1 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.
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). The content of
survey questions and consumer or stakeholder respondents vary from survey to survey. Survey
respondents include individuals, businesses, non-profit institutions, government entities, and
other Board stakeholders.
The estimated total annual burden for the FR 1378 is 2,300 hours. There is no formal
reporting form for this information collection.
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.
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
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, (3) inform respondents that the
information collection has been approved, (4) be used only in such cases where response is voluntary, (5) not be
used to substantially inform regulatory actions or policy decisions, (6) be conducted only and exactly as described in
the OMB submission, (7) involve only noncontroversial subject matter that will not raise concerns for other Federal
agencies, (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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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 information
obtained through the FR 1378 to gather feedback and follow-up information regarding these
activities. This information is not available from other sources.
The FR 1378 has been used once in the period from 2020 through 2023 for a survey
testing the user experience of the Consumer Compliance Outlook website in conjunction with the
Federal Reserve Bank of Philadelphia. The survey was fielded to fewer than the 10-person
threshold required for Paperwork Reduction Act clearance, although approval was received in
case the vendor required additional surveys.
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 under
the FR 1378 relating 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 under the FR 1378 relating 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, mail, other electronic device, or a combination of these methods.
For both quantitative and qualitative surveys, the Board may partner with a Federal
Reserve Bank to develop the survey instrument, plan data collection methods, and/or report
findings. The Board may 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 and a Federal
Reserve Bank, or 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

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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. 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.
Frequency and Time Schedule
The frequency of the survey and content of the questions will vary as needs arise for
feedback on different resources and audiences. The time schedules for the collection and analysis
of data and the distribution of results for each survey are determined during the planning phase
prior to the start of the data collection. Before an individual survey begins, the respondents to
that survey 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 Board uses the information obtained through the FR 1378 to discharge its statutory
responsibilities, including its authority to prescribe or enforce regulations under various
consumer protection laws such as the 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(b)), Equal Credit Opportunity Act (15 U.S.C. §§ 1691b(f) and 1691c),
Electronic Fund 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 (42 U.S.C. § 4012a). In
addition, the Board uses the information obtained through the FR 1378 to discharge its statutory
responsibilities to conduct monetary policy under sections 2A and 12A of the Federal Reserve
Act (12 U.S.C. §§ 225a and 248a). Survey submissions under the FR 1378 are voluntary.
Individual respondents may request confidential treatment in accordance with the Board’s
Rules Regarding Availability of Information.2 Requests for confidential treatment of information
are reviewed on a case-by-case basis. To the extent information provided under these collections
2

12 CFR 261.17.

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is nonpublic commercial or financial information, which is both customarily and actually treated
as private by the respondent, or to the extent the information reflects personnel and medical files
and similar files the disclosure of which would constitute a clearly unwarranted invasion of
personal privacy, the information may be protected from disclosure pursuant to the Freedom of
Information Act exemption 4 or 6, respectively (5 U.S.C. §§ 552(b)(4) and (b)(6)).
Consultation Outside the Agency
The Board may consult informally with outside experts, including staff from other
agencies and Federal Reserve Banks, to obtain 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 August 18, 2023, the Board published an initial notice in the Federal Register (88 FR
56623) requesting public comment for 60 days on the extension, without revision, of the
FR 1378. The comment period for this notice expired on October 17, 2023. The Board did not
receive any comments. The Board adopted the extension, without revision, of the FR 1378 as
originally proposed. On November 30, 2023, the Board published a final notice in the Federal
Register (88 FR 83540).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 1378 is 2,300
hours. These estimates are based on a maximum of 16 surveys per year with an average number
of responses for each survey; however, the actual number of surveys conducted under the
FR 1378 may be lower in a given year, and response rates may be higher or lower than
anticipated. These reporting requirements represent less than 1 percent of the Board’s total
paperwork burden.

FR 1378
Consumer surveys:
Quantitative
Qualitative
Stakeholder surveys:
Quantitative
Qualitative

Estimated
number of
respondents3

Estimated
annual
frequency

1,000
50

2
4

0.25
1.50

500
300

800
50

6
4

0.25
1.50

1,200
300
2,300

Total
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Estimated
Estimated
average hours annual burden
per response
hours

The information collection is voluntary, and no respondents are required to comply with this information
collection. Of these voluntary respondents, 255 quantitative stakeholders and 40 qualitative stakeholders are
considered small entities as defined by the Small Business Administration (i.e., entities with less than $850 million
in total assets). Size standards effective March 17, 2023. See https://www.sba.gov/document/support-table-sizestandards. There are no special accommodations given to mitigate the burden on small institutions.

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The estimated total annual cost to consumers (individuals) for participating in these
surveys is $24,000,4 while the estimated total annual cost to stakeholders (institutions) is
$99,375.5 Accordingly, the estimated total annual cost to the public for the FR 1378 is $123,375.
Sensitive Questions
Respondents may be asked to provide information on their age, gender, and race, which,
if needed, would be collected under guidelines issued by the OMB. 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 estimated cost to the Federal Reserve System for collecting and processing this
information collection is up to approximately $300,000. This estimate is based on 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.

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The average consumer cost of $30 is estimated using data from the Bureau of Labor Statistics (BLS), Occupational
Employment and Wages, May 2022, published April 25, 2023, https://www.bls.gov/news.release/ocwage.t01.htm.
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Total cost to the responding public is estimated using the following formula: total burden hours, multiplied by the
cost of staffing, where the cost of staffing is calculated as a percent of time for each occupational group multiplied
by the group’s hourly rate and then summed (30% Office & Administrative Support at $22, 45% Financial
Managers at $80, 15% Lawyers at $79, and 10% Chief Executives at $118). Hourly rates for each occupational
group are the (rounded) mean hourly wages from the BLS, Occupational Employment and Wages, May 2022,
published April 25, 2023, https://www.bls.gov/news.release/ocwage.t01.htm. Occupations are defined using the
BLS Standard Occupational Classification System, https://www.bls.gov/soc/.

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