Page 1 of 9 CONSUMER FINANCIAL PROTECTION BUREAU INFORMATION COLLECTION REQUEST

– SUPPORTING STATEMENT Financial Coaching Program for Veterans and Low

- income Consumers (OMB CONTROL NUMBER: 3170

- XXXX)

TERMS OF CLEARANCE: Not applicable. This is a request for a new collection of

information.

ABSTRACT: Beginning in late 2014 , the Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) will launch a Financial Coaching project to provide direct financial coaching services to transitioning veterans and economically vulnerable consumers nationwide . Over three years, it i s estimated that tens of thousands of consumers will be served. In order for CFPB to understand whether the program is eff ective and for the financial coaches to be able to deliver efficient services and track clients over time, CFPB will need to take steps to evaluate the program. This will include a process evaluation to examine program implementation and an

outcomes evalua tion to examine program effects on clients. The process and outcome evaluations will involve three key data collection efforts: administrative data collected about clients by f inancial coaches for programmatic purposes; interview data collected by evaluato rs from key informants such as coaching clients, financial coaches and program administrators; and

self

- reported survey data from coaches and coaching clients. The information to be collected

from clients will likely include a combination of personal infor mation (basic contact and demographic information), performance metrics (outputs)

, client

- level outcomes (progress

towards financial goals or other relevant outcomes ) and programmatic and organizational

outcomes

.

A. JUSTIFICATION

1. Circumstances Necessitating the Data Collection

The Dodd

- Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd

- Frank Act”),

Pub. L. 111

- 203, established the CFPB to regulate the offering and provision of consumer products or services under federal consume r financial laws. Consistent with the purposes of the

Dodd

- Frank Act, the CFPB’s mission includes establish ing and enforc ing clear, consistent rules for the financial marketplace ; protect ing American families from unfair financial practices ; and develop ing and implement ing a strategy to improve the financial literacy of consumers. For additional background on the CFPB, please see http://www.consumerfinance.gov/the

- bureau/

.

Secti on 1017(d)(1) of the Dodd

- Frank Act est ablishes a separate fun d in the Federal Reserve, the

Consumer Financ ial Civil Penalty Fund ( “ Civil Penalty Fund ” or “Fund” ), into which the Bureau must depo sit civil penalties it collects fro m any person in any judicial or admi nistrative action

under Federal con sumer financial laws. 12 U.S.C. 5497(d )(1). Under the Act, amounts in the

Fun d may be used ‘‘for payments to the victim s of activities for which civil penalt ies have been imposed under the Federa l consumer financial laws.’’ 12 U.S.C. 5497 (d )(2). In addition, ‘‘[t o ]

the ext ent that such victims cannot be located or such payments are otherwise not practicable,’’Page 2 of 9 the Bureau may use a mounts in the Fund for the purpose of consumer e ducation a nd financial literacy programs.

This program represents the first consumer education program funded by the Civil Penalty Fund

. Because of the scope and size of the program, it is crucial that CFPB collect data on the

beneficiaries of the financial coachi ng services in order to understand if the services are working well and how they might be improved upon.

Additionally, the goals of this project are in line with the individual office mandates of both the

Office of Servicemember Affairs and the Office of Financial Empowerment. The Dodd

- Frank Act assigns the CFPB’s Office of Servicemember Affairs the responsibility to educate and empower servicemembers and their families to make better informed decisions regarding consumer financial products and services. Similarly, the CFPB’s Office of Financial Empowerment seeks to meet the Bureau’s statutory mandate to “provid[e] information, guidance, and technical assistance regarding the offering and provision of consumer financial products and services to traditional ly underserved consumers and commu nities.” 1

New data collection is necessary to help the CFPB and its stakeholders understand whether the program is effective and efficient, and also to gain insights into how the program can be improved.

2. Use of the Information

The information to be collected will likely include a combination of client personal information (i.e., basic contact and demographic information ), performance metrics (outputs)

, client

- level

outcomes related to financial goals

, as well as other relevant organization

- level outcomes.

The coaches will likely be working with the clients over multiple sessions and their information will be collected and housed in a client management system. In addition to that personal

information i ntended for client management and follow

- up , the coaches will also be required to document high level information about the client’s financial goals and progress made towards

those goals . T he coaches will also use the client data management system to captu re the reason s why clients are working with the coach in the first place (for example, to reduce debt) , and progress towards th ose goal s

. Capturing t he outcomes from coaching sessions will help CFPB

determine if the sessions, the coach, and program overall are effective in helping clients achieve their financial goals. CFPB will be able to identify and learn from information that is gleaned from the success of clients and coaches. For example, if one site or coach is particularly effective in working with c lients, the other coaches could learn from this site or person’s processes or technique s

.

C ommon client outcome measures such as income, savings, debt, and credit, might be collect ed

, based on the stated goals identified by individual client s. In addition , i t is likely that a set of

standard outcome measure s will be collected from clients across all coaching sites, as well as

1 12 U.S.C. § 5493.Page 3 of 9 outcomes that vary by site and by the types of populations being served. These site

- specific

outcomes may be based on the existing p rograms ’ service delivery needs and existing systems and/or processes for collecting and tracking outcomes.

Finally, b eyond client outcomes, CFPB may also be interested in collecting additional information (e.g., from coaches, the delivery organizations/agencies, etc.) to contribute to its knowledge and understanding of what has been effective and how to improve the program moving forward. By understanding the macro

- level needs of the clients and coaches, the program can, for example, adjust and respond to training needs that coaches may have in response to issues that the clients are presenting. The bulk of the administrative information collected would

be at the time of intake and captured in the client management system. Each time the clie nt meets with the coach, the coach will likely document relevant information to wards goal accomplishment

. There will also be follow

- up interviews and surveys to capture outcome data

from non

- veteran segments of the clients being served.

The client

- level r aw data will not be s hared outside of CFPB (and its contractors and subcontractors collecting and analyzing the data) . CFPB may , however, choose to release de

identified results and aggregated analyses of those results (such as trends in financial issues) in public reports it will issue. Veteran

- specific data will not be released to the public. C lients

, coaches, and supervisors would provide informed consent before participating in any interview

and/ or survey.

3. Use of Information Technology

Although the administrative data will be collected through conversations that coaches have with their clients, they will be u sing a client management system to collect and report both

information about the clients but also the progress towards their goals.

When collected, outcome surveys w ill be administered on line and/or via telephone. Outcome survey data will be recorded via the survey organization’s Computer Assisted Telephone Interviewing (CATI) system. This system allows interviewers to put pre

- coded responses directly into an electronic database which reduces errors. It automatically guides interviewers through skip patterns , which saves time. This system will ensure that the interview data are accurately recorded and that the outcome survey imposes a reduced burden on respondents. The online version of any survey will similarly rely on skip patterns to target relevant questions only to those respondents who need answer them, which results in time savings.

4. Efforts to Identify Duplication

This information collection would be related to a new CFPB program, therefore, there are no concerns about duplication.

5. Efforts to Minimize Burdens on Small Entities

CFPB does not anticipate any small businesses being impacted by this collection of information.Page 4 of 9 The burden is on clients requesting the financial coaching service

.

6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction

If the coll ection is not conducted, CFPB would not be able to know how the program is performing , nor would it know how to improve the program moving forward.

7. Circumstances Requiring Special Information Collection

There are no special circumstances. The collection of information is conducted in a manner consistent with the guidelines in 5 CFR 1320. 5(d)(2)

.

8. Consultation Outside the Agency

In accordance with 5 CFR 1320.8(d)(1), the Bureau has published a notice in the Federal Register allowing the p ublic 60 days to comment on these proposed new c ollection s of information. Further and in accordance with 5 CFR 1320.5(a)(1)(iv), the Bureau will publish a notice in the Federal Register allowing the public 30 days to comment on the submission of this

info rmation collection request to the Office of Management and Budget. While we are requesting comment on the full package, at this time, the Bureau is only seeking approval for the information collected in association with the client intake process and client management process system. The follow

- up and process evaluation will be submitted to OMB at a later date and will be announced in FEDERAL REGISTER with an opportunity for public comment.

T he Bureau engaged in extensive consulation with people outside the Bureau on the design of the coaching program, to include the information collection component.

I n the process of developing the procurement for the financial coaching program for transitioning veterans and economically vulnerable consumers, the Bureau:

1) Released a public request for information (RFI) in April 2013 to solicit feedback from organizations, potential vendors, and experts. This was sent out to over 2,000 stakeholders working with military and low

- income consumers. We received comments from 50 different organizations and individuals, including organizations serving these respective populations, experts in financial coaching, financial counselors, and others.

2) Held a pre

- solicitation conference in Washington

, DC with webcasting (August 201 3) after

the release of a draft solicitation. That conference was widely attended by vendors and groups

with an interest in veterans and other issues. Potential vendors were invited to submit questions before and during the conference, and the Bureau received and addressed over 200 questions

.

3) Conducted general outreach to learn more about the coaching approach and understand the best way to deliver services to the respective populations . Specifically, CFPB h eld meetings with more than two dozen experts and leaders from organizations (including non

- profit, for

- profit, and government) providing services to th e respective consumer groups. CFPB has also conductedPage 5 of 9 site visits to existing financial coaching programs and attended coaching trainings.

9. Payments or Gifts to Respondents

No payments or gifts will be provided to responden ts for the administrative data

. No payments or gifts will be provided to coach or supervisor respondents for interview or survey responses. Appropriate incentives will be provided for coaching clients who complete an interview and/or

survey.

10. Assurances of Confidentiality

The stand ard confidentiality provisions of the programs of the sponsoring institutions will apply. Respondents to any interview or survey will be given the opportunity to provide informed consent either in written form or verbally over the phone. Data will be trea ted in a private

manner, and directly

- identifying information ( e.g. , respondent names) will not be made available

to CFPB

. Further, any resulting reports on the program will consist only of de

- identified results and aggregated analyses of those results that will be reported in a way that could not reasonably identify any respondent

.

CFPB and t he service delivery and evaluation team s are committed to securely collecting and using the private information collected under this evaluation

. The evaluation procedures will be reviewed by the evaluation partner’s Institutional Review Board (IRB), which reviews proposed collections of potentially sensitive or private data and associated data security measures. 2 To receive IRB approval for a study, the data collection effort must adhere to the following principles:

• Subjects are informed of the nature of the research and how it will be used, and their
consent is either obtained or explicitly waived, where risks to them are determined to be

minimal.

• Adequate provision is made to protect the privacy of subjects and to maintain the privacy
of data that are collected, where promised and as appropriate.

• Risks to subjects from the research are reasonable in relation to a nticipated benefits, and
are minimized to the extent possible.

2 The evaluation partner’s IRB requires that the project’s data security measures ensure that: (1) Data will only be collected about individuals for

whom a signed active informed consent has been obtained. The consent procedures include assurances that requests for information a re not mandatory and that the data will be used only for research purposes

. (2) Access to priva te data will be limited to research team members who need access for evaluation purposes and who have agreed in writing to maintain the privacy of all data

. (3) Adequate precautions will be taken to ensure administrative and physical security of personally identifiable information

. (4) Proje ct findings and reports prepared for dissemination will not contain information that could reasonably be used to identify an individual. (5) Both electronic files and hard copy data materials will be stored securely

. (6) To protect the privacy of research subjects, the data files submitted to CFPB will be “sanitized” to remove any information that could be used to identify a particular individual. (7) All hard copy data files and materials containing personal identifiers will be destroyed

within six months of project completion.Page 6 of 9 • The selection of research subjects is as equitable as possible (the burdens and benefits of
the research are fairly distributed), with particular attention paid to research involving

vulnerable populations and protected health information.

Veteran clients will receive the same services under this initiative

, however they will not be

included in any further outcome or impact studies related to this project.

R eports produced under this evaluatio n will never identify individual respondents by name or

with directly

- identifying personally identifiable information from the key informant interviews

. Additionally, other personal information, such as outcomes survey or program administrative data, such as date of birth

, will not be included in reports produced . For all report and presentation purposes (e.g. draft reports, final reports, and any presentations of the report findings), primary data that are collected for the evaluation will be aggregated to a level at which

the individual identities of those who provided the information could reasonably be discerned

.

The informed consent procedure s will notify interview and survey respondents ( coaching clients

, coaches, and supervisors) that the information gathered from them through each data collection

channel will be combined with information from all other responde nts, will not be reported or shared in a way that would reasonably allow anyone to link what they tell the research team w ith who they are . In addition , no directly

- identifying personally identifiable information will be shared with anyone outside of the research team or at CFPB. Designated program evaluators who need the information for research purposes and who have signed a “Data Privacy Pledge” will

have access to client information. The Data Privacy Pledge is a document which stipulates the data security and privacy procedures which must be followed by all those participating in the

evaluation. All evaluation staff and co nsultants will sign this pledge prior to beginning

evaluation activities. Hard

- copy materials containing direct

- identifying PII will be locked up when not in use, and electronic materials will be stored on a secured server in password

protected computers a nd/or encrypted.

The CFPB is currently drafting a Privacy Impact Assessment (“PIA”) which addresses the collection and use of PII related to this project. The Consumer Education Research PIA has an anticipated publication date of early November, 2014.

11. Justification for Sensitive Questions

The coaches will be collecting Personally Identifiable Information (PII) . Coaches will collect

direct

- identifying PII including name and basic contact information to facilitate participation in the counseling program . Additionally, coaches will collect demographic data and respondent data (goals, challenges, outcomes information provided by participa nts as outlined below ) as part

of program evaluation efforts

.

F inally, coaches may collect other directly identifying information, including Social Security numbers (SSN) and financial account information (credit reports) for a subset of the non

- Veteran

clients who choose to participate ( providing informed consent) in this portion of the program.Page 7 of 9 Disclosure of SSNs by participants will be voluntary and not required for participating in the

program . For the outcome evaluation, SSNs would allow for the pulling of credit reports, and aid in allowing researchers to link self

- reported outcomes with credit bureau records. After credit

bureau information is accessed and linked to self

- reported outcome data, the documents

containin g the SSNs will be destroyed. SSNs will not be used as an ad ministrative identifier or tracking number to aid in the delivery of services; an alternative identification number will be developed. SSNs will not be collected as a normal course of action for program operation

purposes.

CFPB has a System of Records No tice (SORN) , CFPB.021

– Consumer Education and Engagement Records (FR 77 FR 60382 ) in place which will be updated (as necessary) to account
for the collection , use, disclosure, and destruction of PII as it relates to this project.

The project will collect and analyze response data provided by participants when coaches ask questions related to personal financial behavior, such as amount of savings, amount of debt, spending behavior and other personal financial information if applicable to the client’s goals

. Such response data may include sensitive information or be considered, when combined with

other data

, to be personally identifiable. Such data will be stripped of direct identifying PII for analysis purposes. Analysis will include (for example) assess ing financial outcomes and financial behavior relating to participation in the financial coaching program. Because of the individual nature of the program, the vendor, on CFPB ’s behalf, will need to collect the sensitive

information at the individual level fo r certain aspects of the program (such as intake for the client management system). However, as note d

, aggregate data stripped of direct identifi ers will be reported wherever possible and information would only be collected with consent of the client.

12. Estimated Burden of Information Collection

In Exhibits 1 and 2, we provide estimates of the collection burden on study participants. The project team anticipates a total of 10,000 clients enrolled in coaching services through this study. All clients will be asked to complete a brief series of quest ions for the Client Information System

as well as an intake/consent form.

We estimate the follow

- up outcomes study will need to survey just 1,000 individuals. These 1,000 will be divided between individuals who receive treatment and also a control/compar ison group. We arrive at the figure of 1,000 study participants based on approximations of the level of detail/power needed for 1) detecting programmatic impacts, and 2) describing these impacts for the set of selected study sites. Based on previous evalua tions with similar samples, we expect an 80 percent response rate to the survey, for a total of 800 responses. We will also conduct a process evaluation, and will perform in

- person interviews with 50 clients. We will select the clients to be representativ e of the total participant pool. As noted in Item 8 above, we are not seeking OMB approval for the follow

- up study and process evaluation at this time.

Using the Bureau of Labor and Statistics Occupational Employment Statistics (OES) survey 37th percentile we estimate an average hourly wage for coaching clients (economically vulnerable and returning veteran) of $13.76. We then multiply this figure by the number of burden hours forPage 8 of 9 each of these activities, which generates estimates of the total annual cost burden.

In addition to these data collection efforts, financial coaches may record information about clients during the course of their meetings (e.g. meeting goal, length, date, etc.) that also will be entered into the Client Management System. The evaluation will make use of these already collected program/administrative data, and as they do not represent new data collection from coaching clients, the y are not included in the burden calculations below.

E XHIBIT 1. E STIMATE OF A NNUALIZED T IME B URDEN TO R ESPONDENTS

Number of Respondents Number of Responses

Per Respondent Total

Annual Responses Average Burden per Response (in hours) Total

Annual

Burden

Hours

Client I nfo rmation for CMS (Client Management System) 10,000 1 10,000

. 10 1,000

Intake/Consent 10,000 1 10,000 .25 2,500

Process e valuation interview q uestions 50 1 50

. 75 38

Follow

- up outcome s urvey 1,000 1 800

. 33 267

Total 10,000 //////////////// 20,850 //////////////// 3

, 792

E XHIBIT 2. E STIMATE OF A NNUALIZED C OST B URDEN TO R ESPONDENTS

Number of Respondents Total annual

burden

hours Average hourly

wage rate 3 Total

annual cost

burden

Client I nfo rmation for the Client Management System 10,000 1,000 $13.76 $13,760

Intake/Consent 10,000 2,500 $13.76 $34,400

Process Evaluation Questions 50 38 $13.76 $523

Follow

- up Survey 1,000 267 $13.76 $3,674

Total $52,357

13. Estimated Total Annual Cost Burden to Respondents or Recordkeepers

3 Average hourly wage was derived from the Bureau of Labor and Statistics Occupational Employment Statistics (OES) survey

, using the 37 th percentile (Average hourly rates available at http://www.bls.gov/oes/current/oes_nat.htm ) . Note that many of the

clients will be seeking employment, so an average wage may not reflect the entire distribution

.Page 9 of 9 There are no capital/start

- up or ongoing operation/maintenance costs associated wi th this

information collection.

14. Estimated Cost to the Federal Government

The estimated cost for this work is still to be determined

. However, we estimate that CFPB will

need to cover the costs (via the contract) of a client management/outcome tracking system in order to be able to collect and report data , as well as costs associated with the collection, analysis, and reporting of interv iew and survey data

.

15. Program Changes or Adjustments

This submission to OMB is a new request for approval; there is no change in burden.

16. Plans for Tabulation, Statistical Analysis, and Publication

The period of time for the demonstration phase of the financial coaching project is three years with two additional option years. CFPB, at this time, plans to publish for stakeholders and the public at least one report that would provide basic information about the program’s implementation, the types of issues clients are facing, what their outcomes have been, and general lessons learned to date. All data would be published in the aggregate. CFPB does not know, at this time, what the publication(s) dates wo uld be, but the first publication would occur after the program has been up and running for at least one year.

17. Display of Expiration Date

The Bureau will display the expiration date for OMB approval of the information collection on

all instruments.

18. Exceptions to the Certification Requirement

The Bureau certifies this collection of information is consistent with the requirements of 5 CFR 1320.9, and the related provisions of 5 CFR 1320.8(b)(3) and is not seeking an ex em ption to
these certification requirements

.