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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 is estimated that tens of thousands of consumers will be served. In order for CFPB to 

understand whether the program is effective 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 evaluation to examine program effects on clients. The process and outcome 

evaluations will involve three key data collection efforts: administrative data collected about 

clients by financial coaches for programmatic purposes; interview data collected by evaluators 

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 information (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 consumer financial laws. Consistent with the purposes of the 

Dodd-Frank Act, the CFPB’s mission includes establishing and enforcing clear, consistent rules 

for the financial marketplace; protecting American families from unfair financial practices; and 

developing and implementing a strategy to improve the financial literacy of consumers. For 

additional background on the CFPB, please see http://www.consumerfinance.gov/the-bureau/.

Section 1017(d)(1) of the Dodd-Frank Act establishes a separate fund in the Federal Reserve, the 

Consumer Financial Civil Penalty Fund (“Civil Penalty Fund” or “Fund”), into which the Bureau 

must deposit civil penalties it collects from any person in any judicial or administrative action 

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

Fund may be used ‘‘for payments to the victims of activities for which civil penalties have been 

imposed under the Federal consumer financial laws.’’ 12 U.S.C. 5497(d)(2). In addition, ‘‘[to]

the extent that such victims cannot be located or such payments are otherwise not practicable,’’ 
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the Bureau may use amounts in the Fund for the purpose of consumer education and 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 coaching 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 traditionally underserved consumers and communities.”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 intended 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. The coaches will also use the client data management system to capture the reasons

why clients are working with the coach in the first place (for example, to reduce debt), and 

progress towards those goals. Capturing the 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 clients, the other coaches could learn from this site or person’s processes or

techniques.

Common client outcome measures such as income, savings, debt, and credit, might be collected,

based on the stated goals identified by individual clients. In addition, it is likely that a set of

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

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

outcomes may be based on the existing programs’ service delivery needs and existing systems

and/or processes for collecting and tracking outcomes.

Finally, beyond 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 client meets 

with the coach, the coach will likely document relevant information towards 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 raw data will not be shared outside of CFPB (and its contractors and 

subcontractors collecting and analyzing the data). CFPB may, however, choose to release deidentified 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. Clients, 

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 using a client management system to collect and report both 

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

When collected, outcome surveys will be administered online 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. 
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The burden is on clients requesting the financial coaching service. 

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

If the collection 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 public 60 days to comment on these proposed new collections 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 

information 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.

The Bureau engaged in extensive consulation with people outside the Bureau on the design of 

the coaching program, to include the information collection component.

In 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 2013) 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 held meetings with 

more than two dozen experts and leaders from organizations (including non-profit, for-profit, and 

government) providing services to the respective consumer groups. CFPB has also conducted 
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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 respondents 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 standard 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 treated 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 the service delivery and evaluation teams 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 anticipated 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 are not 

mandatory and that the data will be used only for research purposes. (2) Access to private 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) Project 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. 
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• 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. 

Reports produced under this evaluation 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 procedures 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 respondents, will not be reported or 

shared in a way that would reasonably allow anyone to link what they tell the research team with 

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 consultants 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 passwordprotected computers and/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 participants as outlined below) as part 

of program evaluation efforts. 

Finally, 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. 
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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 

containing the SSNs will be destroyed. SSNs will not be used as an administrative 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 Notice (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) assessing 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 for certain aspects of the program (such as intake for the client 

management system). However, as noted, aggregate data stripped of direct identifiers 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 questions 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/comparison 

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 evaluations 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 representative 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 for 
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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, they are not included in the burden calculations below.

EXHIBIT 1. ESTIMATE OF ANNUALIZED TIME BURDEN TO RESPONDENTS 

Number of

Respondents

Number of 

Responses

Per 

Respondent

Total 

Annual 

Responses

Average

Burden per

Response

(in hours)

Total 

Annual 

Burden

Hours

Client Information for CMS

(Client Management 

System)

10,000 1 10,000 .10 1,000

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

Process evaluation 

interview questions 50 1 50 .75 38

Follow-up outcome survey 1,000 1 800 .33 267

Total 10,000 //////////////// 20,850 //////////////// 3,792

EXHIBIT 2. ESTIMATE OF ANNUALIZED COST BURDEN TO RESPONDENTS 

Number of

Respondents

Total annual 

burden

hours

Average 

hourly

wage rate3

Total 

annual cost

burden

Client Information 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 37th 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.
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There are no capital/start-up or ongoing operation/maintenance costs associated with 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 interview 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 would 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 exemption to 

these certification requirements.