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BUREAU OF CONSUMER FINANCIAL PROTECTION

PAPERWORK REDUCTION ACT SUBMISSION

INFORMATION COLLECTION REQUEST

SUPPORTING STATEMENT PART A

Generic Information Collection Plan for Surveys Using the Consumer Credit Panel

(OMB CONTROL NUMBER: 3170-XXXX)

TERMS OF CLEARANCE: None. This is a Request for a new collection 

ABSTRACT: Under the Dodd-Frank Wall Street Reform and Consumer Protection Act, the 

Consumer Financial Protection Bureau is charged with researching, analyzing, and reporting on 

topics relating to the Bureau’s mission, including consumer behavior, consumer awareness, and 

developments in markets for consumer financial products and services. In order to improve its 

understanding of how consumers engage with financial markets, the CFPB uses the Consumer 

Credit Panel (CCP), a proprietary sample dataset from one of the national credit reporting 

agencies, as a frame to survey people about their experiences in consumer credit markets. The 

Bureau seeks to obtain approval for a generic information collection plan for these types of 

surveys. Survey responses will be used for general, formative, and informational research on 

consumer financial markets and consumers’ use of financial products and will not directly 

provide the basis for specific policymaking at the Bureau.

A. JUSTIFICATION

1. Circumstances Necessitating the Data Collection

Much of the Consumer Financial Protection Bureau (CFPB, Bureau)’s mission focuses

on understanding how consumer financial markets work, highlighting avenues for innovation in 

financial products and services, and identifying and mitigating potential risks to consumers.1 The 

Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) authorizes the 

CFPB to engage in research and market monitoring activities to assess trends and to identify 

 1 CFPB FY 2013 – FY 2017 Strategic Plan, goal 3, http://www.consumerfinance.gov/strategic-plan/
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emerging risks in consumer financial markets.2

 Section 1013(b)(1) of the Dodd-Frank Act 

establishes the Office of Research for the purpose of researching, analyzing, and reporting on 

topics related to the Bureau’s mission, including consumer behavior, consumer awareness, and 

developments in markets for consumer financial products and services. The Office of Research 

and the Bureau as a whole improve their understanding in these areas by analyzing empirical 

evidence and performing rigorous analyses that can be used to benefit consumers, businesses, 

researchers, and policymakers.

To perform the tasks necessary to carry out its mission, the CFPB needs to build a 

nuanced understanding of consumer behavior in financial markets. For this reason, the Office of 

Research is planning to build a portfolio of generic information collection plans for “research” 

functions (outside of rulemaking), to improve our scientific understanding. 

To further improve its understanding of how consumers engage with financial markets, 

the CFPB proposes research projects that rely on the Consumer Credit Panel (CCP), a 

proprietary sample dataset from one of the national credit reporting agencies. The CFPB seeks 

to use this generic information collection clearance to survey consumers of financial products 

and services based on credit records sampled from the CCP. The research will be used for 

developmental and informative purposes, but will not directly provide the basis for specific 

rulemaking or policymaking at the Bureau.

In general, the topics that the Bureau is interested in studying include:

• consumer experiences with financial products and potential risks to consumers, 

including traditionally underserved consumers;

• consumer awareness and decision-making, for example, understanding what 

financial products or features people are aware of and why they choose one 

product over another;

• information disclosure and how disclosure may affect behavior;

• the effect of educational or other interventions on consumer financial behavior or 

outcomes.

 2 DFA Section 1013(b)(1) mandates that the Bureau have research staff whose responsibilities include 

“[r]esearching, analyzing, and reporting on (A) developments in markets for consumer financial products or 

services, including market areas of alternative consumer financial products or services with high growth rates and 

areas of risk to consumers; (B) access to fair and affordable credit for traditionally underserved communities; (C)

consumer awareness, understanding, and use of disclosures and communications regarding consumer financial 

products or services; (D) consumer awareness and understanding of costs, risks, and benefits of consumer financial 

products or services; (E) consumer behavior with respect to consumer financial products or services, including 

performance on mortgage loans; and (F) experiences of traditionally underserved consumers, including un‐banked 

and under‐banked consumers.”
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These topics will typically be examined in the context of consumer financial product 

markets, including mortgages, auto loans, student loans, installment loans, small dollar loans, 

credit cards, debit cards, and prepaid cards. The CFPB envisions that the research covered 

under this generic clearance will be basic research about consumer credit markets and household 

finance.

When collecting information about consumer credit markets, the CFPB recognizes that 

there are privacy and data security risks. We outline the ways the CFPB plans to mitigate these 

risks when collecting data using this generic clearance later in this supporting statement.

2. Use of the Information

The CFPB requests approval from the Office of Management and Budget (OMB) for a 

generic information collection plan clearance which will allow the bureau to collect data by 

administering surveys which use the CCP as a survey frame. The specific purpose of this 

generic clearance is to allow the Bureau to better inform and advance scientific understanding of 

consumer credit markets and household finance. For example, the Office of Research envisions 

a broad, multifaceted set of data collection efforts, and this generic clearance will facilitate and 

expedite monitoring and research of market developments. This generic clearance will allow the 

Bureau to conduct data collections which will achieve our research goals with the least amount 

of burden on the public, and while ensuring strong privacy and data protections throughout these 

projects.

Research conducted under the requested clearance will not be the primary basis for 

particular regulatory decisions or for the development and evaluation of specific policies. 

Studies conducted under this generic approval may identify opportunities for enhanced or 

improved regulatory or other policy actions; however, as noted, the Bureau will not initiate any 

changes based solely on research projects enabled by this generic information collection plan . 

Activities conducted under this clearance may include pretesting of the questionnaires to 

ensure the collection of reliable information while minimizing the cost and burden to 

respondents. For example, the Bureau may engage in cognitive interviewing or pretesting to 

gauge the effectiveness of the survey questions and respondents’ understanding of the questions.
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The CCP is a 1-in-48 nationally representative random sample of de-identified credit 

records from one of the three major national credit reporting agencies. Using these data, the 

CFPB plans to select survey samples and then to inform the credit reporting agency of which 

credit records are selected. The credit reporting agency (which, unlike the CFPB, has access to 

direct identifying information related to these records) will mail a copy of the survey instrument 

to the consumer associated with each sampled credit record. The Bureau expects that for most 

surveys to be conducted under this clearance, consumers will be able to respond to the survey 

either online or by mail using a prepaid envelope. All responses will be collected by the credit 

reporting agency or a subcontractor, who will remove any direct identifying information that 

respondents may have inadvertently included, convert the responses into an electronic format, 

and transmit the data to the Bureau. The respondents will remain anonymous to the CFPB, but 

the survey responses will include a unique key that will allow responses to be matched with the 

associated de-identified credit record. The Bureau has experience using de-identified credit 

records as a sampling frame and with conducting mail and web surveys through this type of 

arrangement with the credit bureau and a survey subcontractor through its work with FHFA on 

the National Survey of Mortgage Borrowers and the expected Survey of Consumer Views on 

Debt.

The CCP data are proprietary and cannot be shared publicly. To allow outside 

researchers and other interested parties to benefit from research conducted by the Bureau, the 

CFPB may make a version of the survey data available publicly to the extent that such releases 

are legally permissible and consistent with protecting consumers’ privacy. Any public-release 

version of the data would be de-identified and exclude any direct identifying information. In 

addition, the CFPB may, for example, withhold some data elements, aggregate response 

categories, or take other steps to protect the privacy of respondents in any publicly available 

version of the data.

3. Use of Information Technology

Surveys will be sent by mail to sampled consumers. The Bureau expects to typically 

allow respondents to complete the survey either online or by mail using a prepaid envelope. The 
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website to complete the survey online will be hosted on servers owned and operated by the credit 

reporting agency’s subcontractor. 

The Bureau generally expects to provide a Spanish version of the survey instrument at 

least online for any survey. Returned paper surveys will be electronically scanned by a 

subcontractor of the credit reporting agency, stripped of any direct identifying information that 

the respondent may have inadvertently included, and converted to an electronic format. The data 

will then be transmitted to the CFPB using a secure FTP server.

4. Efforts to Identify Duplication

The CFPB will design surveys to address questions that have not yet been satisfactorily 

answered in the relevant research literature. For topics on which there exists previous research, 

the CFPB will detail the relationship between the proposal and existing studies and will describe 

how the data collection supports the CFPB’s mission. A review of the existing relevant literature 

will be undertaken before proceeding with any project initiated under this generic clearance. 

Surveys may include general questions that are asked on existing surveys to, for example, draw 

rough conclusions about how characteristics measured in the CFPB survey relate to those 

measured in other surveys.

5. Efforts to Minimize Burdens on Small Entities

No small businesses will be impacted by this study, as survey respondents will be 

individuals only.

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

We envision a series of one-time data collections, not an on-going collection of the same 

information. For this reason, less frequent collections are not possible.

The proposed clearance will allow the Bureau to collect information on the markets we 

regulate from consumers, allowing us to develop a more complete understanding of this market 

and consumers’ experiences with it. Without this data collection, the Bureau will not be as well 

informed, and the CFPB will not be able to achieve its mission as effectively. 
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Where appropriate, the CFPB plans to make the results of any research conducted using 

these data publicly available. Additionally, where legally permissible and consistent with 

protecting consumers’ privacy, we envision making the collected survey data available to 

researchers outside of the CFPB and to the public. Therefore, the data to be collected under this 

proposed clearance will not only improve the CFPB’s understanding of consumer financial 

markets, but also increase the knowledge of researchers and other policymakers.

7. Circumstances Requiring Special Information Collection

Generally, most information collections under this generic clearance will be conducted in 

a manner consistent with the guidelines in 5 CFR 1320. 5(d)(2). Most collections will require a 

single interaction between the agency and respondents, but some information collections could 

require multiple interactions. For example, some studies may ask for subjects to be surveyed 

more than once, and possibly more than once in a quarter. The CFPB will work to limit the 

burden on respondents and ensure that studies only include repeated interactions when the 

additional information gained is anticipated to be substantial and valuable to the study.

8. Consultation Outside the Agency

In accordance with 5 CFR 1320.8(d)(1), the Bureau has published a notice Federal 

Register allowing the public 60 days to comment on this proposed new generic information 

collection plan. 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.

9. Payment or Gifts to Respondents

Survey recipients will receive a pre-paid cash incentive as an inducement to complete and 

return the survey questionnaire (ex: five dollars). Recipients who fail to respond to the initial 

survey solicitation will receive a second cash incentive (ex: another five dollars). This incentive 

strategy is identical to that used by the National Survey of Mortgage Borrowers, and the Bureau 

expects to use this same strategy for the planned Survey of Consumer Views on Debt.
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Meta-analyses of mail surveys find that incentives given initially with the questionnaire 

yield significantly higher response rates than do incentives contingent on return of the survey or 

no incentives; furthermore, monetary incentives produce a stronger effect than non-monetary 

incentives.3,4 Many recurring federally-funded surveys use monetary incentives, including the 

Survey of Consumer Finances, the Survey of Income and Program Participation, and the 

National Survey of Drug Use and Health, and self-administered surveys such as the Survey of 

Doctorate Recipients, the National Survey of Recent College Graduates, and the National Survey 

of Mortgage Borrowers.5 Incentives have consistently been found to improve response rates 

across a variety of survey topics and modes.6,7

 Incentives have been found to be cost-effective in 

different modes and often reduce the effort required to contact and interview sample persons or 

the number of follow-up mailings.8,9,10

10. Assurances of Confidentiality

CFPB shall treat the information in accordance with applicable federal law, including, but 

not limited to, the Bureau’s confidentiality rules, 12 C.F.R. Part 1070, and the federal laws and 

regulations that apply to federal agencies for the protection of privacy, confidentiality, security 

and integrity. 

The CFPB uses best practices of social science research design to inform the notice and 

consent vehicles. For research studies under this generic clearance, the CFPB provides notice to 

individuals that explain how their information will be used through Privacy Act Statements. 

Privacy Act Statements are made available prior to the collection of information and explain 

 3 Allan H. Church (1993), “Estimating the Effects of Incentives on Mail Survey Response Rates: A Meta-Analysis.” 

Public Opinion Quarterly, 57(1): 62-79 4 Phil Edwards et al. (2002), “Increasing Response Rates to Postal Questionnaires: Systematic Review.” British 

Medical Journal, 324: 1183-1189. 5 Fan Zhang (2010), “Incentive Experiments: NSF Experiences.” NSF Working Paper. 6 Eleanor Singer (2002), “The Use of Incentives to Reduce Nonresponse in Household Surveys.” In R.M. Groves, 

D.A. Dillman, J.L. Eltinge, and R.J.A. Little (eds), Survey Nonresponse. New York: Wiley, pp 163-177. 7 Eleanor Singer, Cong Ye (2013), “The Use and Effects of Incentives in Surveys.” The Annals of the American 

Academy of Political and Social Science, 645 8 Martha Berlin et al. (1992), “An Experiment in Monetary Incentives.” Proceedings of Survey Research Methods 

Section, American Statistical Association, pp. 393-398. 9 Eleanor Singer et al. (2000), “Experiments with Incentives in Telephone Surveys.” Public Opinion Quarterly,

64(2): 171-188. 10 Gwen L. Alexander et al. (2008), “Effects of Incentives and Mailing Features on Recruitment for an Online 

Health Program.” American Journal of Preventative Medicine, 34(5): 382-388.
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whether the information is mandatory or voluntary; the authority for the information collection; 

whether there are any opportunities to consent to sharing and submission of information; how the 

information will be secured and what System of Records applies. 

The information collected under this generic clearance by contractors will include direct 

identifying personally identifiable information (PII) in order to contact survey participants and 

match the survey data to administrative records. The CFPB will only receive and keep response 

data stripped of direct identifying PII. 

Conducting these research studies implicates privacy concerns because a breach of 

confidentiality, or re-identification, could result in an individual suffering harm. To reduce the 

risk of breaches of confidentiality, the CFPB designs recruitment materials so as not to disclose 

sensitive information about those it seeks to recruit, and uses appropriate security controls to 

protect information used in research. There is also risk related to misuse of information collected 

for research. Misuse might involve secondary types of research that are incompatible with the 

purposes of the initial collection, or a use of the information that individuals do not understand or 

to which they have not provided consent.

To reduce the risk of misuse, the CFPB minimizes access to PII based on need-to-know and 

stipulates, in most instances, that contractors that collect data on behalf of the Bureau remove or 

redact all direct identifying PII, as defined by the Bureau’s privacy office, before transmitting 

data to the Bureau. Any contractor staff assigned to the project also sign confidentiality 

agreements. When appropriate, research results will be presented in aggregated form to protect 

the confidentiality of firms or consumers, and any publicly released version of data will use 

disclosure protection techniques (e.g., rounding, imputation, exclusion of some variables, 

aggregation of categorical responses) to minimize the risk of releasing personally identifiable or 

otherwise sensitive information (12 CFR 1070.40 et seq.). The Bureau treats the information 

collected from participating persons and institutions in a manner consistent with our 

confidentiality regulations, and all data and analyses are subject to legal and privacy review prior 

to their release. 

The Bureau also evaluates the potential privacy risk and harm to individuals of specific 

research relative to that authorized purpose, and vets research proposals to ensure that they serve 

an authorized purpose. Research conducted under this generic clearance will be consistent with 
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the Privacy Act and the E-Government Act. The requisite SORNs and PIAs will document the 

collection, use, disclosure, and retention of PII; the technical, administrative, and physical 

controls used to minimize privacy risks. The CFPB.022 Market and Consumer Research 

Records, 77 FR 67802 System of Records Notice, and the Market Analysis of Administrative 

Data under Research Authorities PIA cover the use of administrative data and the matching 

required to contact potential survey respondents. The Consumer Experience Research PIA covers 

the collection of survey responses. The SORNs and PIAs will be updated as appropriate, and 

details regarding information handling will be specified in individual submissions under this 

generic clearance.

11. Justification for Sensitive Questions

Questions about an individual’s finances, for example, monthly income or mortgage 

payments, are commonly considered sensitive. Nonetheless, the CFPB must ask these questions 

in order to understand consumer behavior and to recognize financial trends and emergent risks 

relevant to consumers. The Bureau believes that these questions are justified by their central 

importance to the Bureau’s mission.

In addition, some people may believe that questions about race and other socioeconomic 

factors may be considered sensitive. However, the CFPB is mandated to enforce fair lending 

laws and focus on the risks to vulnerable populations, including service members and older 

Americans. For this reason, the Bureau often needs to ask these types of sensitive questions. For 

information collections involving questions of race/ethnicity, the CFPB will ensure that the 

OMB standards for Classification of Federal Data on Race and Ethnicity (Federal Register, 

October 30, 1997, Volume 62, Number 210, pages 58781-59790) are followed.

Respondent participation will be voluntary for each survey distributed under this generic 

clearance; subjects will be made aware of this fact. All respondents shall be free to opt-out of a 

data collection at any time and for any reason. Administrative data for the respondents and nonrespondents will be used to analyze nonresponse bias.

The CFPB will ensure that a citation is made to any applicable System of Records Notice 

(SORN) for the collection of direct identifying information, and that a Privacy Impact 

Assessment (PIA) is published.
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12. Estimated Burden of Information Collection

Exhibit 1: Burden Hour Summary 

Information 

Collection 

No. of 

Respondents

Frequency Annual 

Responses

Average 

Response Time

Annual 

Burden 

Hours

Surveys 8,500 1 8,500 .5 hours 4,250

3 Year Total: 25,500 /////////////// 25,500 /////////////// 12,750

The CFPB plans to mail surveys to up to 25,000 consumers per year under this generic 

clearance and estimates an average response rate of 34 percent. For the estimated 8,500 

respondents per year who fill out the survey, we estimate that completing a survey will take 30 

minutes on average, for a total burden of 4,250 hours per year. 

13. Estimated Total Annual Cost Burden to Respondents or Recordkeepers

There are no capital/start-up or ongoing operation/maintenance costs associated with this 

information collection. Postage costs to return the survey questionnaire will be pre-paid by the 

survey contractor.

14. Estimated Cost to the Federal Government

The costs of each individual survey distributed under this generic clearance will vary 

based on the number individuals surveyed and the size of any payments made to incentivize 

participation. We expect the cost of each survey to range from $250,000 to $600,000.

15. Program Changes or Adjustments

This is a new information collection request; therefore, all the burden (see item 12) is 

considered a program change.

16. Plans for Tabulation, Statistical Analysis, and Publication

All survey responses gathered under this generic clearance will be tabulated and analyzed 

once received. Generally, data collection will take at least two to three months. Once the data have 
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been received, we expect data tabulation and preliminary data analyses to last another four to five 

months normally. We expect the analysis will include providing descriptive statistics for those 

variables of primary interest in a given survey, which may include statistics for which there are 

currently no reliable estimates. These and any other analysis would incorporate nonresponseadjusted sample weights. We also expect to produce cross-tabulations of these key measures by, 

for example, demographic characteristics. The tabulations and analytical results will be 

published as technical articles that will be publically disseminated as working papers, published 

in peer-reviewed journals, or published as CFPB white papers. If any survey data are publicly 

released, the data release will generally follow the publication of documents presenting the 

results of their analysis.

17. Display of Expiration Date

The Bureau plans to display the expiration date for OMB approval of the information 

collection on all instruments. Further, the OMB control number and expiration date will be 

displayed on the Federal government’s electronic PRA docket at www.reginfo.gov.

18. Exceptions to the Certification Requirement

The Bureau certifies that 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.