Page 1 of 13 CONSUMER FINANCIAL PROTECTION BUREAU INFORMATION COLLECTION REQUEST

– SUPPORTING STATEMENT PART A DEVELOPMENT OF METRICS TO MEASURE FINANCIAL WELL

- BEING OF WORKING

- AGE AND OLDER AMERICAN CONSUMERS (OMB CONTROL NUMBER: 3170

- XXXX)

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

ABSTRACT: Under the Dodd

- Frank Wall Street Reform and Consumer Protection Act, Public Law No. 111

- 203, the Bureau’s Office of Financial Education (“OFE”) is responsible for developing and implementing a strategy to improve the financial literacy of consumers that in cludes measurable goals and initiatives, in consultation with the Financial Literacy and Education Commission, consistent with the National Strategy for Financial Literacy. In addition, the Office of Financial Protection for Older Americans (OA) within th e CFPB is charged with conducting research to identify methods and strategies to educate and counsel seniors, and developing goals for programs that provide seniors with financial literacy and counseling.

The CFPB intends to collect quantitative data through surveys with working

- age (age 18

- 61) and older American (age 62 and older) consumers in order to develop and refine survey instruments that will enable the CFPB to reliably and accurately measure adult consumers’ finan cial well

being. The primary anticipated data collection strategy is through internet

- based surveys. The core objective of the data collection is to iteratively test, refine, and produce valid and reliable measures of consumer financial well

- being that wi ll create a strong, standardized basis for setting measurable goals, and evaluating financial education strategies and programs.

A. JUSTIFICATION

1. Circumstances Necessitating the Data Collection

The Dodd

- Frank Wall Street Reform and Consumer Protecti on Act of 2010 (Pub. L. 111

- 203) (“the Dodd

- Frank Act” or “the Act”) requires the Consumer Financial Protection Bureau (CFPB) to regulate the offering and provision of consumer products or services under Federal consumer financial law. The Act also establ ished the Office of Financial Education (OFE) within the CFPB, which is responsible for developing and implementing a strategy to improve the financial literacy of consumers that includes measurable goals and objectives, in consultation with the Financial Literacy and Education Commission (FLEC) 1 , and, together with the CFPB’s Office of

1 The Financial Literacy and Education Commission was established under the Fair and Accurate Credit Transactions Act of 2003. The Commission was tasked to develop a national strategy on financial education. It is chaired by the Secretary of the Treasury, vice

- chaired by the Director of the CFPB, and made up of the heads of 20Page 2 of 13 Research, for conducting research related to financial education and counseling. In addition, the Act established the Office of Financial Protection for Older Americans (OA) within the CFPB, which is charged with conducting research to identify methods and strategies to educate and counsel seniors, and developing goals for programs that provide seniors with financial literacy and counseling.

There are at least three challenges in formulating and setting measurable goals for effective financial education initiatives. First, there is inadequate evidence regarding which financial education strategies are most effective. According to a June 2011 Government Accountabilit y Office (GAO) report on financial literacy, “relatively few evidence

- based evaluations of financial literacy programs have been conducted, limiting what is known about which specific methods and strategies are most effective. 2 ” Second, there are no standard or rigorously tested measures of consumer financial knowledge, behavior, or well

- being outcomes that can provide a gauge to measure the effectiveness of financial education or capability programs, products, or services. FLEC’s Research & Evaluati on Working Group has identified the development of “‘key metrics’ for financial education/capability, including measures of knowledge, behaviors, and well

- being” as one of its top priority areas for research. 3 Third, there is limited evidence of the preci se role financial knowledge plays in improving financial decisions and financial well

being and whether it is relatively more important in this respect than, for example, numeracy, patience, cognitive abilities or social aspects of financial choices and fi nancial behavior.

In order to help the CFPB, other FLEC agencies, and the broader financial education field develop and support strategies and programs that lead to better financial outcomes for American consumers, the CFPB is engaging in a major researc h project (“this Project” or “the Project”) focused on making significant progress toward learning:

1. What knowledge and behavior predict financial well

- being; 2. What the importance of financial knowledge is relative to other factors (personal traits and soc ial context) in improving financial well

- being; and, 3. How to effectively measure key financial knowledge, behavior, and well

- being concepts.

The products of this Project should allow the CFPB, other FLEC agencies, and the broader financial education field to develop well

- informed approaches to improving consumer financial well

- being. Further, by creating or vetting rigorously developed metrics (measures) of consumer financial knowledge, behavior, well

- being, and related factors, the Project will create a st rong basis for evaluating financial education policies and programs. More specifically, these metrics should significantly increase the ability of the CFPB, other FLEC agencies, and private

additional federal agencies.
2 U.S. Government Accountability Office, GAO

- 11

- 614, Financial Literacy: A Federal Certification Process for Providers Would Pose Challenge s (June 28, 201 1), available at http://www.gao.gov/assets/330/320203.pdf.
3 Financial Literacy and Education Commission, 2012 Research Priorities and Research Question , available at http://www.treasury.gov/resource

- center/financial

- education/Documents/2012%20Research%2 0Priorities%20

- %20May%2012.pdfPage 3 of 13 researchers to undertake a wide range of program and policy effec tiveness testing to determine which approaches make the biggest difference in consumer outcomes.

This Project is anticipated to encompass three phases of data collection:

(1) Qualitative research to inform separate definitions of financial well

- being for both working

- age and older Americans, and the development of clear hypotheses regarding the drivers of financial well

- being. In addition, the qualitative research will inform the wording of survey items to test these hypotheses. (2) Rigorous development, testin g, and refinement of survey items to measure the constructs (variables) hypothesized in phase one to relate to financial well

- being. (3) A quantitative test of the hypotheses developed in phase one, using survey items developed during phase two.

The informat ion collected through these processes will increase the CFPB’s understanding of consumers’ financial experiences and outcomes and therefore what type of financial education and empowerment programs and practices may improve financial decision

- making skills and outcomes for consumers.

The Office of Management and Budget (OMB) has previously approved information collection for phase one, the qualitative research to inform hypotheses about financial well

- being and the wording of survey items to test these hypo theses , which has been completed . Through this new Information Collection Request, “Development of Metrics to Measure Financial Well

- being of Working

- Age and Older American Consumers,” the CFPB seeks approval to conduct the second phase of this project: ri gorous development, testing, and refinement of survey items to measure the constructs (variables) hypothesized in phase one to relate to financial well

- being.

2. Use of the Information

In order to conduct survey research in support of financial well

- being metrics development, t he CFPB has contracted with the Corporation fo r Enterprise Development (CFED). CFED, in turn, has subcontracted with the Center for Financial Security at the University of Wisconsin

- Madison (CFS) and Vector Psychometrics Group (VPG), to field three rounds of surveys . CFED and its subcontractors will work with Survey Sampling International (SSI) to coordinate fielding of the survey and survey question refinement after each phase has been completed.

Of the a pproximately 16,500 surveys that will be completed by a sample of Americans ages 18 and over resembling the larger US population :

 15,000 surveys will be fielded online in two rounds by Survey Sampling International. SSI will then field a third round of 1,500 surveys using mixed presentation modes (online, telephone and pencil

- paper) ;  1 1,500 surveys will be completed by working

- age Americans (ages 18

- 61) and 5,000 will be completed by older Americans (age 62 and older)

.Page 4 of 13 Survey Sampling International ( SSI ) will recruit two online samples: one that includes working age Americans between the ages of 18 and 61 and another that includes Americans ages 62 and older. Both of these samples will resemble the US population as a whole in terms of their income, education, employment status, marital status, age, gender

, race/ethnicity , presence/ages of children, and geography

. Working

- Age American S amples

SSI will administer three rounds of surveys to working

- age Americans . No respondent will be asked to take more than one survey. The first round will consist of 7,000 completed online surveys. The second round will consist of 3,000 completed online surveys. The third round will consist of 1,500 surveys: approximately 500 completed online, 500 completed over the phone and 500 completed using a pencil

- paper questionnaire. The objective of the third survey round is to compare responses to individual questions across methods o f administration and to further refine survey questions for the final instruments . It is not necessary for the third round survey sample to closely resemble the US population as a whole because psychometric analysis will focus on response differences by de livery mode as opposed to socio

- demographic characteristics

.

Older Americans S amples

SSI will administer two rounds of surveys to older Americans . No respondent will be asked to take more than one survey. The first round will consist of 2,000 completed online surveys . The second round will consist of 3,000 completed online surveys.

Information to be Collected

Each iteration of the survey will include questions on demographics of respondents, including their gender, race/ethnicity, marital s tatus, employment status, education status, income level, dependent status (whether they have children or are someone else’s dependent), and general geographic region (urban, suburban, or rural). If SSI already has this information from
resp ondents and it is up to date, SSI will not include these questions in the survey. No personally identifiable information will be collected. In addition to demographic information, each iteration of the survey will ask questions in the following types of conceptual areas :

• financial well

- being ;

• financial and general knowledge;

• financial behaviors and decisions;

• personality traits; and

• social context.

The goal of these surveys is to de velop a final set of items (question and answer sets) to measure each concept. These items should be easily comprehended by the average American consumer and should provide a statistically reliable measure of each concept. To achieve this goal, an iterative process is used with continuous refinement of the wording of each item , as well as a weeding out of poor or irrelevant items. Individual question and answer sets may change eachPage 5 of 13 time the survey is fielded based on the analysis of the results of the previous survey. In its simplest form, the process can be described as follows:

Step 1 : Generate a large pool of candidate survey items (see Survey Question Item Bank

, attached as Appendix A ) based on a literature review and qua litative research undertaken in a previous phase of the project

. Step 2: Revise the candidate survey items with the panel of experts associated with the project in order to refine item wording and weed out poor questions

. Step 3: Field the first round of the survey online to test the items and use psychometric techniques to analyze the items’ performance. Pr omising questions will be retained and poor performing questions will be weeded out.

Step 4: Field the second round of the survey online with the revised items to refine and validate the work from round one using additional psychometric techniques (e.g. , confirmatory factor analysis and item response theory

- based methods ), leading to recommended measures for the selected concepts (e.g., financial well

- being, financial knowledge)

. Step 5: Field a third, final round of the survey in order to test its reli ability and validity when administered over

- the

- phone and as a pencil

- and

- paper test.
Each round of survey data will be used to assess whether the majority of respondents comprehended the question s and to determine if the question responses fell within the expected
range. Psychometric analysis will reveal whether survey items are statistically valid and reliable measures of the key concepts (e.g., financial well

- being).

No population inferences will be made using this data.

3. Use of Information Technology

The contractor will collect data electronically through the use of online survey software . Such software will help reduce errors by:

• a utomatically skipping questions, where appropriate, based on prior answers to questions;

• r andomizing how certain questions, or groups of questions, are presented (e.g., asking certain consumers about financial behaviors before asking about financial well

- being and asking about financial well

- being before asking about financial behaviors ) to mit igate the effects of potential biases caused by the order the questions are presented;

• e nsuring that some questions cannot be skipped; and.

• r ejecting invalid responses or data entries

. Additionally, the contractor can collect data on the length of time re spondents spent answering the survey and unit and item non

- response rates. This type of information can be used to improve the question and answer sets

.Page 6 of 13 4. Efforts to Identify Duplication

The CFPB is not aware of any similar data collection efforts aimed at testing the accuracy, statistical reliability, and respondent comprehension of candidate survey question and answer sets intended to measure financial well

- being and its key drivers.

Prior to initia l development of this survey, the contractor conducted an extensive review of academic literature and prior surveys intending to measure individuals’ financial knowledge 4

, behavior 5 , and overall financial capability 6 . While these prior studies refer to the concept of financial well

- being, they neither rigorously defined the concept nor provided metrics for its
measurement

. Many studies in the consumer science literature have focused heavily on explicit financial knowledge or numeracy : e.g. asking respondents to identify the correct answer when presented with financial word problems on topics such as compound interest or inflation. 7 A review of the broader literature on knowledge and well

- being related behaviors in the education, psychology and hea lth fields conducted as a part of this study suggests, however, that consumers’ knowledge of financial facts likely is not the sole relevant predictor of their financial well

- being

.

4 See Allgood, Sam, and William Walstad. 2011. “The Effects of Perceived and Actual Financial Knowledge on Credit Card Behavior.” Networks Financial Institute Working Paper 15. Indianapolis, Indiana: Networks Financial Inst itute. ; Atkinson, Adele, and Flore

- Anne Messy. 2012. “Measuring Financial Literacy: Results of the OECD / International Network on Financial Education (INFE) Pilot Study.” Finance, Insurance and Private Pensions Working Paper 15. Washington, D.C.: Organiz ation for Economic Cooperation and Development. ; Gerardi, Kristopher, Lorenz Goett, and Stephen Meier. 2010. “Financial Literacy and Subprime Mortgage Delinquency: Evidence from a Survey Matched to Administrative Data.” Atlanta Federal Reserve Bank Working Paper 2010

- 10. Atlanta, GA: Federal Reserve Bank of Atlanta. ; Knoll, Melissa A.Z., and Carrie R. Houts. 2012. “The Financial Knowledge Scale: An Application of Item Response Theory to the Assessment of Financial Literacy.” Journal of Consumer Affairs 46(3 ), 381

- 410. ; Hilgert, Marianne A., Jeanne M. Hogarth, and Beverly, Sondra G,. 2003. “Household Financial Management: The Connection between Knowledge and Behavior.” Federal Reserve Bulletin 89: 309

- 322. ; Lusardi, Annamaria, and Olivia S. Mitchell. 2009. “ How ordinary consumers make complex economic decisions: Financial literacy and retirement readiness.” National Bureau of Economic Research Working Paper 15350. Cambridge, MA: National Bureau of Economic Research .; Van Rooij, Maarten, Annamaria Lusardi and Rob Alessie. 2011. “Financial literacy and stock market participation.” Journal of Financial Economics 101(1): 449

- 472

.

5 See Dew, Jeffery, and Jing Jian Xia. 2011. “The Financial Management Behavior Scale: Development and Validation.” Journal of Financial Counseling and Planning 22(1): 43

- 59. ; Hilgert, Marianne A., Jeanne M. Hogarth, and Beverly, Sondra G,. 2003. “Household Financial Management: The Connection between Knowledge and Behavior.” Federal Reserve Bulletin 89: 309

- 322. ; Lynch, John G., Richard G . Netemeyer, Stephen A. Spiller, and Alessandra Zammit. 2010. “A Generalizable Scale of Propensity to Plan: The Long and the Short of Planning for Time and Money.” Journal of Consumer Research 37(1): 108

- 128.

6 See Taylor, Mark. 2011. The Long Term Impacts of Financial Capability: Evidence from the BHPS. Colchester, Essex: The University of Essex. Consumer Financial Education Body Research Report 03. ; Shim, Soyeon, and Joyce Serido. 2011. Young Adults’ Financial Capability. Tuscan, AZ: University of Arizona. A Pathway to Life Success for University Students Research Brief Wave 2.

7 The best example of survey questions commonly used in other studies to measure financial literacy comes from Lusardi, Annamaria, and Olivia S. Mitchell. 2007. “Financial Li teracy and Retirement Preparedness: Evidence and Implications for Financial Education.” Business Economics 42(1): 35

- 44.Page 7 of 13 5. Efforts to Minimize Burdens on Small Entities

The data collection is not anticipated to burden small entities because the survey will only collect information from individuals

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

The CFPB would be less able to meet its obligation to develop measurable goals and objectives that support increasing the financial literacy of consumers , or to develop goals for programs that provide seniors with financial literacy and counseling , as s pecified by the Dodd

- Frank Act, without undertaking the proposed surveys to develop measures of financial well

- being

.

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), on August 8, 2013, the Bureau published a notice in the Federal Register allowing the public 60 days to comment on this proposed new collection of information (78 FR 48422 ) . Further and in accordance with 5 CFR 1320.5(a)(1)(iv), the Bureau has published 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. Payments or Gifts to Respondents

The incentives respondents will receive are based on their pre

- existing agreements with Survey Sampling International (SSI) and are not specific to this survey. Survey respondents will come from existing panels managed by SSI

. Agreements regarding incentive payments were established between SSI and the panelist at the time s/he was recruited. For example, when signing up for OpinionWorld , a panel administered by SSI, respondents can choose from a variety of incentives including donations to a preferred charity, entries into a drawing for a monetary prize

, etc. SSI offers a wide variety of incentives in order to increase diversity of its sample frames because dif ferent types of rewards will motivate different respondents to participate in a survey

. Rewards offered vary by survey length and the characteristics of the population being targeted. SSI uses a reasonable level of reward based on the amount of effort requ ired and subpopulation interests (iTunes credits are popular among younger panelists, for example)

. These levels in whatever currency was agreed for that particular respondent are set based on extensive research to balance motivation to respond and impact on the content of that response.

For the length of survey proposed in this collection, the typical dollar value of the incentivePage 8 of 13 ranges from $1.50 to $2.

10. Assurances of Confidentiality

An email or online invitation to participate in the survey (attached as Appendix B) will direct respondents to an informed consent statement (attached as Appendix C)

. This statement will tell respondents about the study’s purpose, that cooperation is voluntary, and that directly identifying information , such as name and email address, will not be provided to the CFPB or to any third party outside of SSI 8 (SSI’s privacy policy is attached as Appendix D). If they agree to the terms described in the informed consent statement , respondents will select the link prov ided to enter the survey.

The CFPB has specified in its contract with the data collection contractor CFED that the CFPB does not own and cannot receive personally identifiable information 9 in order to protect the privacy of respondent data and ensure the p ledges of privacy made to respondents by the CFED research team.

In addition, n o personally identifiable information will be stored in the data file or provided to the contractor. Survey Sampling International protects the identifying information on its panelists and does not share it with any agency or company conducting research with its panel. This means that neither the contractor nor the CFPB will be able to reference or disclose such personally identifiable information about the participants. The contractor and the CFPB will analyze data and report results only in the aggregate.

11. Justification for Sensitive Questions

Respondents will be asked to provide basic demographic and socio

- economic information including their race/ethnicity, income level, employment status, gender and age . This information will be used to ensure that the sample population resembles the larger national population and to complete an analysis of differences between consumers who did and did not respond. Respondents wil l also be asked questions about their current objective financial circumstance (e.g., debt, credit scores, wealth, retirement savings, etc.). This information will be used to assess economic or normative measures of financial well

- being (e.g., savings rel ative to
averages for the consumer’s age, income, etc.) in order to compare this information to scores on the new scales being developed to measure financial well

- being

.
12. Estimated Burden of Information Collection

The table below presents the burden h ours for the proposed survey, split up by type of respondent. The last phase, the implementation assessment, is expected to take less time than the first phases, so the table splits these respondents out.

8 SSI will not share any personally identifiable information with the research team. Rather, the research team (CFED and its subcont ractors) will only receive information on respondent demographics, along with their responses to the survey questions.
9 The contract language includes the following: “Contractor shall not provide CFPB any personally identifiable information that could re asonably be used to identify individuals participating in the project.”Page 9 of 13 Task Hours per Respondent Number of Respondents Burden hours per task Working

- Age Americans Survey Phases 1 & 2: Metric Development & Validation

- phone 17 minutes 10,000 2

, 833

Phase 3: Implementation Assessment

– online /telephone /paper 15 minutes 1, 500 375

Older Americans Survey Phases 1 & 2: Metric Development & Validation

- phone 17 minutes 5,000 1

, 41 7

Total Burden Hours: 4 , 625

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.

14. Estimated Cost to the Federal Government

There will be no annualized capital/start

- up costs for the government to receive the survey information. The testing is funded with non

- appropriated funds. It will cost approximately $80 0,000 to collect and analyze these data.

The Blanket Purchase Agreement, under which the survey will be conducted, was awarded through a competitive bidding process.

15. Program Changes or Adjustments

This is the first request for a new collection

.
16. P lans for Tabulation, Statistical Analysis, and Publication

Using responses from three distinct phases of data collection, the contractor will develop metrics to assess three constructs of interest (i.e., Financial Well

- being, Financial Knowledge, and Fina ncial Behavior) using modern psychometric methods (e.g., Netemeyer et al. 2003; Thissen and Wainer 2001; Wirth and Edwards 2007). A large pool of candidate items (questions and response sets) based on the finding from qualitative research, the project literature review, and a review of other financially related surveys will be developed (see attached Item Bank document for an initial pool of questions on all anticipated topics) . A panel of psychometric and content experts will review and refine the pool of candidate items so that the remaining items are targeted and well

- worded. No more than 100 items will be included in the refined item pool. This number of items is specified to ensure that respondents are not overly burdened when responding to the item pool.Page 10 of 13 In phase I, SSI will field the candidate items online to approximately 7,000 working

- age and 2,000 older Americans. Following any necessary data cleaning, preliminary data analyses, by age group, will then be conducted to examine the variables individually and in pairs to see if any response patterns need to be addressed before the next steps in data analysis . These will include one and two

- way frequency tables for items and item pairs as well as a polychoric correlatio n matrix. Classical test theory analyses (e.g., Cronbach’s alpha, item

- total correlations, alpha if removed) for both individual items and the preliminary scales as a whole will also be conducted to see how well these items, individually and in groups, mea sure what we expect them to

measure . Structural assessments (exploratory and confirmatory factor analysis ) will be conducted to ensure that an appropriate number of dimensions are employed to model the relationships among the items for each construct, usin g analysis methods appropriate for the categorical nature of the data (Wirth and Edwards 2007). To ensure that preferred models are not over

- fit to the data, each sample will be randomly divided into two sub

- samples: one for exploratory modeling and the ot her for confirmatory modeling. Finally, item response theory (IRT) calibration analyses will be conducted within each age group for each construct individually using the preferred factor structure from the structural assessment results. Item parameter resu lts from the IRT calibration of each construct will be presented in tables and in the form of trace line plots/item characteristic curves (ICCs) for each item. An ICC for a given item represents the probability of endorsing an item as a function of an indi vidual’s level on the underlying construct.

Using the IRT calibration results and expert opinion, the candidate items used in phase I will be

re

- evaluated. Items that are performing poorly will be eliminated from further use. An examination of the remain ing items will be conducted to determine any content areas that are not well

- represented or areas on the construct continuum (e.g., ranges along the spectrum from low financial well

- being to high financial well

- being) that are not well

- measured. Item devel opment will be conducted to create items intended to fill any identified gaps

. Using the items that performed well in phase I and the newly developed items, new iterations of the 3 financially

- related metrics (well

- being, knowledge, and behavior) will b e created. The second round of online surveys (phase II) will be fielded to 3,000 working

- age and 3,000 older Americans. Analyses will follow the same structure as outlined previously. As a final step, it is currently planned that analyses will be conducte d to assess if the performance of items differs across the two age groups, working

- age and older Americans. However, for these differential item functioning (DIF) analyses to be conducted, it is necessary that there is a sufficient amount of overlap across age

- groups, with respect to the well

- performing items. A feasibility review will be conducted to determine, for each construct, if the overlap of items across age groups is sufficient to allow for comprehensive DIF testing across the age groups . At the en d of Phase II, the IRT calibration and DIF results, if available, as well as expert opinion will inform the selection of items to the final versions of the metrics for each construct.

The final set of analyses is planned for the third phase of data collec tion, which will contain responses from 1500 working

- age Americans and use three different modes of item presentation:

o nline, p hone, and p aper

- and

- p encil. Structural and IRT analyses will be performed, individually for each presentation mode. Next, DIF a nalyses will be conducted to identify anyPage 11 of 13 item performance changes across the three presentation modes. Items with poor or inconsistent performance across modes are candidates for removal. Finally, targeted correlational and regression analyses will be con ducted to examine the relationships among the 3 financial constructs and other theoretical drivers; the analyses conducted at this point are pre

- determined by the hypotheses regarding the drivers of financial well

- being that were developed during the quali tative phase of scale development.

The CFPB anticipates t hat the survey (all three rounds for working age and two rounds for older Americans ) will be completed within five months of OMB approval. The contractor will develop the initial analysis and summary of the study findings after data collection has been completed. This is to be completed within the four months after data has been collected. The CFPB may choose to publ ish the research findings.

17. Display of Expiration Date

The CFPB plans to display the expiration date for OMB approval of the information collection on all instruments.

18. Exceptions to the Certification Requirement

The Bureau certifies that this coll ection 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.

Bibliography

Allgood, Sam, and William Walstad. 2011. “The Effects of Perceived and Actual Financial Knowledge on Credit Card Behavior.” Networks Financial Institute Working Paper 15. Indianapolis, Indiana: Networks Financial Institute.

Atkinson, Adele, and Flore

- Anne Messy. 2012. “Measuring Financial Literacy: Results of the OECD / International Network on Financial Education (INFE) Pilot Study.” Finance, Insurance and Private Pensions Working Paper 15. Washington, D.C.: Organization for Economic Cooperation and Development.

Cortina, Jose M. 1993. “Interaction , Nonlinearity, and Multicollinearity: Implications for Multiple Regression.” Journal of Management 19 (4): 915

- 922.

Dew, Jeffery, and Jing Jian Xia. 2011. “The Financial Management Behavior Scale: Development and Validation.” Journal of Financial Counsel ing and Planning 22(1): 43

- 59.

FLEC. Financial Literacy and Education Commission Research and Evaluation Working Group. 2012. “2012 Research Priorities and Research Questions.” http://www.treasury.gov/resource

center/financial

- education/Documents/2012%20Research%20Priorities%20

- %20May%2012.pdf

GAO Highlights. 2011. “Financial Literacy: A Federal Certification Process for Pr oviders WouldPage 12 of 13 Pose Challenges.” GAO

- 11

- 614 http://www.gao.gov/assets/330/320203.pdf

Gerardi, Kristopher, Lorenz Goett, and Stephen Meier. 2010. “Financial Literacy and Subprime Mortgage Delinquency: Evidence from a Survey Matched to Administrative Data.” Atlanta Federal Reserve Bank Working Paper 2010

- 10. Atlanta, GA: Federal Reserve Bank of Atlanta.

Knoll, Melissa A.Z., and Carrie R. Houts. 2012. “The Financial Knowledge Scale: An Application of It em Response Theory to the Assessment of Financial Literacy.” Journal of Consumer Affairs 46(3) : 381

- 410.

Hilgert, Marianne A., Jeanne M. Hogarth, and Beverly, Sondra G,. 2003. “Household Financial Management: The Connection between Knowledge and Behavior.” Federal Reserve Bulletin 89: 309

- 322.

Lusardi, Annamaria, and Olivia S. Mitchell. 2009. “How ordinary consumers make complex economic decisions: Financial literacy and retirement readiness.” National Bureau of Economic Research Working Paper 15 350. Cambridge, MA: National Bureau of Economic Research.

Lusardi, Annamaria, and Olivia S. Mitchell. 2007. “Financial Literacy and Retirement Preparedness: Evidence and Implications for Financial Education.” Business Economics 42(1): 35

- 44.

Lynch, John G., Richard G. Netemeyer, Stephen A. Spiller, and Alessandra Zammit. 2010. “A Generalizable Scale of Propensity to Plan: The Long and the Short of Planning for Time and Money.” Journal of Consumer Research 37(1): 108

- 128.

Netemeyer, Richard G., William O. Bearden, and Subhash Sharma. 2003. Scaling Procedures: Issues and Applications . Thousand Oaks, CA: Sage Publications

.

Shim, Soyeon, and Joyce Serido. 2011. Young Adults’ Financial Capability. Tuscan, AZ: University of Arizona. A Pathway to Life Success for University Students Research Brief Wave 2.
Taylor, Mark. 2011. The Long Term Impacts of Financial Capability: Evidence from the BHPS. Colchester, Essex: The University of Essex. Consumer Financial Education Body Research Report 03.

Thissen, David, and Howard Wainer (Eds.). 2001. Test Scoring . Mahwah, NJ: Lawrence Erlbaum Associates.

Van Rooij, Maarten, Annamaria Lusardi and Rob Alessie. 2011. “Financial literacy and stock market participation.” Journal of Financial Economics 101(1): 449

- 472

. Wirth, R. J., & Michael C. Edwards. 2007.”Item factor analysis: Current approaches and futurePage 13 of 13 directions.” Psychological Methods 12: 58

- 79.

Attachments

• Supporting Statement Part B

• Appendix A

– Su r vey Question Item Bank

• Appendix B

– Survey Invitations

• Appendix C

– Informed Consent and Link to Enter Survey

• Appendix D

– SSI Privacy Policy