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BUREAU OF CONSUMER FINANCIAL PROTECTION

PAPERWORK REDUCTION ACT SUBMISSION

INFORMATION COLLECTION REQUEST

SUPPORTING STATEMENT PART A

Generic Information Collection Plan to Conduct Cognitive Research and Pilot Testing

(OMB CONTROL NUMBER: 3170-XXXX)

OMB TERMS OF CLEARANCE: None

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 developments in markets for consumer 

financial products and services, consumer awareness, and consumer behavior. In order to 

improve its understanding of how consumers engage with financial markets, the CFPB seeks to 

obtain approval for a generic information collection plan to conduct research to improve the 

quality of data collection by examining the effectiveness of data-collection procedures and 

processes, including potential psychological and cognitive issues.

A. JUSTIFICATION

1. Circumstances Necessitating the Data Collection

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 

emerging risks in consumer financial markets.2 Section 1013(b)(1) of the Dodd-Frank Act 

 1 CFPB FY 2013 – FY 2017 Strategic Plan, goal 3, http://www.consumerfinance.gov/strategic-plan/ 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)
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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 Act also established 

the Office of Financial Education (OFE) within the CFPB, which is responsible for developing 

and implementing initiatives intended to educate and empower consumers to make betterinformed financial decisions, and, together with the CFPB’s Office of Research, for conducting 

research related to financial education and counseling. Using empirical evidence and rigorous 

research, the Bureau improves its understanding of consumer financial markets and is able to 

provide accurate and comprehensive information to consumers, firms, researchers, and 

policymakers. 

The CFPB supports this mission by building an understanding of the markets that it regulates 

and the nature of consumer behavior within these markets. For this reason, the Office of 

Research plans to obtain several generic clearances for “research” functions (outside of 

rulemaking), to improve our scientific understanding. 

The purpose of this generic clearance is to improve and- refine data collection procedures by 

testing specific aspects of methods and procedures such as questionnaire design. For research 

projects like surveys and controlled trials in field and economic laboratory settings, it is 

generally best practice in the social sciences to rigorously pretest instruments or interventions

prior to the full data collection. Pretesting methods will allow the CFPB to develop, test, and 

improve its survey and data collection instruments and methodologies, for example: evaluating 

questionnaires/assessments and various data collection procedures; developing survey scales;

identifying questionnaire/assessment and procedural problems; suggesting solutions; and 

measuring the relative effectiveness of alternative solutions.

Common pretesting methods include: pilot testing, behavior coding, interviewer debriefing, 

exploratory interviews, respondent debriefing questionnaire, follow-up interviews or reinterviews, split sample experiments, cognitive and usability interviews, and focus groups.

 

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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Below are detailed explanations of each method, which may be used in combination for a single 

research project.

Pilot testing. For the purposes of this clearance, we are defining pilot tests as data 

collection efforts to evaluate, for example, data collection-instruments, materials, and 

procedures on a reduced scale before conducting a full-scale data collection. Pilot tests 

are an essential component of this clearance package because they serve as the vehicle for 

investigating basic item properties for new or redesigned data collection efforts, such as 

reliability, validity, and difficulty, as well as feasibility of methods for standardized 

administration of forms. If the methodology appears sound, pilot data may be used to 

augment data collected during the full research project.

Behavior coding. This method involves applying a standardized coding scheme to the 

completion of an interview or questionnaire, either by a coder using a tape-recording of 

the interview or by an in-person observer at the time of the interview. The coding scheme 

is designed to identify situations that occur during the interview that reflect problems 

with the questionnaire. For example, if respondents frequently interrupt the interviewer 

before the question is completed, the question may be too long. If respondents frequently 

give inadequate answers, this suggests the question is unclear. Quantitative data derived 

from this type of standardized coding scheme can provide valuable information to 

identify problem areas in a questionnaire, and can be used as a substitute for or as a 

complement to the traditional interviewer debriefing.

Interviewer debriefing. This method employs the knowledge of the employees who have 

the closest contact with the potential respondents. In conjunction with other methods, we 

plan to use this method to collect information about how interviewers react to the survey 

instruments and laboratory or field experimental procedures; to understand problems and 

pitfalls encountered by interviewers during the interview; and to learn from interviewers 

about respondents’ reactions in the field.
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Exploratory interviews. These may be conducted with individuals who are experts to 

understand a topical area and may be used in the very early stages of developing a new

procedure. For example, experts may be from relevant industries or leading researchers 

who study the issues at hand. It may cover discussions related to administrative records 

(e.g. what types of records, where, and in what format), subject matter, definitions, etc.

Exploratory interviews may also be used to investigate whether sufficient issues are 

present related to an existing data collection to consider a redesign.

Respondent debriefing questionnaire. In this method, standardized debriefing 

questionnaires are administered to respondents who have participated in a field test, 

laboratory study, or completed a survey that is being tested. The debriefing form is 

administered at the end of the questionnaire being tested, and contains questions that 

probe to determine how respondents interpret the questions and whether they have 

problems completing the questionnaire or procedure. For example, this structured 

approach to debriefing enables quantitative analysis of data from a sample of respondents

in order to learn whether respondents can answer the survey questions, and whether they 

interpret them in the manner intended by the questionnaire designers.

Follow-up interviews or re-interviews. This involves re-interviewing or re-assessing a 

sample of respondents after the completion of a survey or assessment. Responses given in 

the re-interview are compared with the respondents’ initial responses to gauge

consistency between responses. In this way, re-interviews provide data for studies of test–

retest reliability and other measures of data quality. In turn, this information aids in the 

development of more reliable measures.

Split sample experiments. This involves testing alternative versions of questionnaires, 

and other collection methods. The alternatives may be designed to address problems 

identified in draft questionnaires or questionnaires from previous studies or to investigate 

methodological research questions. In the case of surveys, multiple questionnaires are 

developed and then randomly assigned to potential respondents, to permit statistical 

comparisons; data collection can include mail, telephone, Internet, or in-person 
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interviews or group sessions at which self-administered questionnaires are completed. 

Comparison of revised questionnaires against a control version or against each other 

facilitates statistical evaluation of the performance of alternative versions of the 

questionnaire. Split sample tests that incorporate questionnaire design experiments are 

likely to have a larger maximum sample size than field tests using other methodologies. 

Larger sample sizes will enable the detection of statistically significant differences and 

facilitate methodological experiments that can extend questionnaire design knowledge 

more generally for use in a variety of CFPB data collection instruments.

Cognitive and usability interviews. This method involves intensive, one-on-one 

interviews in which the respondent is typically asked to "think aloud" as he or she 

answers survey questions or participates in the experimental procedure and to answer 

follow-up questions about the survey or experimental procedure. A number of different 

techniques may be involved, including asking respondents to paraphrase questions or 

instructions, asking probing questions to determine how respondents came up with their 

answers or interpreted directions, and so on. The objective is to identify problems of 

ambiguity or misunderstanding, or other difficulties respondents have. This is frequently 

one of the early stages of revising study materials.

Focus groups. This method involves group sessions guided by a moderator, who follows 

a topical outline containing questions or topics focused on a particular issue, rather than 

adhering to a standardized questionnaire. Focus groups are useful for surfacing and 

exploring issues (e.g., confidentiality concerns).

This clearance is similar in intent and scope to the testing clearances held by the Census 

Bureau, the Bureau of Labor Statistics, the National Center for Education Statistics, and the 

National Science Foundation, that allowing these agencies to develop, redesign, and test data 

collection instruments and procedures in a timely manner.
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2. Use of the Information

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

generic information collection plan which would allow the Bureau to collect data through 

pretesting, for example, by testing various instruments or methodologies prior to the full 

collection. The aim of these pretests is to improve the Bureau’s data collection processes and 

improve the quality of the data in the studies that are ultimately conducted.

The CFPB generally plans to test survey instruments, laboratory methods, and field trials

on a small scale prior to their use in full-scale studies, e.g. through cognitive pretesting or by

conducting a subset of the surveys initially and reviewing the responses for evidence of problems 

before fielding the survey more widely. These methods can provide tools to improve 

questionnaires and other research instruments, for example, by testing comprehension of survey

and lab questions. Through this testing, questions can be tailored to increase the accuracy of the 

collected information and to reduce respondent burden by ensuring that large-scale information 

collection is optimized.

Research under this generic clearance is important in order to 1) improve the data 

collection instruments employed by the Bureau, 2) increase the accuracy of the data and, in turn,

of the research studies produced by the CFPB, including studies that may be factored into some 

policy decisions, 3) reduce the burden of completing or administering survey instruments for 

respondents and interviewers, 4) increase response rates in surveys, 5) increase the ease of use of 

the CFPB programs and products, and 6) enhance the CFPB’s reputation resulting in greater 

confidence and respect in study methods used by CFPB.

 

The information collected in this generic clearance will be used by the CFPB to evaluate 

and improve the quality of instruments or interventions before full-scale research projects are

conducted. In general, data collected under this clearance will not alone be used as official 

federal agency statistics. Data may be made public, when appropriate, in research reports,

presentations related to study methodology, at professional meetings, in publications on the 

CFPB website, and in professional journals.
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3. Use of Information Technology

The CFPB will employ information technology as appropriate to reduce the burden of 

respondents who agree to participate in its research. Computer-assisted participation will be used 

when feasible and appropriate, including online studies. In general, the Bureau intends to 

incorporate electronic data-collection techniques whenever possible, particularly since in many 

instances they are likely to impose the lowest burden on respondents and may be the most costeffective. However, the extent to which the Bureau will use electronic data collection for a given 

project will be determined by weighing several factors, including response rates and costs. For 

example, evidence to date suggests that web-only data collections tend to have lower response 

rates than surveys conducted by mail or phone.3 The Bureau expects that the most effective 

mode, including mixed-mode combinations, may also vary with the complexity and sensitivity of 

the information to be collected.

4. Efforts to Identify Duplication

The Bureau will explore methodological, psychological and cognitive methods-related 

issues in order to answer questions that are not satisfactorily addressed in the relevant research 

literature. A review of the existing relevant literature will be undertaken before proceeding with

projects. To the extent possible, the CFPB will make use of existing information, including 

information from previous studies. However, this information often is not sufficient to refine our

study questionnaires and assessments without conducting additional research.

5. Efforts to Minimize Burdens on Small Entities

All of our research projects will be limited to individual consumers, not businesses, so 

there will be no impact on small businesses or other small entities. 

 3 Roger Tourangeau, Fredrick Conrad, and Mick Couper (2013), “The Science of Web Surveys.” USA: Oxford 

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

The planned collection of data under this generic clearance will allow the CFPB to

improve larger scaled data collections before they are administered, reducing burden by 

increasing the effectiveness of the larger information collection. Failing to scientifically 

investigate the data collection process can lead to significant costs in terms of data quality and 

burden to respondents, interviewers, and data users alike during the final data collection and 

analysis of results. For example, poorly or confusing question that is not written clearly could 

unintentionally engender an incorrect response the lead to biased responses or to high rates of 

item nonresponse. 

7. Circumstances Requiring Special Information Collection

There are no special circumstances anticipated for the information collections under this 

generic clearance, they will be consistent with the applicable guidelines contained 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 Federal 

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

collection plan. Any comments received in response to this notice will be summarized, including

the Bureau’s response to those comments, in the submission to OMB. Further and in accordance 

with 5 CFR §1320.5(a)(1)(iv), the Bureau will also 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

Respondents for activities conducted in the laboratory (for example, cognitive interviews 

and focus groups) under this clearance will receive a small stipend. This practice has proven 

necessary and effective in recruiting subjects to participate in this small-scale research, and is 
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also employed by the other Federal cognitive laboratories. The incentive for participation in a 

cognitive interview is $40, and for participation in a focus group is $50-$75. The CFPB may 

provide smaller incentives than these amounts at its discretion; however, any requests for nonstandard amounts must be justified in writing to OMB. 

10. Assurances of Confidentiality

CFPB shall treat the information collected 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. When required and when practicable, the CFPB provides notice to 

individuals that explain how their information will be used through appropriate vehicles, 

such as Privacy Notices, Privacy Act Statements or Informed Consent forms. Such notice is 

typically made available prior to the collection of information and explains whether the 

information is mandatory or voluntary; whether there are any opportunities to consent to 

sharing and submission of information; how the information will be secured and when a 

System of Records is created under the Privacy Act. In some instances, research may be 

based on observations or on information collected directly from a third party, and notice and 

consent may not be applicable. 

When the CFPB collects information from third parties, commercial sources, and 

public databases, individuals to whom information may pertain do not have the opportunity 

to consent to uses, decline to provide information, or opt out directly to the Bureau. In such 

cases, it is those third parties’ responsibility to provide any opportunity that may be required 

to consent, decline, or opt out of how their information may be used. As part of the due 

diligence process, the CFPB reviews the privacy policies or other public disclosures from 

the third-parties regarding their use of the information to verify that there are no 
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contradictions with the research, and the CFPB encourages the development of notice and 

consent opportunities. In these instances, the Bureau will ensure that appropriate privacy 

provisions are included in contract language, Memorandum of Understanding (MOUs) and 

Statements of Work (SOW), as applicable. 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.

The information collected under this generic clearance may include direct identifying 

personally identifiable information (PII), depending on the type of project. Typically direct 

identifying PII consists of contact information used to facilitate administration of research, 

and is separated from response data generated from the research. When the CFPB does use 

direct identifying PII in analyses, it does so in order to a) match across datasets; b) update 

data sets; c) weight datasets in order to make generalizations regarding a given population; 

and d) contact potential recipients of our studies to solicit information on consumer 

experiences with consumer financial products and services.

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-toknow 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. In general, the CFPB will only keep response data 
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stripped of direct identifying PII. 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. Pretesting research will be conducted consistent with 

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 SORNs and PIAs will so be updated

to reflect any changes. The CFPB has two SORNs that will cover pretesting research: 

CFPB.021 Consumer Education and Engagement Records, 77 FR 60382; and CFPB.022 

Market and Consumer Research Records, 77 FR 67802. Specific details regarding 

information handling will be specified in individual submissions under this generic 

clearance, but will conform to these broad guidelines.

11. Justification for Sensitive Questions

Questions about an individual’s finances, for example, what their income is or how 

much their mortgage costs each month, are commonly considered sensitive. Nonetheless, 

the CFPB often 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.
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In addition, some people may consider questions about race and other demographic 

information to be sensitive. The CFPB is, however, mandated to enforce fair lending laws 

and to identify risks to vulnerable populations, including service members, older 

Americans, and lower-income consumers. For this reason, the Bureau often needs to ask 

these types of questions. For information collections involving questions of race or 

ethnicity, the CFPB will follow the OMB standards for Classification of Federal Data on 

Race and Ethnicity (Federal Register, October 30, 1997, Volume 62, Number 210, pages 

58781-59790).

Respondent participation will be voluntary for each survey, economic lab experiment, 

or other information collection distributed under this generic clearance, and participants

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. When possible, administrative data for the 

respondents and nonrespondents will be used to analyze nonresponse bias for information 

collections.

The CFPB will ensure that a citation is made to any applicable SORN and PIAs are 

published as appropriate.

12. Estimated Burden of Information Collection

For research projects like surveys and controlled trials in field and economic laboratory 

settings, the CFPB plans to rigorously pretest instruments or interventions prior to the full data 

collection. Currently the Bureau plans to conduct up to four surveys, three controlled trials in the 

field, and four controlled trials in the lab each year, and in many cases the Bureau will want to 

pretest components of each of these before conducting the full data collection. On average, 

pretesting of surveys will require 600 participants each year for 60 minutes each, while studies in 

field and lab contexts will require 50 and 20 participants, respectively, for an hour and a half

each. Therefore, estimated total burden hours under this generic clearance total 8,325. 
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Burden Hour Estimate for All Data Collections, 3-yr period

Types of Projects Subtotal

Pretesting for Surveys 7,200

Pretesting for Field Studies 360

Pretesting for Lab Studies 675

8,235

Burden Hour Estimate for Pretesting of Surveys, 3-yr period

Number of Projects

Number of 

Participants 

in a Project

Hours per 

Participant Subtotal

12 600 1 7,200

7,200

Burden Hour Estimate for Pretesting of Economic Studies in the Field, 

3-yr period

Number of Projects

Number of 

Participants 

in a Project

Hours per 

Participant Subtotal

9 50 1.5 675

675

Burden Hour Estimate for Pretesting of Economic Studies in the Lab, 

3-yr period

Number of Projects

Number of 

Participants 

in a Project

Hours per 

Participant Subtotal

12 20 1.5 360

360

There will be no financial burden on the respondents. For each specific collection request 

submitted under this generic plan, a detailed estimate of the burdens of that particular request 

will be submitted.

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. If there are postage costs to return a survey questionnaire, it will be prepaid by the contractor. For other methods of participation, including phone, online, or in-person, 
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respondents should not bear costs. In tests of instruments or procedures of controlled trials in 

laboratory or field settings, the CFPB does not anticipate any cost burden to respondents.

14. Estimated Cost to the Federal Government

The costs of pretesting and cognitive testing research projects under this generic 

clearance will vary based on the number of individuals in the study, the method of pretesting 

used, and the size of any payments to incentivize participation. We expect the cost of each 

project to range from $15,000 to $75,000

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

This generic clearance will be used to pretest instruments or interventions prior to the full 

data collection for surveys and controlled trials in field and laboratory settings. The purpose of 

data collected under this generic clearance is to improve the quality of data collection by 

examining the psychological and cognitive aspects of collection methods and procedures. For 

this reason, results from data collected under this generic clearance may or may not be published, 

depending on the project. When results are published, the data will be used for research and 

development reports or be included as a methodological appendix or footnote in a report 

containing data from a larger data collection effort. In addition, the methodological results of this 

research may be prepared for presentation at professional meetings or for publication in 

professional journals.

The Bureau’s research projects are intended to expand scientific understanding of 

consumer decision making in financial domains. Research findings of full research projects 

generally will be published as technical articles that are publicly disseminated as working papers, 

peer-reviewed journal articles, CFPB white papers, or CFPB research briefs. Due to the nature 

of this clearance, there currently is no definitive or tentative schedule. We expect work to be 
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conducted more or less continuously throughout the duration of the clearance. The Office of 

Research plans to conduct an ongoing program of research and therefore plans to apply for an 

extension to the anticipated generic clearance when it expires.

17. Display of Expiration Date

The OMB control number and expiration date associated with this PRA submission will 

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

instruments associated with information collections approved under this collection plan.

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.