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BUREAU OF CONSUMER FINANCIAL PROTECTION

PAPERWORK REDUCTION ACT SUBMISSION

INFORMATION COLLECTION REQUEST

SUPPORTING STATEMENT PART A

[OWNING A HOME EVALUATION STUDY]

(OMB CONTROL NUMBER: 3170-XXXX)

General Instructions

The Supporting Statement is the heart of an “information collection request” (ICR) to the Office 

of Management and Budget (OMB). A completed Supporting Statement A must accompany each 

request for approval of a collection of information. The Supporting Statement should be 

prepared in the format described below, and must contain the information specified below. If an 

item is not applicable, provide a brief explanation. When the question “Does this ICR contain 

surveys, censuses, or employ statistical methods?” is marked "Yes," then a Supporting Statement 

B must be completed. OMB reserves the right to require the submission of additional information 

with respect to any request for approval.

The Supporting Statement is a public document and should be written in a manner that provides 

the average person with an understanding of why information must be collected and what use 

you will make of the information. The entire ICR package is entered into and submitted to OMB 

for review and approval via ROCIS. It is available to the public at www.reginfo.gov.

General Guidelines:

• All Supporting State responses should be written in plain English with acronyms, 

programs, organizations, etc., fully spelled out. No level of program understanding 

should be assumed. Remember, these documents are for the public. 

• Try not to use N/A as a response to a question. If you feel a question does not apply, 

answer appropriately in a full sentence. For example, a good response to question #9: 

“Explain any decision to provide any payment or gift to respondents, other than 

remuneration of contractors and grantees” would be: “There are no plans to provide any 

payments or gifts to respondents.”

• While there are a number of questions that must be answered in each Supporting 

Statement, an “Introduction” section may precede the actual questions and responses if 

it could help the reader understand the context around an information collection.
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TERMS OF CLEARANCE: [This information is found on a previous submission’s “Notice of 

Action” for approval. List previous “Terms of Clearance” here. Briefly explain how the terms 

were addressed. If none, enter “None.” If a new collection, enter “Not applicable. This is a 

request for a new collection of information.

”]

ABSTRACT: [Provide a brief description of this collection of information; including a 

description of respondents, what information is collected, why it is collected, and how it will be 

used. This statement should be what you want to appear on www.reginfo.gov and in the 60 and 

30 day Federal Register notices.]

The Dodd Frank Act directs the Consumer Financial Protection Bureau (CFPB) to develop a 

program of consumer education and engagement. As part of that program, the CFPB has 

developed a suite of online tools and resources to help consumers make better, more informed 

decisions about mortgages. Collectively, these tools and resources are known as the Owning a 

Home project.

The purpose of this information collection is evaluate and improve the Owning A Home project.

The CFPB seeks to gain insights as to (1) whether and how the Owning a Home project impacts 

consumers; (2) which consumer segments or profiles benefit the most from the Owning a Home 

project; (3) the mechanisms by which the Owning a Home project impacts consumer behavior 

and attitudes; (4) general consumer behavior, attitudes, and approaches to obtaining a mortgage 

and mortgage shopping; (5) the validity of certain hypotheses underlying the development of the 

Owning a Home project.

To answer these questions, the CFPB intends to conduct a field study of the Owning a Home 

project. We will recruit prospective homebuyers and assign them to one of two study groups:

those exposed to the Owning a Home tools or resources (the treatment groups) and those not 

exposed to Owning a Home (the control group). We will survey both groups of homebuyers as 

they go through the process of shopping for and acquiring a mortgage, and we will track the 

treatment group’s usage of the Owning a Home web tools and resources. We will then compare 

the two groups’ attitudes, behaviors, and outcomes.

A. JUSTIFICATION

1. Circumstances Necessitating the Data Collection

[Explain the circumstances that make the collection of information necessary. Identify any legal 

or administrative requirements that necessitate the collection.

Your response should cover the need for this information collection. Include specific references 

to statutes, executive orders, regulations, notices or other relevant information that you believe 

directs you to collect the information at issue. You should also include copies of such documents 

as attachments to this Supporting Statement. After reading your response to this question, a 
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reader should have a full understanding of why the CFPB must collect this information.]

The Dodd Frank Act directs the Consumer Financial Protection Bureau (CFPB) to “to educate 

and empower consumers to make better informed decisions.” As part of fulfilling this 

mission, the CFPB has developed a suite of online tools and resources to help consumers make 

better, more informed decisions about mortgages. Collectively, these tools and resources are 

known as the Owning a Home project.

In order to ensure that the CFPB’s tools are as effective as possible, and to ensure that resources 

are well-spent, the CFPB must study the impact of the Owning A Home project. The CFPB seeks 

to gain insights as to (1) whether and how the Owning a Home project impacts consumers; (2) 

which consumer segments or profiles benefit the most from the Owning a Home project; (3) the 

mechanisms by which the Owning a Home project impacts consumer behavior and attitudes; (4) 

general consumer behavior, attitudes, and approaches to obtaining a mortgage and mortgage 

shopping; (5) the validity of certain hypotheses underlying the development of the Owning a 

Home project.

2. Use of the Information

[Indicate how, by whom, and for what purpose the information is to be used. Except for a new 

collection, indicate the actual use the agency has made of the information received from the 

current collection. Be specific. If this collection is a form or a questionnaire, every question 

needs to be justified. The following checklist provides a useful tool to answering this question:

• What information will be collected, reported, or recorded? Are there any pieces of 

information that are especially burdensome in the collection? What are they and why are 

they necessary? 

• From whom will the information be collected? If there are different respondent categories 

(i.e., loan applicant versus bank), each should be describe along with the type of 

collection activity that will apply. 

• How will you use this information? Include all uses. If additional uses arise after OMB 

has cleared this ICR, you will need to revise the supporting statement and re-submit for 

OMB’s approval. 

• How will the information be collected (e.g., forms, non-forms, electronically, face-toface, over the phone, over the internet)? Does the respondent have multiple options for 

providing the information? If so, what are they? 

• How frequently will the information be collected? 

• Will the information be shared with any other parties outside of the CFPB?

• If this is an ongoing collection, how have the collection requirements changed over time? 

Be specific when answering this question. To say the collection of information is necessary to 

“ensure compliance” or “for program evaluation” is too general. In these cases, you would want 

to provide specific examples of how certain information will be used to determine compliance or 

what area of program is being evaluated and how the information collected will enable that 
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evaluation to occur.]

Use of the information

This information will be used to inform CFPB’s future work on the Owning a Home project. It 

will also inform – at a high level – CFPB’s overall approach to consumer education and 

engagement. As described in more detail in section 4, the Owning A Home project is premised 

on two key hypotheses: (1) that shopping in the mortgage market leads to better consumer 

outcomes; and (2) that consumers often do not shop for a mortgage because shopping in the 

mortgage market is difficult, confusing, and generally discouraged by the market structure. The 

Owning A Home project seeks to remedy this situation by encouraging consumers to shop for 

mortgages and supporting and empowering them with user-friendly tools and resources designed 

to make shopping easier and give consumers greater confidence when shopping.

This study will inform CFPB’s future work on Owning A Home as well as its overall approach 

to consumer education and engagement in several ways. First, the study will help us understand 

to what extent – and for what specific consumer segments or profiles – the above hypotheses are 

true. There is some support in existing literature and much anecdotal wisdom to support these 

hypotheses, but little solid research. This study will contribute significantly to the baseline 

factbase on which the CFPB and other governmental agencies and community intermediaries

operate.

Second, the study will help us understand more about how the market and behavioral forces 

implicit in these hypotheses work in practice, which will help inform both the Owning a Home 

project and related programs the CFPB might develop in the future. Third, the study will help us 

understand to what extent, in what specific ways, and for what specific consumer segments or 

profiles the Owning A Home suite is effective at encouraging consumers to shop and mitigating 

the market conditions and behavioral forces that discourage shopping. This nuanced information 

will help the CFPB refine and improve the Owning A Home suite over time.

The CFPB intends to publish aggregate and overall findings from the study so that other 

researchers and agencies may benefit from the work, but it will not make raw data available to 

other agencies or parties. This is a one-time research study. There are no plans to collect this 

information on an on-going basis.

Collection of the information

The target audience for the Owning a Home project is prospective homebuyers. Thus, the study 

will attempt to replicate this target audience by recruiting respondents from among prospective 

homebuyers. Respondents will be asked to complete a short screening questionnaire first in 

order to determine if they are eligible. Data obtained in the screening questionnaire does not 

contain any directly identifying information and will be analyzed only in the aggregate to assess 

which eligibility criteria have the most impact on disqualifying individuals. Upon completing 

the screening questionnaire, respondents are presented with informed consent language and 

asked to opt-in to the study.

Respondents will be asked to provide information in three primary ways. First, respondents will 
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be asked to complete several short surveys, approximately two weeks apart, for approximately 

three months. Second, respondents will be asked to consent to automated tracking of the Owning 

a Home website. Third, respondents will be asked to submit their mortgage documents.

The survey component will include questions on consumers’ current attitudes and behaviors 

around shopping for and acquiring a mortgage. These questions will explore consumers’ 

attitudes to learn how consumers think about and perceive the mortgage shopping/acquisition 

process, and consumers’ behaviors to learn more about what consumers actually do when 

shopping for or acquiring a mortgage. The control group will help us understand more about the 

status quo, while the treatment group will help us understand how Owning a Home can alter that 

status quo.

The online tracking of Owning a Home usage will help us learn more about what types of 

consumers are best served by the Owning a Home project, and what pieces of the Owning a 

Home experience are most effective in improving consumer attitudes and behaviors.

Finally, the collection of mortgage documents will enable us to learn whether changes in 

attitudes and behaviors produced by Owning a Home actually lead to improvements in consumer 

outcomes, i.e. lower-priced or more appropriate mortgages. It is important to collect these 

documents because data obtained from self-reporting of complex financial transactions is 

extremely unreliable. Any personally identifiable information present on these documents will 

be redacted prior to delivery to the CFPB. 

Survey

The survey for this evaluation is organized into 10 modules. A brief description of the modules 

is as follows, with additional justification below.

Module Description of questions

A: Screening and 

background

Involvement in the mortgage industry and in household’s financial decisions. Plans to 

buy a home, and if so, when.

B: Stage of the home 

buying process

Participants’ stage of the home buying process and mortgage search process (e.g. 

whether they have made an offer on a home).

C: Information sources 

used

Identification of the sources used to learn about housing and mortgage options, and 

frequency of usage.

D: Empowerment Participants’ confidence in searching for and evaluating mortgage information and 

offers.

E: Knowledge of the 

mortgage process

Factual questions on mortgages, including concepts like discount points and mortgage 

insurance. Beliefs about real estate agents and lenders.

F: Beliefs about the 

mortgage market

Expectations regarding financial terms, including purchase price, closing costs, and 

interest rates.

G: Request for 

documents

Instructions on how to provide documents. If a participant opts not to submit a HUD-1, 

they are instead asked a series of questions about that document. 

H: Correlates Time preference; Risk preference; Financial literacy; Need for cognition; Numeracy; 

Locus of control (internal vs external); Cognitive reflection

I: Demographics Basic demographic and socio-economic information including race/ethnicity, income, 

employment status, gender, and age. Financial information relevant to mortgage search.

J: Wrap-up Open-ended feedback from participants on the survey; treatment reinforcement.
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Module A is required to identify eligible participants from the population of interest –

individuals who are interested in buying a home in the next few months, are involved in their 

household’s financial decisions, and who are not real estate professionals. Module A will 

measure these concepts in order to screen potential participants for eligibility. It will be 

administered one-time, and is therefore not expected to represent an undue burden. At the 

conclusion of Module A, participants are presented with informed consent language and asked to 

opt-in to the remainder of the study.

Module B assesses participants’ stage of the home and mortgage search processes. It is used to 

identify which subsequent modules will be administered (and skipped), and therefore is useful 

for minimizing participant burden. Additionally, it will provide information on the dynamics of 

participants’ information search, for instance, at what point in their home search they begin to 

think about mortgage terms.

Module C assesses participants’ information search for home and mortgage information. It is 

necessary for measuring where participants are receiving information about mortgages (including 

the Owning a Home website).

Module D contains questions on participants’ empowerment, that is, their subjective ability to 

navigate the mortgage process and confidence in doing so. These questions will allow 

researchers to investigate whether the Owning a Home website increases empowerment, one of 

the outcomes of interest. 

Module E contains factual questions that measure knowledge of the mortgage process. These 

questions will allow researchers to investigate whether the Owning a Home website increases 

knowledge, one of the outcomes of interest. It will also be used to assess whether knowledge 

increases during the process of searching for a home or mortgage. By collecting this information 

from both the treatment and control groups, researchers can compare the relative improvement in 

knowledge (if any) between the groups.

Module F is designed to assess participants’ beliefs about the mortgage market, that is, the terms 

that they believe they will receive. By combining information from this module with 

information on respondents’ demographic and financial characteristics, the research team will be 

able to assess whether beliefs are reasonable, and whether they increase in accuracy over time. 

Module G provides instructions to participants on how to send in their loan documents. Previous 

research has shown that self-reported mortgage information is often inaccurate.

1

 Specifically, in 

a study in which borrowers were asked to identify mortgage terms (using their loan documents), 

the percentage identifying a term correctly was sometimes as low as 5%.2

 Given that mortgage 

outcomes are one of the primary measures of interest, it is essential to collect accurate 

 1 Bucks, B., and Pence, K. (2008). Do borrowers know their mortgage terms? Journal of Urban Economics, 

64(2): 218-33. 2 Lacko, J. M., and Pappalardo, J. K. (2010). The failure and promise of mandated consumer mortgage 

disclosures: Evidence from qualitative interviews and a controlled experiment with mortgage borrowers. 

American Economic Review: Papers and Proceedings, 100: 516-21.
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information on mortgage terms. To reduce burden, participants will be given the opportunity to 

send in their documents directly through a method of their choice: uploading electronic files, 

mobile capture, or sending a fax. Any direct identifying information present on the documents 

will be redacted immediately, and the source documents will be destroyed as soon as practicable. 

If participants decline to send in their final mortgage documents, this module will ask a series of 

questions about their mortgage terms instead, allowing for a coarse estimate of mortgage terms.

In order to further reduce respondent burden, Module G will be administered only when 

participants report having received a new loan estimate or after closing. 

Module H collects background information on respondents’ characteristics, including risk and 

time preferences, financial knowledge, and need for cognition. These characteristics will be 

helpful in subsequent analyses for assessing whether the Owning a Home tool is more effective 

for certain homebuyers. For instance, it may be the case that those with a high level of 

knowledge of financial concepts are more easily able to interpret the information that is provided 

on the website. Module H will be administered one time to reduce burden on respondents.

Module I collects basic demographic and socio-economic information including race/ethnicity, 

income, employment status, gender, and age, as well as financial information relevant to 

mortgage search. Data from Module I will be used for two purposes: 1) to assess whether 

randomization has been conducted successfully and 2) to determine whether participants are 

receiving mortgages that are relatively expensive or inexpensive, given their background 

characteristics. Module I will be administered only once to reduce burden on respondents.

Module J consists of a reinforcing treatment language for both treatment groups, as well as a 

single open-ended, optional question, where participants can report any additional thoughts or 

problems that they have with the survey. Data from Module J will be used to track any potential 

problems with the survey collection that should be addressed by the research team. As it is an 

optional question, it is expected to pose little burden to respondents.

3. Use of Information Technology

[Describe whether, and to what extent, the collection of information involves the use of 

automated, electronic, mechanical, or other technological collection techniques or other forms of 

information technology, e.g., permitting electronic submission of responses, and the basis for the 

decision for adopting this means of collection. Also describe any consideration of using 

information technology to reduce burden and specifically how this collection meets GPEA 

requirements. If the collection is not being considered for electronic delivery, you should provide 

a detailed justification of this decision. 

Note: OMB must approve all internet forms prior to their implementation, including any new or 

revised instructions resulting from this effort. ]

This collection will be collected entirely or almost entirely using electronic submission 

technology. The survey component will be delivered electronically and responses will be 

received electronically. The tracking of Owning a Home site usage will be completed entirely 
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electronically.

For the mortgage document submission component, we intend to give respondents several 

options for submitting their documents. One option would be to scan (if necessary – many 

consumers may receive mortgage documents electronically) and securely upload the documents.

A second option would be mobile capture technology, in which consumers take pictures of their 

paper documents with their mobile phones. A third option could include consumers mailing or 

faxing a copy of their paper documents. We will evaluate the consumer demand for this third 

option during the Pilot Phase of the study.

There are several reasons why electronic delivery and submission are appropriate for this 

collection. The Owning a Home project is itself an online set of tools and resources in its current 

iteration. Thus, our target audience for the Owning a Home project are prospective homebuyers 

with at least moderate competence in using modern internet technology. Our recruitment pool for 

the study will be drawn from the existing customer base of a major online home shopping 

website. Therefore, individuals in the study population are well-equipped to use an online survey 

interface. Moreover, we anticipate that given the respondent pool, respondents will likely prefer

an online interface, and that conducting the study online will increase the response rate.

4. Efforts to Identify Duplication

[Describe efforts to identify duplication. Show specifically why any similar information already 

available cannot be used or modified for use for the purposes described in Item 2 above.

Duplication includes from other sources within the CFPB, from other Federal government 

sources, and from outside sources. If you are aware that information is collected elsewhere in the 

Federal government, the response should include a description of why it would be necessary to 

collect it from a member of the public again.]

The primary purpose of this collection is to identify (1) whether and how the Owning a Home 

project impacts consumers; (2) which consumer segments or profiles benefit the most from the 

Owning a Home project; and (3) the mechanisms by which the Owning a Home project impacts 

consumer behavior and attitudes. Because the Owning a Home project has been specifically 

developed by the CFPB as part of its consumer education and engagement mandate, no preexisting sources of information relevant to these objectives exists.

Two additional purposes of this collection are to gain insight into: (4) general consumer 

behavior, attitudes, and approaches to obtaining a mortgage and mortgage shopping; and (5) the 

validity of certain hypotheses underlying the development of the Owning a Home project. While 

some existing research does exist on these topics, it is limited in scope.

One of the hypotheses used to develop the Owning a Home project is that additional mortgage 

shopping should allow consumers to obtain more favorable mortgage terms. Previous research 

has explored the returns to shopping; however, there are two main limitations of this work in 

addressing this hypothesis. First, the majority of existing research concentrates on consumer 
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goods other than mortgages.3 Given that shopping for a home and mortgage is a large, 

infrequently undertaken, and financially complex transaction, it is unclear whether results from 

other markets will generalize to mortgage outcomes. A second limitation of existing research is 

that methodologically, it has been limited to theoretical and correlational analysis.

4

 Such 

research designs make it impossible to establish a causal relationship between shopping behavior 

and mortgage outcomes, because homebuyers’ shopping behavior may be correlated with other 

unobservable characteristics. Analyses that do not induce variation in shopping behavior are 

unable to cleanly identify returns to shopping.

We have relied on this research in developing the approach to the Owning a Home project, but it 

is not an adequate substitute for the planned collection. We expect that the Owning a Home

project will contribute two main sets of findings to existing research. First, the project will 

provide estimates of the impact of Owning a Home and similar tools on mortgage outcomes. A

randomized controlled trial, such as the one described here, is the best method for cleanly 

estimating the impact of financial education on mortgage outcomes from other individual 

characteristics. Second, the project will provide estimates of the returns to search in the 

mortgage market. As discussed, this work will broaden existing research on consumer search 

using other consumer products and make methodological improvements in establishing the 

causal effect of search on outcomes.

5. Efforts to Minimize Burdens on Small Entities

[If the collection of information impacts small businesses or other small entities, describe any 

methods used to minimize burden.

Out of the total number of respondents, you should give a percentage or estimated number of 

respondents that are small business in your response.]

The information will be collected from private citizens, not business entities.

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

[Describe the consequence to Federal program or policy activities if the collection is not 

conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing 

burden.

 3 See, for example, Griffith, R. et al. (2009). “Consumer Shopping Behavior: How Much Do Consumers Save?” 

The Journal of Economic Perspectives, 23(2), pp. 99-120; Ratchford, B. and Srinivasan N. (1993). “An Empirical 

Investigation of Returns to Search.” Marketing Science, 12(1), pp. 73-87; Brown, J. and Goolsbee, A. (2000). 

“Does the Internet make Markets More Competitive? Evidence from the Life Insurance Industry.” NBER Working 

Paper 7996; 

4 See, for example, Cook M. et al. (2002). “Losing Interest: How Much Can Consumers Save by Shopping Around 

for Financial Products?” Financial Services Authority Occasional Paper Series 19 and Woodward, S. and Hall, R. 

(2012). “Diagnosing Consumer Confusion and Sub-Optimal Shopping Effort: Theory and Mortgage-Market 

Evidence.” American Economic Review, 102(7), 3249-3279.
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Address the impact on the CFPB’s mission if the information is not collected or is conducted less 

frequently. This explanation may include justification such as an inability to deliver program 

benefits, or the timely implementation of a new program.]

This is a one-time collection of information. If the information is not collected, the CFPB will be 

unable to make evidence-based decisions about how best to deliver on its consumer education 

and engagement mandate. In order to be certain that we are using the most effective approaches 

and investing our resources in the most effective places and ways, the CFPB needs to study the 

impact of its consumer education and engagement work, including the Owning a Home project.

7. Circumstances Requiring Special Information Collection

[Explain any special circumstances that would cause an information collection to be conducted 

in a manner:

• Requiring respondents to report information to the agency more often than quarterly;

• Requiring respondents to prepare a written response to a collection of information in 

fewer than 30 days after receipt of it;

• Requiring respondents to submit more than an original and two copies of any 

document;

• Requiring respondents to retain records, other than health, medical, government 

contract, grant-in-aid, or tax records, for more than three years;

• In connection with a statistical survey that is not designed to produce valid and 

reliable results that can be generalized to the universe of study;

• Requiring the use of a statistical data classification that has not been reviewed and 

approved by OMB;

• That includes a pledge of confidentiality that is not supported by authority established 

in statute or regulation, that is not supported by disclosure and data security policies 

that are consistent with the pledge, or which unnecessarily impedes sharing of data 

with other agencies for compatible confidential use; or

• Requiring respondents to submit proprietary trade secrets, or other confidential 

information, unless the agency can demonstrate that it has instituted procedures to 

protect the information's confidentiality to the extent permitted by law.

If the answer to any of these bullets is “yes”, include a full explanation of those circumstances. If 

you feel that none of the bullets apply, you can use the following sample language: “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).” ]

Participation in this study is entirely voluntary, and respondents can choose to cease their 

involvement at any time. Respondents will be asked to report information approximately every 

two weeks, for a period of approximately three months. This frequency of survey was chosen so 
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as to ensure that we can capture the changes in consumers’ attitudes and behaviors over a 

relatively short mortgage shopping/acquisition window. A less frequent survey schedule would 

require respondents to recall how they felt or what actions they took over too long of a recall 

period. In behavioral surveys, the best practice is to survey respondents frequently enough so that 

the period of recall is not too long to confound their memories. To minimize burden, the 

individual surveys will be kept short.

Respondents will be asked to respond to surveys within approximately five days of receipt.

Again, the goal is to capture consumers’ attitudes and behavioral reports while the information is 

still fresh in their mind. Moreover, given that respondents will be surveyed again two weeks 

later, the first survey must be answered in a timely fashion so as not to conflate results with the 

subsequent survey.

8. Consultation Outside the Agency

[If applicable, provide a copy and identify the date and page number of publication in the Federal 

Register of the agency's 60-day notice, required by 5 CFR 1320.8(d), soliciting comments on the 

information collection prior to submission to OMB. Summarize public comments received in 

response to that notice and in response to the PRA statement associated with the collection over 

the past three years, and describe actions taken by the agency in response to these comments.

Specifically address comments received on cost and hour burden. Comments obtained from the 

60-day notice should be provided to OMB. 

Describe efforts to consult with persons outside the agency to obtain their views on the 

availability of data, frequency of collection, the clarity of instructions and recordkeeping, 

disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or 

reported.

Consultation with representatives of those from whom information is to be obtained or those who 

must compile records should occur at least once every three years — even if the collection of 

information activity is the same as in prior periods. There may be circumstances that may 

preclude consultation in a specific situation. These circumstances should be explained.]

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 collection of information. Further 

and in accordance with 5 CFR 1320.5(a)(1)(iv), the Bureau will publish a notice in the Federal 

Register allowing the public 30 days to comment on the submission of this information 

collection request to the Office of Management and Budget.

The CFPB has also consulted on the design of this survey with Mick Couper, a professor and 

survey design expert at the Population Studies Center at the University of Michigan. The CFPB 

will conduct a pilot test of the study in advance of the full study. Learnings from the pilot will 

be used to refine the survey and recruitment language, process, and incentive structure. This 

pilot-phase study will be approved by the Office of Management and Budget under a separate 

generic PRA clearance.
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9. Payments or Gifts to Respondents

[Explain any decision to provide any payment or gift to respondents, other than remuneration of 

contractors or grantees. If such a decision is contemplated, include a justification for this action, 

description, monetary value of the item.

If you do not plan to provide payments or gifts, a possible response would be: “No payments or 

gifts are provided to respondents.”]

Prospective homebuyers are a hard-to-find population—only a small percentage of the 

population is actively interested in purchasing a new home at any given time. Additionally, 

searching for a home is a time-consuming activity. We believe incentives are necessary to ensure 

an adequate response rate.

Based on similar research and consulting with survey experts, we believe that an incentive of 

approximately $65-70 will be appropriate to attract sufficient response while minimizing cost to 

the government. Because the study requires multiple surveys over a period of time, the incentive 

will be delivered in multiple installments—the precise incentive that a participant earns will 

depend on the completeness of their participation. 

We plan to conduct a Pilot Phase study to test how best to allocate the survey budget between 

upfront and deferred payments. This is discussed more in question 14. Incentives will be 

delivered via through PayPal and Amazon e-giftcard. Respondents will also have the option to 

choose to receive a reusable gift card. 

Participants will be able to complete all survey activities at home or in the location of their 

choice, thus there are no expected travel costs. The surveys have been tested to minimize time 

burden; additional details are provided below in Section 12.

10. Assurances of Confidentiality

[Describe any assurance of confidentiality provided to respondents and the basis for the 

assurance in statute, regulation, or agency policy.

If the CFPB has unique confidentiality policies or other privacy policies apply, they should be 

cited and discussed in terms of what protections will be provided to respondents.]

The Bureau will not disclose any personally identifiable information collected except to the 

extent that it is required to do so by law and as provided in the Privacy Act Statement listed 

below. Additionally, the Bureau will treat the information collected consistent with its 

confidentiality regulations at 12 C.F.R. Part 1070, et seq.
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The information contemplated here is covered under two separate Privacy Impact Assessments 

(PIA). The Consumer Experience Research PIA is available at 

http://files.consumerfinance.gov/f/201406_cfpb_consumer-experience-research_pia.pdf, while 

the forthcoming Consumer Education PIA will be published on consumerfinance.gov/privacy 

prior to the start of the pilot. Additionally, information contemplated here is subject to the 

Privacy Act of 1974 and is covered under the Bureau’s existing Consumer Education and 

Engagement Records System of Records Notice, 77 FR60382.

11. Justification for Sensitive Questions

[Provide additional justification for any questions of a sensitive nature, such as sexual behavior 

and attitudes, religious beliefs, race/ethnicity, disability, social security numbers, and other 

matters that are commonly considered private. This justification should include the reasons why 

the agency considers the questions necessary, the specific uses to be made of the information, the 

explanation to be given to persons from whom the information is requested, and any steps to be 

taken to obtain their consent.

For information collections involving questions of race/ethnicity, you should 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. 

If this question does not apply, a possible response would be: “This information collection does 

not include questions of a sensitive nature.”]

Respondents will be asked to provide basic demographic and socio-economic information 

including their race/ethnicity, employment status, gender, and age. This information is necessary 

to determine whether a socio-demographically diverse data set has been collected. Additionally, 

it is necessary to determine that the randomization process was correctly executed and that the 

treatment and control groups are similar with regard to known factors. 

Respondents will also be asked to provide financial information relevant to their home and 

mortgage search, including an estimated purchase price, income level, liquid assets available, 

and perceived credit score. This information is necessary to determine whether respondents are 

receiving a relatively expensive or inexpensive mortgage, as mortgage rates are partially 

determined by purchase price, a borrower’s creditworthiness (credit score, income), and potential 

down payment (liquid assets).

Finally, respondents will be asked to provide mortgage loan documents. Previous research has 

demonstrated that borrowers may not be aware of all of their mortgage terms; therefore, it is 

necessary to see loan documents directly. Improvement in mortgage terms is one of the main 

measures of interest.

Before providing any personally identifiable or otherwise sensitive information, participants will 

be given informed consent documents. Such documents will give researchers permission to 
Page 14 of 22

collect and analyze demographic and financial information throughout the study. Additionally, 

during survey collection, respondents may refuse to answer any question or participate in 

additional survey activity, including providing mortgage documents.

12. Estimated Burden of Information Collection

[Provide estimates of the hour burden of the collection of information. The statement should:

• Indicate the number of respondents, frequency of response, annual hour burden, and an 

explanation of how the burden was estimated. Unless directed to do so, agencies should 

not conduct special surveys to obtain information on which to base hour burden 

estimates. Consultation with a sample (fewer than 10) of potential respondents is 

desirable. If the hour burden on respondents is expected to vary widely because of 

differences in activity, size, or complexity, show the range of estimated hour burden, and 

explain the reasons for the variance. Generally, estimates should not include burden hours 

for customary and usual business practices.

• If this request for approval covers more than one form, provide separate hour burden 

estimates for each form and aggregate the hour burdens.

• Provide estimates of annualized cost to respondents for the hour burdens for collections 

of information, identifying and using appropriate wage rate categories. The cost of 

contracting out or paying outside parties for information collection activities should not 

be included here.

This response should be detailed enough for the reader to understand how you developed the 

burden estimates (e.g., sources of data, changes in program requirements). It is not necessary to 

indicate collection instrument by collection instrument how the estimated response was derived; 

however, a general statement on how those numbers were developed is necessary.

Whenever there is more than one source of burden (e.g., multiple forms, surveys, or 

recordkeeping requirements), you should use a burden table or spreadsheet in Excel to show the 

burden estimate for each collection requirement.

Note: a respondent is counted only ONCE though he or she may complete multiple documents.

Therefore, the number of respondents affected by the collection should not necessarily equal the 

sum of the number of the respondent’s column. The number of respondents is the actual number 

of individuals the collection is estimated to impact in a given year.

In developing burden estimates, you should take into account the following considerations: 

• In complex collections, you may need to calculate the burden estimate separately for 

different categories of respondents. A single grid can be used for this, but some narrative 

should be provided to describe the burden estimation approach used for each group of 

respondents.

• The burden estimate may need to account for different methods of collecting the same 
Page 15 of 22

information. For example, if a form previously (and currently) available in hard copy 

format is now available on the Internet and the capability also exists to submit the 

information to the agency electronically, then separate burden calculations for submission 

of the same information should be included to reflect the different time requirements 

associated with each method of collection. This can also be included, with proper 

notations in the description column, in the same table or grid, as long as a detailed 

narrative explaining the duplication is provided in the response.

• If you do not offer other methods for reporting required information other than physically 

visiting a field or headquarters office, then you must include round trip travel time in the 

burden estimate. If multiple collection options are offered, then travel time should be 

calculated for only the percentage of responses that you feels will result from a physical 

visit to an office.

With respect to annualized costs to respondents for the hour burdens for collections of 

information, the estimate of annualized cost is a theoretical cost accounting for the idea that the 

respondent’s time spent complying with the information collection request is worth something -

i.e., time is money. The total burden hours should be multiplied against an average hourly wage 

rate for the respondent universe.

Minimum wage may be used, but only if that wage is reasonable for the class of respondent 

affected. An explanation of the wage rate used should be provided and the source, if applicable, 

cited. If multiple respondent groups exist, then the burden hours for each group should be 

factored against an appropriate hourly wage rate and summed. Note: This information can be 

found at Dept. of Labor, Bureau of Statistics website. The most current BLS data is available at:

http://www.bls.gov/news.release/pdf/ocwage.pdf.]

The calculation of burden is complex, as attrition over the course of this longitudinal study 

results in a diminishing number of participants at each stage. The below table includes estimates 

of attrition and a detailed calculation of burden hours for each task. The per-task burden 

estimates were developed using a small (less than 9) sample of instrument pre-testers. The total 

burden is estimated at 9,661 hours. 
Page 16 of 22

13. Estimated Total Annual Cost Burden to Respondents or Recordkeepers 

[Provide an estimate of the total annual non-hour cost burden to respondents or recordkeepers 

resulting from the collection of information. (Do not include the cost of any hour burden already 

reflected in item 12.)

• The cost estimate should be split into two components: 

o (a) a total capital and start-up cost component (annualized over its expected useful 

life) and 

o (b) a total operation and maintenance and purchase of services component. The 

estimates should take into account costs associated with generating, maintaining, 

and disclosing or providing the information (including filing fees paid for form 

processing). Include descriptions of methods used to estimate major cost factors 

Line # Component Retention # ParticipantsSample/attrition 

calculation notes

Time/ 

person 

(mins)

Burden 

Hours

Burden calculation notes

1 Arrive at Study Home Page 50,000

2 Screener (Module A) 0.95 47,500 Nearly all those who arrive in will 

at least take the screener

3 2375

3 -- Eligibility criteria: plan to offer w/in 3 mos 0.67 31,825

4 -- not employed by mortgage industry 0.95 30,234

5 -- financial decisionmaker 0.95 28,722

6 Opt-in to study 0.5 14,361 50% of those completing screener 

will agree to participate

7 Baseline Survey (Module B-F; H-J) 0.9 12,925 those eligible & opted-in who 

start the baseline

uses average of start and finish 

participant numbers

8 0.75 9,694 those who complete once started 

(long survey - lower completion 

rate)

22 4147

9 Periodic Survey #1 (Module B, C, D, J) 0.8 7,755 those who start periodic surveys

10 0.95 7,367 short survey; higher completion 6 756 uses average of start and finish 

ii b 11 Periodic Survey #2 (Module B, C, D, J) 0.9 6,630

12 -- rejoiner rate (those who miss survey #1) 0.05 485

13 -- completion rate 0.95 6,759 short survey; higher completion 6 462 uses average of start and finish 

14 Periodic Survey #3 (Module B, C, D, J) 0.85 5,745

15 -- rejoiner rate (those who miss survey #2) 0.04 295

16 -- Start, don't complete 0.1 604 6 30 applies a 0.5 factor to burden time 

to account for drop outs

17 -- Complete 0.8 4,832 later survey; lower completion 

rate

6 483

18 -- Closed, jump to exit survey 0.1 604 see "early closers" below

19 Periodic Survey #4 (Module B-G, J) 0.75 3,624 calculated from # that finish 

survey 3 -- later stage, attrition 

likely permanent

20 -- Start, don't complete 0.1 362 18 54 applies a 0.5 factor to burden time 

to account for drop outs

21 -- Complete 0.75 2,718 18 815

22 -- Closed, jump to exit survey 0.15 544 see "early closers" below

23 GFE document collection (Module G) 0.5 1,359 calculated from # that finish 

survey 4

4 91 not all participants will have docs

24 Final Survey - Late closers (Module B, C, F, J) 0.7 1,903 starting survey - calculated from # 

finishing survey 4 

25 0.8 1,522 completing survey 8 228

26 Final Survey - Early closers (Module B, C, F, J) 1,148 early closers 100% start rate, non complete 

accounted for in earlier surveys

27 0.8 918 completing survey 8 138

28 Final document collection (Module G) 0.5 1,220 of those completing final survey 4 81

28 Total 109 9,661
Page 17 of 22

including system and technology acquisition, expected useful life of capital 

equipment, the discount rate(s), and the time period over which costs will be 

incurred. Capital and start-up costs include, among other items, preparations for 

collecting information such as purchasing computers and software; monitoring, 

sampling, drilling and testing equipment; and record storage facilities.

• If cost estimates are expected to vary widely, agencies should present ranges of cost 

burdens and explain the reasons for the variance. The cost of purchasing or contracting 

out information collection services should be a part of this cost burden estimate. In 

developing cost burden estimates, agencies may consult with a sample of respondents 

(fewer than 10), utilize the 60-day pre-OMB submission public comment process and use 

existing economic or regulatory impact analysis associated with the rulemaking 

containing the information collection, as appropriate.

• Generally, estimates should not include purchases of equipment or services, or portions 

thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with 

requirements not associated with the information collection, (3) for reasons other than to 

provide information or keep records for the government, or (4) as part of customary and 

usual business or private practices.

This question and its response should address the ACTUAL cost a respondent must bear as a 

result of the information collection. In most situations, this will be zero; however, the agency 

should consider all aspects of the information collection to determine if any equipment, software, 

or services must be procured by the respondent in order to provide the agency with the 

information requested.

If you do not feel there are any costs of this nature, the following response may be used: “There 

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

collection.”]

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

information collection.

14. Estimated Cost to the Federal Government

[Provide estimates of annualized cost to the Federal government. Also, provide a description of 

the method used to estimate cost, which should include quantification of hours, operational 

expenses (such as equipment, overhead, printing, and support staff), and any other expense that 

would not have been incurred without this collection of information.

The response should include the ACTUAL costs the CFPB will incur as a result of implementing 

this information collection. The estimate should include costs, if applicable, for: 

• Employee labor and materials for developing, printing, storing forms (formula to use re: 

printing - .0473 per page (i.e., a 10 page form would cost .473 x number of copies 

printed, whether it be printed by the plant or Xeroxed); 

• Employee labor and materials for developing computer systems, screens, or reports to 
Page 18 of 22

support the collection; 

• Employee travel costs; 

• Cost of contractor services or other reimbursements to individuals or organizations 

assisting in the collection of information; 

• Employee labor and materials for collecting the information; and

• Employee (programs) labor and materials for analyzing, evaluating, summarizing, and/or 

reporting on the collected information.

Consider summarizing this information in a table or grid. When costs for employee time are 

being described, a separate table or grid entry should be noted for each different grade/step 

category involved in the collection activity.

If there are no costs: “There are no additional costs to the Federal Government.”]

The costs to the Government to conduct this collection consist of a firm-fixed price contract for 

survey administration support and data matching, and the incentives paid to participants. 

Category Method of computation Cost

Contractor support Firm fixed-price contract $246,058

Incentives to respondents See below. $189,465

Total cost to the Government: $435,523

Incentives to Respondents

The calculation of the total cost of incentives is complex, as attrition over the course of this 

longitudinal study results in a diminishing number of participants at each stage. The below table 

includes estimates of attrition and incentive costs for each stage of the study. In the pilot phase 

of this study, we will test variations to the incentive structure to refine our approach and 

minimize costs to the Government. 
Page 19 of 22

15. Program Changes or Adjustments

Line # Component Retention # ParticipantsIncentive Total $

1 Arrive at Study Home Page 50,000

2 Screener (Module A) 0.95 47,500

3 -- Eligibility criteria: plan to offer w/in 3 mos 0.67 31,825

4 -- not employed by mortgage industry 0.95 30,234

5 -- financial decisionmaker 0.95 28,722

6 Opt-in to study 0.5 14,361

7 Baseline Survey (Module B-F; H-J) 0.9 12,925

8 0.75 9,694 $5 $48,470

9 Periodic Survey #1 (Module B, C, D, J) 0.8 7,755

10 0.95 7,367

11 Periodic Survey #2 (Module B, C, D, J) 0.9 6,630

12 -- rejoiner rate (those who miss survey #1) 0.05 485

13 -- completion rate 0.95 6,759

14 Periodic Survey #3 (Module B, C, D, J) 0.85 5,745

15 -- rejoiner rate (those who miss survey #2) 0.04 295

16 -- Start, don't complete 0.1 604

17 -- Complete 0.8 4,832

18 -- Closed, jump to exit survey 0.1 604

19 Periodic Survey #4 (Module B-G, J) 0.75 3,624

20 -- Start, don't complete 0.1 362

21 -- Complete 0.75 2,718

22 -- Closed, jump to exit survey 0.15 544

23 GFE document collection (Module G) 0.5 1,359 $5 $6,795

24 Final Survey - Late closers (Module B, C, F, J) 0.7 1,903

25 0.8 1,522 $50 $76,100

26 Final Survey - Early closers (Module B, C, F, J) 1,148

27 0.8 918 $50 $45,900

28 Final document collection (Module G) 0.5 1,220 $10 $12,200

28 Total $70 $189,465
Page 20 of 22

[Explain the reasons for any program changes or adjustments in hour or cost burden.

This response should address any changes from the previous approval of the collection. If no 

changes have been made then the following statement would be appropriate: “There are no 

changes to the information collection since the last OMB approval.”

If there are changes, your response should be detailed enough for the reader to track the requests 

for changes from the previously approved burden amount to the current burden request. Program 

changes include: changes that were implemented proactively by the CFPB (e.g., a regulatory 

change which eliminated or added reporting/recordkeeping requirements; a change in frequency 

of collection; a change in the method of collection) regardless of whether or not the changes 

were directed by legislation. Adjustments include: changes due to things not necessarily in the 

CFPB’s control (e.g., a change in the number of respondents, a change in program funding 

levels) or changes in the burden estimation approach (e.g., addition of a form currently in use, 

but not previously approved; a change in a burden estimate, changes due to previous 

miscalculations in the burden estimate). If a new collection, enter “This is a new information 

collection request; therefore, all the burden (see Item 12) is considered a program change”]

This is a new information collection. There is no prior OMB approval.

16. Plans for Tabulation, Statistical Analysis, and Publication

[For collections of information whose results will be published, outline plans for tabulation and 

publication. Address any complex analytical techniques that will be used. Provide the time 

schedule for the entire project, including beginning and ending dates of the collection of 

information, completion of report, publication dates, and other actions. Also indicate whether the 

information would be distributed internally or externally.]

Information from participants at baseline will be used to evaluate the quality of the 

randomization process. Specifically, if assignment to treatment and control groups has occurred 

randomly, then there should be no statistically distinguishable differences between the treatment 

and control groups with regard to descriptive characteristics. The initial survey will include 

information on basic demographic and socio-economic characteristics, information sources used 

thus far in the mortgage search, and knowledge of and attitudes toward the mortgage process.

The primary analytic technique for estimating the impact of the Owning a Home suite of tools is 

a comparison of the outcomes for participants who were given access to these tools (the 

treatment group) to those who were not given access (the control group). The research team 

intends to use “intent to treat” analysis, thereby estimating effects on those who had the 

opportunity to receive treatment, including those who did and did not use the tools. Assuming 

that the randomization process is performed correctly, this analysis identifies the causal impact 

of access to the Owning a Home suite of tools on mortgage outcomes for the study population.

Estimates of the differences between the two groups will be calculated using data from surveys, 

online tracking, and mortgage outcomes. For each difference, statistical confidence intervals 
Page 21 of 22

will be calculated using standard statistical assumptions.

For some outcomes, the research team is additionally interested in how outcomes changed during 

the home shopping process. For example, it may be expected that respondents who have 

completed their home purchase and have closed on a mortgage will have higher knowledge of 

the mortgage process than those who are in the initial stages of their home search. As such, 

changes in mortgage knowledge between baseline and the final survey will be compared for

those in treatment and control groups.

In addition to variation that is imposed on the groups from random assignment, there will be 

variation on an individual basis. The research team is interested in whether the Owning a Home 

suite of tools is more effective for individuals with particular characteristics, such as higher 

financial literacy. Thus, within the treatment group, outcomes will be compared for respondents 

with differing baseline characteristics.

Finally, it is worthwhile to know whether shopping behavior itself improves mortgage outcomes, 

and some academic research has investigated this question.

5

 It is expected that participants in 

the treatment group may engage in more shopping behavior than those in the control group. In 

order to isolate the effect of shopping, researchers will employ what is known as a “two stage 

least squares” approach. This technique will statistically isolate the effect of shopping on 

mortgage outcomes, allowing researchers to estimate the benefits from shopping.

The research team will analyze, integrate, and summarize data and findings from the research in 

a report, which will be made publicly available. 

Tentative Timetable

Information collected April – July 2015

Data analysis August 2015 – March 2016

Writing of report March 2016 – September 2016

Publication of aggregate report Approximately December 2016

17. Display of Expiration Date

[If seeking approval to not display the expiration date for OMB approval of the information 

collection, explain the reasons that display would be inappropriate.

If the agency plans to print the expiration date of OMB approval on all forms/surveys/ 

questionnaires, then the following statement would be appropriate: “The Bureau plans to display 

the expiration date for OMB approval of the information collection on all instruments.”]

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.

 5 Woodward, S. E., and Hall, R. E. (2010). Consumer confusion in the mortgage market: Evidence of less than a 

perfectly transparent and competitive market. American Economic Review: Papers & Proceedings, 100: 511-15.
Page 22 of 22

18. Exceptions to the Certification Requirement

[Explain each exception to the topics of the certification statement identified in "Certification for 

Paperwork Reduction Act Submissions." If there are exceptions, a detailed justification of each 

should be provided. 5 CFR 1320.9, and the related provisions of 5 CFR 1320.8(b)(3), The 

certification is to be made with reference to those regulatory provisions and include the 

following items: 

(a) It is necessary for the proper performance of agency functions; 

(b) It avoids unnecessary duplication; 

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous terminology that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and 

recordkeeping practices;

(f) It indicates the retention period for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8(b)(3):

(i)Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and 

effective management and use of the information to be collected (see note in Item 19 of the 

instructions)

(i) It uses effective and efficient statistical survey methodology; and

(j) It makes appropriate use of information technology.

If no exemption is being sought, enter “The Bureau certifies the 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 to these certificastion requirements.” 

Note: Generally, the Bureau’s PRA Officer does not sign information collection request seeking an exemption to 

the PRA certification requirements unless a robust and defensible justification for such an exemption is provided.]

The Bureau certifies the 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 to these 

certification requirements