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CONSUMER FINANCIAL PROTECTION BUREAU

INFORMATION COLLECTION REQUEST – SUPPORTING STATEMENT

PART A

DEVELOPMENT OF METRICS TO MEASURE FINANCIAL WELL-BEING OF 

WORKING-AGE AND OLDER AMERICAN CONSUMERS

(OMB CONTROL NUMBER: 3170-XXXX)

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.

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

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

Law No. 111-203, the Bureau’s Office of Financial Education (“OFE”) is responsible for 

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

includes measurable goals and initiatives, in consultation with the Financial Literacy and 

Education Commission, consistent with the National Strategy for Financial Literacy. In addition, 

the Office of Financial Protection for Older Americans (OA) within the CFPB is charged with 

conducting research to identify methods and strategies to educate and counsel seniors, and 

developing goals for programs that provide seniors with financial literacy and counseling. 

The CFPB intends to collect quantitative data through surveys with working-age (age 18-61) and 

older American (age 62 and older) consumers in order to develop and refine survey instruments 

that will enable the CFPB to reliably and accurately measure adult consumers’ financial wellbeing. The primary anticipated data collection strategy is through internet-based surveys. The 

core objective of the data collection is to iteratively test, refine, and produce valid and reliable 

measures of consumer financial well-being that will create a strong, standardized basis for setting 

measurable goals, and evaluating financial education strategies and programs.

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 

reader should have a full understanding of why the CFPB must collect this information.]

The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Pub. L. 111-203) 

(“the Dodd-Frank Act” or “the Act”) requires the Consumer Financial Protection Bureau (CFPB) 

to regulate the offering and provision of consumer products or services under Federal consumer 

financial law. The Act also established the Office of Financial Education (OFE) within the 

CFPB, which is responsible for developing and implementing a strategy to improve the financial 

literacy of consumers that includes measurable goals and objectives, in consultation with the 

Financial Literacy and Education Commission (FLEC)1

, and, together with the CFPB’s Office of 

 1 The Financial Literacy and Education Commission was established under the Fair and Accurate Credit 

Transactions Act of 2003. The Commission was tasked to develop a national strategy on financial education. It is 

chaired by the Secretary of the Treasury, vice-chaired by the Director of the CFPB, and made up of the heads of 20 
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Research, for conducting research related to financial education and counseling. In addition, the 

Act established the Office of Financial Protection for Older Americans (OA) within the CFPB, 

which is charged with conducting research to identify methods and strategies to educate and 

counsel seniors, and developing goals for programs that provide seniors with financial literacy 

and counseling.

There are at least three challenges in formulating and setting measurable goals for effective 

financial education initiatives. First, there is inadequate evidence regarding which financial 

education strategies are most effective. According to a June 2011 Government Accountability 

Office (GAO) report on financial literacy, “relatively few evidence-based evaluations of 

financial literacy programs have been conducted, limiting what is known about which specific 

methods and strategies are most effective.2” Second, there are no standard or rigorously tested 

measures of consumer financial knowledge, behavior, or well-being outcomes that can provide a 

gauge to measure the effectiveness of financial education or capability programs, products, or 

services. FLEC’s Research & Evaluation Working Group has identified the development of 

“‘key metrics’ for financial education/capability, including measures of knowledge, behaviors, 

and well-being” as one of its top priority areas for research.3

 Third, there is limited evidence of 

the precise role financial knowledge plays in improving financial decisions and financial wellbeing and whether it is relatively more important in this respect than, for example, numeracy, 

patience, cognitive abilities or social aspects of financial choices and financial behavior. 

In order to help the CFPB, other FLEC agencies, and the broader financial education field 

develop and support strategies and programs that lead to better financial outcomes for American 

consumers, the CFPB is engaging in a major research project (“this Project” or “the Project”) 

focused on making significant progress toward learning:

1. What knowledge and behavior predict financial well-being;

2. What the importance of financial knowledge is relative to other factors (personal 

traits and social context) in improving financial well-being; and,

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

concepts.

The products of this Project should allow the CFPB, other FLEC agencies, and the broader 

financial education field to develop well-informed approaches to improving consumer financial 

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

financial knowledge, behavior, well-being, and related factors, the Project will create a strong 

basis for evaluating financial education policies and programs. More specifically, these metrics 

 

additional federal agencies.

2 U.S. Government Accountability Office, GAO-11-614, Financial Literacy: A Federal Certification Process for 

Providers Would Pose Challenges (June 28, 2011), available at http://www.gao.gov/assets/330/320203.pdf. 3 Financial Literacy and Education Commission, 2012 Research Priorities and Research Question, available at 

http://www.treasury.gov/resource-center/financial-education/Documents/2012%20Research%20Priorities%20-

%20May%2012.pdf
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should significantly increase the ability of the CFPB, other FLEC agencies, and private 

researchers to undertake a wide range of program and policy effectiveness testing to determine 

which approaches make the biggest difference in consumer outcomes. 

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

(1) Qualitative research to inform separate definitions of financial well-being for both 

working-age and older Americans, and the development of clear hypotheses regarding the 

drivers of financial well-being. In addition, the qualitative research will inform the 

wording of survey items to test these hypotheses. 

(2) Rigorous development, testing, and refinement of survey items to measure the constructs 

(variables) hypothesized in phase one to relate to financial well-being. 

(3) A quantitative test of the hypotheses developed in phase one, using survey items 

developed during phase two.

The information collected through these processes will increase the CFPB’s understanding of 

consumers’ financial experiences and outcomes and therefore what type of financial education 

and empowerment programs and practices may improve financial decision-making skills and 

outcomes for consumers.

The Office of Management and Budget (OMB) has approved information collection for phase 

one, the qualitative research to inform hypotheses about financial well-being and the wording of 

survey items to test these hypotheses, which is currently underway. Through this Information 

Collection Request, “Development of Metrics to Measure Financial Well-being of Working-Age 

and Older American Consumers,” the CFPB seeks approval to conduct the second phase of this 

project: rigorous development, testing, and refinement of survey items to measure the constructs 

(variables) hypothesized in phase one to relate to financial well-being.

2. Use of the Information

[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 
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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 evaluation to occur.]

In order to conduct survey research in support of financial well-being metrics development, the 

CFPB has contracted with the Corporation for Enterprise Development (CFED). CFED, in turn, 

has subcontracted with the Center for Financial Security at the University of Wisconsin-Madison 

(CFS) and Vector Psychometrics Group (VPG), to field three rounds of surveys. CFED and its 

subcontractors will work with Survey Sampling International (SSI) and partner organizations to

coordinate fielding of the survey and survey question refinement after each phase has been 

completed.

Of the approximately 16,500 surveys that will be completed by a sample of Americans ages 18 

and over resembling the larger US population:

 15,000 surveys will be fielded online in two rounds by Survey Sampling International. 

SSI will then field a third round of 1,500 surveys using a mixed methods approach

(online, telephone and pencil-paper);

 11,500 surveys will be completed by working-age Americans (ages 18-61) and 5,000 will 

be completed by older Americans (age 62 and older).

Survey Sampling International (SSI) will recruit two online samples: one that includes working 

age Americans between the ages of 18 and 61 and another that includes Americans ages 62 and 

older. Both of these samples will resemble the US population as a whole in terms of their 

income, education, employment status, marital status, age, gender, race/ethnicity, presence/ages 

of children, and geography.

Working-Age American Samples

SSI will administer three rounds of surveys to working-age Americans. No respondent will be 

asked to take more than one survey. The first round will consist of 7,000 completed online 

surveys. The second round will consist of 3,000 completed online surveys. The third round will 

consist of 1,500 surveys: approximately 500 completed online, 500 completed over the phone
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and 500 completed using a pencil-paper questionnaire. The objective of the third survey round is 

to compare responses to individual questions across methods of administration and to further 

refine survey questions for the final instruments. It is not necessary for the third round survey

sample to closely resemble the US population as a whole because psychometric analysis will 

focuses on responses differences by delivery mode as opposed to socio-demographic 

characteristcs.

Older Americans Samples

SSI will administer two rounds of surveys to older Americans. No respondent will be asked to 

take more than one survey. The first round will consist of 2,000 completed online surveys. The 

second round will consist of 3,000 completed online surveys.

Information to be Collected

Each iteration of the survey will include questions on demographics of respondents, including 

their gender, race/ethnicity, marital status, employment status, education status, income level, 

dependent status (whether they have children or are someone else’s dependent), and general 

geographic region (urban, suburban, or rural). If SSI already has this information from 

respondents and it is up to date, SSI will not include these questions in the survey. No personally 

identifiable information will be collected. In addition to demographic information, each iteration 

of the survey will ask questions in the following types of conceptual areas: 

• financial well-being;

• financial and general knowledge;

• financial behaviors and decisions;

• personality traits; and

• social context.

The goal of these surveys is to develop a final set of items (question and answer sets) to measure 

each concept. These items should be easily comprehended by the average American consumer

and should provide a statistically reliable measure of each concept. To achieve this goal, an 

iterative process is used with continuous refinement of the wording of each item, as well as a 

weeding out of poor or irrelevant items. Individual question and answer sets may change each 

time the survey is fielded based on the analysis of the results of the previous survey. 

In its simplest form, the process can be described as follows:

Step 1: Generate a large pool of candidate survey items based on a literature review and 

qualitative research undertaken in a previous phase of the project.

Step 2: Revise the candidate survey items with the panel of experts associated with the project in 

order to refine item wording and weed out poor questions.

Step 3: Field the first round of the survey online to test the items and use psychometric 
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techniques to analyse the items’ performance. Promising questions will be retained and poor 

performing questions will be weeded out.

Step 4: Field the second round of the survey online with the revised items to refine and validate 

the work from round one using additional psychometric techniques (e.g., confirmatory factor 

analysis and item response theory-based methods), leading to recommended measures for the 

selected concepts (e.g., financial well-being, financial knowledge).

Step 5: Field a third, final round of the survey in order to test its reliability and validity when 

administered over-the-phone and as a pencil-and-paper test. 

Each round of survey data will be used to assess whether the majority of respondents 

comprehended the questions and to determine if the question responses fell within the expected 

range. Psychometric analysis will reveal whether survey items are statistically valid and reliable 

measures of the key concepts (e.g., financial well-being). 

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. ]

The contractor will collect data electronically through the use of online survey software. Such 

software will help reduce errors by:

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

• randomizing how certain questions, or groups of questions, are presented (e.g., asking 

certain consumers about financial behaviors before asking about financial well-being and 

asking about financial well-being before asking about financial behaviors) to mitigate the 

effects of potential biases caused by the order the questions are presented;

• ensuring that some questions cannot be skipped; and.

• rejecting invalid responses or data entries.

Additionally, the contractor can collect data on the length of time respondents spent answering 

the survey and unit and item non-response rates. This type of information can be used to improve 

the question and answer sets. 
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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 CFPB is not aware of any similar data collection efforts aimed at testing the accuracy, 

statistical reliability, and respondent comprehension of candidate survey question and answer 

sets intended to measure financial well-being and its key drivers. 

Prior to initial development of this survey, the contractor conducted an extensive review of 

academic literature and prior surveys intending to measure individuals’ financial knowledge

4

, 

behavior5

, and overall financial capability6. While these prior studies refer to the concept of

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

measurement. Many studies in the consumer science literature have focused heavily on explicit 

financial knowledge or numeracy: e.g. asking respondents to identify the correct answer when 4 See Allgood, Sam, and William Walstad. 2011. “The Effects of Perceived and Actual Financial Knowledge on 

Credit Card Behavior.” Networks Financial Institute Working Paper 15. Indianapolis, Indiana: Networks 

Financial Institute.; Atkinson, Adele, and Flore-Anne Messy. 2012. “Measuring Financial Literacy: Results of 

the OECD / International Network on Financial Education (INFE) Pilot Study.” Finance, Insurance and Private 

Pensions Working Paper 15. Washington, D.C.: Organization for Economic Cooperation and Development.; 

Gerardi, Kristopher, Lorenz Goett, and Stephen Meier. 2010. “Financial Literacy and Subprime Mortgage 

Delinquency: Evidence from a Survey Matched to Administrative Data.” Atlanta Federal Reserve Bank 

Working Paper 2010-10. Atlanta, GA: Federal Reserve Bank of Atlanta.; Knoll, Melissa A.Z., and Carrie R. 

Houts. 2012. “The Financial Knowledge Scale: An Application of Item Response Theory to the Assessment of 

Financial Literacy.” Journal of Consumer Affairs 46(3), 381- 410.; Hilgert, Marianne A., Jeanne M. Hogarth, 

and Beverly, Sondra G,. 2003. “Household Financial Management: The Connection between Knowledge and 

Behavior.” Federal Reserve Bulletin 89: 309-322.; Lusardi, Annamaria, and Olivia S. Mitchell. 2009. “How 

ordinary consumers make complex economic decisions: Financial literacy and retirement readiness.” National 

Bureau of Economic Research Working Paper 15350. Cambridge, MA: National Bureau of Economic 

Research.; Van Rooij, Maarten, Annamaria Lusardi and Rob Alessie. 2011. “Financial literacy and stock market 

participation.” Journal of Financial Economics 101(1): 449-472.

5 See Dew, Jeffery, and Jing Jian Xia. 2011. “The Financial Management Behavior Scale: Development and 

Validation.” Journal of Financial Counseling and Planning 22(1): 43-59.; Hilgert, Marianne A., Jeanne M. 

Hogarth, and Beverly, Sondra G,. 2003. “Household Financial Management: The Connection between 

Knowledge and Behavior.” Federal Reserve Bulletin 89: 309-322.; Lynch, John G., Richard G. Netemeyer, 

Stephen A. Spiller, and Alessandra Zammit. 2010. “A Generalizable Scale of Propensity to Plan: The Long and 

the Short of Planning for Time and Money.” Journal of Consumer Research 37(1): 108-128.

6 See Taylor, Mark. 2011. The Long Term Impacts of Financial Capability: Evidence from the BHPS. Colchester, 

Essex: The University of Essex. Consumer Financial Education Body Research Report 03.; Shim, Soyeon, and 

Joyce Serido. 2011. Young Adults’ Financial Capability. Tuscan, AZ: University of Arizona. A Pathway to Life 

Success for University Students Research Brief Wave 2.
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presented with financial word problems on topics such as compound interest or inflation.7 A 

review of the broader literature on knowledge and well-being related behaviors in the education, 

psychology and health fields conducted as a part of this study suggests, however, that 

consumers’ knowledge of financial facts likely is not the sole relevant predictor of their financial

well-being. 

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 data collection is not anticipated to burden small entities because the survey will only collect 

information from individuals.

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

[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.

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.]

The CFPB would be less able to meet its obligation to develop measurable goals and objectives 

that support increasing the financial literacy of consumers, or to develop goals for programs that 

provide seniors with financial literacy and counseling, as specified by the Dodd-Frank Act, 

without undertaking the proposed surveys to develop measures of financial well-being. 

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;

 7 The best example of survey questions commonly used in other studies to measure financial literacy comes from 

Lusardi, Annamaria, and Olivia S. Mitchell. 2007. “Financial Literacy and Retirement Preparedness: Evidence and 

Implications for Financial Education.” Business Economics 42(1): 35-44.
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• 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).”]

There are no special circumstances. The collection of information is conducted in a manner 

consistent with the guidelines in 5 CFR 1320.5(d)(2).

8. Consultation Outside the Agency

[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.]
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In accordance with 5 CFR 1320.8(d)(1), the Bureau published a Federal Register Notice which notified 

the public of the CFPB’s intent to collect this survey, and provided a 60-day comment period, on XXX 

(Vol. XX, No. XXX, Pages XXXX-XXXX). 

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.”]

The incentives respondents will receive are based on their pre-existing agreements with Survey 

Sampling International (SSI) and are not specific to this survey. Survey respondents will come 

from existing panels managed by SSI. Agreements regarding incentive payments were 

established between SSI and the panelist at the time s/he was recruited. For example, when 

signing up for OpinionWorld, a panel administered by SSI, respondents can choose from a 

variety of incentives including donations to a preferred charity, entries into a drawing for a 

monetary prize, etc. SSI offers a wide variety of incentives in order to increase diversity of its

sample frames because different types of rewards will motivate different types of populations to 

participate in a survey.

Rewards offered vary by survey length and the characteristics of the population being targeted. 

SSI uses a reasonable level of reward based on the amount of effort required and subpopulation 

interests (iTunes credits are popular among younger panelists, for example). These levels in 

whatever currency was agreed for that particular respondent are set based on extensive research 

to balance motivation to respond and impact on the content of that response.

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.]

In the email invitation to the survey, respondents will be told about the study’s purpose, the 

authority under which the data are being collected, that cooperation is voluntary, that responses

will be used to produce statistical summaries only, and that identifying information, such as 

name and email address, will not be provided to the CFPB or to any third party outside of SSI8

.

 8 SSI will not share any personally identifiable information with the research team. Rather, the research team 

(CFED and its subcontractors) will only receive information on respondent demographics, along with their 

responses to the survey questions. 
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Respondents will be informed of the survey’s OMB control number, and that the CFPB cannot 

conduct the survey without the valid OMB control number. From this email invitation, 

respondents will select the link provided to enter the survey.

The CFPB has specified in its contract with the data collection contractor CFED that the CFPB 

does not own and cannot receive personally identifiable information9 in order to protect the 

privacy of respondent data and ensure the pledges of privacy made to respondents by the CFED 

research team. 

In addition, no personally identifiable information will be stored in the data file or provided to 

the contractor. Survey Sampling International protects the identifying information on its 

panelists and does not share it with any agency or company conducting research with its panel. 

This means that neither the contractor nor the CFPB will be able to reference or disclose such 

personally identifiable information about the participants. The contractor and the CFPB will 

analyze data and report results only in the aggregate. 

11. Justification for Sensitive Questions

[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, income level, employment status, gender and age. This 

information will be used to ensure that the sample population resembles the larger national 

population and to complete an analysis of differences between consumers who did and did not 

respond. Respondents will also be asked questions about their current objective financial 

circumstance (e.g., debt, credit scores, wealth, retirement savings, etc.). This information will be 

used to assess economic or normative measures of financial well-being (e.g., savings relative to 

normative targets for the consumer’s age, income, etc.).

 9 The contract language includes the following: “Contractor shall not provide CFPB any personally identifiable 

information that could reasonably be used to identify individuals participating in the project.”
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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 

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 
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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 table below presents the burden hours for the proposed survey, split up by type of 

respondent. The last phase, the implementation assessment, is expected to take less time than the 

first phases, so the table splits these respondents out. 

Task

Hours per 

Respondent

Number of 

Respondents

Burden 

hours per 

task

Working-Age Americans

Survey Phases 1 & 2: Metric 

Development & Validation - phone

17 minutes 10,000 2833.3

Phase 3: Implementation Assessment –

online/telephone/paper

15 minutes 1,500 375

Older Americans

Survey Phases 1 & 2: Metric 

Development & Validation - phone

17 minutes 5,000 1416.6

Total Burden Hours: 4625

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.)
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• 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 

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.
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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 

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.]

There will be no annualized capital/start-up costs for the government to receive the survey 

information. The testing is funded with non-appropriated funds. It will cost approximately 

$800,000 to collect and analyze these data.

The Blanket Purchase Agreement, under which the survey will be conducted, was awarded 

through a competitive bidding process.

15. Program Changes or Adjustments

[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 
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previous miscalculations in the burden estimate).]

This is the first request for a new collection. 

16. Plans for Tabulation, Statistical Analysis, and Publication

The contractor will develop measurement instruments to assess financial well-being and its 

drivers using modern measurement theory (e.g., item response theory as outlined by DeVellis 

2011 and de Ayala 2009). The contractor will begin the process by developing a large pool of 

candidate items (question and answer sets) based on the finding from qualitative research, the 

literature review, and a review of the financial well-being related surveys currently being used in 

the literature. A panel of psychometric and content experts will review and refine the pool of 

candidate items so that the remaining items are targeted and well-worded. During the next stage 

of the research, SSI will field the candidate items online to approximately 7,000 working-age and 

2,000 older Americans. Using these data, the initial item candidates will be examined using item 

response theory and classical test theory methods. Based on the results of these analyses, the 

item pool will be updated as needed (e.g., problem items reworded, additional items added, etc.). 

The items, revised when needed, will be used for a second round of data collection. The second 

round of online surveys will again be fielded to 3,000 working-age and 3,000 older Americans. 

Using the full, combined data sets the items will be evaluated using both classical test theory 

methods (e.g., coefficient alpha) and modern measurement theory methods – such as item 

response theory and confirmatory factor analysis (Hu and Bentler 1999; Joreskog and Sorbom 

2006; Netemeyer et al. 2003). The focus of these analyses will be on developing a measure with 

strong psychometric properties that can be used for experimental / intervention and survey 

research. A final implementation assessment will be conducted to validate the survey instrument 

when delivered over-the-phone or in pencil and paper form.

The CFPB anticipates that the survey (all three rounds for working age and two rounds for older 

Americans) will be completed within five months of OMB approval. The contractor will develop 

the initial analysis and summary of the study findings after data collection has been completed. 

This is to be completed within the four months after data has been collected. The CFPB may 

choose to publish the research findings.

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 CFPB plans to display the expiration date for OMB approval of the information collection 

on all instruments.
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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.]

There are no exceptions to the Certification Requirement.

Bibliography

Allgood, Sam, and William Walstad.2011. “The Effects of Perceived and Actual Financial 

Knowledge on Credit Card Behavior.” Networks Financial Institute Working Paper 15. 

Indianapolis, Indiana: Networks Financial Institute.

Atkinson, Adele, and Flore-Anne Messy. 2012. “Measuring Financial Literacy: Results of the 

OECD / International Network on Financial Education (INFE) Pilot Study.” Finance, Insurance 

and Private Pensions Working Paper 15. Washington, D.C.: Organization for Economic 

Cooperation and Development.

Cole, J. C., Rabin A. S., Smith, T. L., & Kaufman. A. S. 2004. “Development and validation of a 

Rasch-derived CES-D short form.” Psychological Assessment, 16: 360–372.

Cortina, Jose M. 1993. “Interaction, Nonlinearity, and Multicollinearity: Implications for 

Multiple Regression.” Journal of Management Vol. 19 (4): 915-922.

DeVellis, Robert F. Scale Development: Theory and Applications. Thousand Oaks, CA: Sage 

Publishers. Applied social research methods series, 26. 2012.

Dew, Jeffery, and Jing Jian Xia. 2011. “The Financial Management Behavior Scale: 

Development and Validation.” Journal of Financial Counseling and Planning 22(1): 43-59.

FLEC. Financial Literacy and Education Commission Research and Evaluation Working Group. 

2012. “2012 Research Priorities and Research Questions.” http://www.treasury.gov/resourcecenter/financial-education/Documents/2012%20Research%20Priorities%20-%20May%2012.pdf

GAO Highlights. 2011. “Financial Literacy: A Federal Certification Process for Providers Would 

Pose Challenges.” GAO-11-614 http://www.gao.gov/assets/330/320203.pdf

Gerardi, Kristopher, Lorenz Goett, and Stephen Meier. 2010. “Financial Literacy and Subprime 

Mortgage Delinquency: Evidence from a Survey Matched to Administrative Data.” Atlanta 

Federal Reserve Bank Working Paper 2010-10. Atlanta, GA: Federal Reserve Bank of Atlanta.

Knoll, Melissa A.Z., and Carrie R. Houts. 2012. “The Financial Knowledge Scale: An 

Application of Item Response Theory to the Assessment of Financial Literacy.” Journal of 

Consumer Affairs 46(3), 381- 410.
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Hilgert, Marianne A., Jeanne M. Hogarth, and Beverly, Sondra G,. 2003. “Household Financial 

Management: The Connection between Knowledge and Behavior.” Federal Reserve Bulletin 89: 

309-322.

Hu, Li-tze and Bentler, Peter M. (1999). “Cutoff criteria for fit indexes in covariance structure 

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Joreskog, K., & Sorbom, D. (2006). LISREL 8.8 user’s reference guide. Chicago, IL: Scientific

Software.

Lusardi, Annamaria, and Olivia S. Mitchell. 2009. “How ordinary consumers make complex 

economic decisions: Financial literacy and retirement readiness.” National Bureau of Economic 

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35-44.

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Generalizable Scale of Propensity to Plan: The Long and the Short of Planning for Time and 

Money.” Journal of Consumer Research 37(1): 108-128.

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Models, and Applications. Maple Grove, MN: JAM Press

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Van Rooij, Maarten, Annamaria Lusardi and Rob Alessie. 2011. “Financial literacy and stock

market participation.” Journal of Financial Economics 101(1): 449-472.
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Page 1 of 7

CONSUMER FINANCIAL PROTECTION BUREAU

INFORMATION COLLECTION REQUEST – SUPPORTING STATEMENT

PART B

DEVELOPMENT OF METRICS TO MEASURE FINANCIAL WELL-BEING OF 

WORKING-AGE AND OLDER AMERICAN CONSUMERS

(OMB CONTROL NUMBER: 3170-XXXX)

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

Instructions: The CFPB should be prepared to justify its decision not to use statistical methods 

in any case where such methods might reduce burden or improve accuracy of results. When the 

question “Does this ICR contain surveys, censuses, or employ statistical methods?” is marked

"Yes," in the Supporting Statement in Part A the following documentation should be included in 

Supporting Statement B to the extent that it applies to the methods proposed:

Note: If you do not feel this section applies, a possible response would be: “This information 

collection does not employ statistical methods.” If this is the case, you do not need to answer the 

following questions. 

1. Respondent Universe and Selection Methods

[Describe (including a numerical estimate) the potential respondent universe and any sampling 

or other respondent selection method to be used. Data on the number of entities (e.g., 

establishments, State and local government units, households, or persons) in the universe 

covered by the collection and in the corresponding sample are to be provided in tabular form for 

the universe as a whole and for each of the strata in the proposed sample. Indicate expected 

response rates for the collection as a whole. If the collection had been conducted previously, 

include the actual response rate achieved during the last collection.

The response should describe how that universe was or will be selected. The method of sampling 

should also be explained. With respect to the response rate, the narrative should cover the 

actual percentage response rate that is anticipated. Additionally, you should describe the efforts 

that will be undertaken to ensure a high response rate, including pre-survey telephone calls or 

correspondence, post-mailing reminders, etc. If correspondence will be used to boost response 

rates, copies of all letters, telephone scripts or other materials should be included in the 

package. If the collection has been conducted previously, you should provide a summary of that 

activity, including the response rate achieved.]

The Consumer Financial Protection Bureau has contracted with CFED to collect survey data to 

support the development of metrics to measure financial well-being. CFED has, in turn, 

subcontracted with Vector Psychometric Group (VPG) to conduct the psychometric analysis in 

support of the development of these metrics. VPG uses item response theory-based methods in 

its metric development process. Item response theory-based methods are not probabilistic—they 
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do not assume that the survey data being analyzed are from a random sample. Item response 

theory-based analysis does however require a large, socio-demographically diverse sample that

resembles the US population.

1 Large, diverse samples help ensure stable parameters around a 

wide-range of possible survey responses and enables analysts to test the performance of the 

metrics in different subpopulations.

CFED and its contractors will work with Survey Sampling International (SSI) to survey sample 

populations of working-age and older Americans that are sufficiently large and sociodemographically diverse to meet the needs of the project. 2 Specifically, CFED and its 

subcontractors will provide SSI with socio-demographic recruitment targets with respect to 

income, education, employment status, marital status, age, gender, race/ethnicity, presence/ages 

of children and geography. SII will recruit until the specified socio-demographic targets are met 

and then they will close the survey to those subpopulations. SSI is a global company and one of 

the largest providers of sampling, data collection and data analytics services. SSI adheres to 

World Association for Social, Opinion and Market Research (ESOMAR) standards and is Grand 

Mean audited through Sample Source Auditors and annually audited by Ernst & Young. In 

2012, SSI successfully completed 29 million surveys in 78 countries. 

SSI will collect for this project completed, online surveys from 16,500 Americans (11,500 

working-age and 5,000 older Americans) who resemble the larger U.S. population. The sampling 

universe for this study includes the approximately 163 million Americans who are age 18 and 

older and have access to the internet from some location.

3 In the future, the CFPB may field the 

survey tool developed via this requested information collection to a randomly selected, 

representative sample of the US population in order to assess the financial well-being of all U.S. 

residents. Americans ages 18 and older who have access to the internet from some location is 

therefore the appropriate potential respondent universe for the metrics testing associated with this 

project.

SSI’s sampling frame (the persons who have the potential to be part of the sample that SSI will 

collect for this study), includes “the unique audience across a set of SSI web “properties” 

[generally online advertisements] who notice the invitation to join and are motivated to act on 

it.”4

 SSI asks persons who respond to their invitations to complete a brief online survey that 

includes socio-demographic questions. After receiving the responses to this survey, SSI utilizes a 

suite of quality control procedures including digital fingerprinting, to avoid 

duplication. Additionally, SSI samples incoming participants with its blending questionnaire, 

which asks behavior and psychographic questions in order to monitor the consistency of the 

sample coming into the system. SSI’s recruitment is not limited to its proprietary online research 

 1 Here we use ‘resemble’ to describe a sample population has the same socio-demographic profile as the US 

population at large, but was not drawn at random from the US population at large. The SSI sample will be 

representative of the US population on the observable socio-economic characteristics we use to recruit the sample, 

but it may not be representative of the US population with respect to unobservable characteristics that are not part of 

this data collection.

2 ‘Working-age Americans’ include Americans ages 18-61 and ‘older Americans’ includes Americans ages 62 and 

older.

3 US Census Bureau 2012 estimates

4 See “Mixing the Right Sample Ingredients: A New Source Recipe.” Pete Cape, Kristin Cavallaro and Jackie Lorch. 

Survey Sampling International Memo.
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panels, but also utilizes relationships with certified partners, which allows them to tap into 

participants who may not want to be part of a research panel.

The sampling frames, for the purposes of this study, include working-age Americans (US 

residents ages 18 to 61) and older Americans (ages 62 and older) who are actively participating 

in an SSI panel. From these sample frames, SSI will develop “out go” or contact samples. 

Persons in the “out go” samples will receive invitations to take the surveys being fielded as part 

of this project. The contact samples will be sufficiently diverse to ensure that the eventual survey 

respondents resemble the US population at large. Because some respondents are more likely 

than others to respond to the survey participation invitation, the contact population will likely 

resemble the larger US population to a lesser degree than the population completing the surveys 

because SSI takes into account the fact that the survey take-up rate varies by subpopulation. For 

example, the contact sample is likely to contain a much larger number of males ages 18 to 24 

than females ages 45 to 54 given the differences in each group’s likelihood of responding (the 

older females being more likely to respond than the younger males). As the sample is fielded, 

SSI monitors response rates within the target demographics (age, education, income, gender, 

race/ethnicity, geography) and adjusts the outgo as necessary to ensure the resulting sample 

resembles the larger US population.

Following the psychometric analysis of the SSI samples, Vector Psychometric Group will test 

online, paper-and-pencil as well as telephonic versions of the survey tool with using a third 

sample from SSI. The sample that will be used for this testing can be relatively small and does 

not need to resemble the US population at large since the focus of the analysis will be on the 

stability of the item parameters across these different modes. 

Sample Population 

universe

SSI sampling 

frame

Persons receiving 

an invitation from 

SSI to participate 

in the survey

Number of SSIfielded 

completed 

surveys

Working-age 

Americans

~140 million 

individuals in the 

US ages 18 and 

older who access 

the internet from 

some location

1.02 million 

individuals ages 

18 and older 

participating in 

SSI panels

Approximately 

280,000 SSI panel 

participants

11,500 SSI panel 

participants 

resembling the 

US population 

ages 18-61

Older Americans ~23 million 

individuals in the 

US ages 62 and 

older who access 

the internet from 

some location

180,000 

individuals ages 

62 and older 

participating in 

SSI panels

Approximately 

120,000 SSI panel 

participants

5,000 SSI panel 

participants 

resembling the 

US population 

ages 62 and 

older

2. Information Collection Procedures

[Describe the procedures for the collection of information including:
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* Statistical methodology for stratification and sample selection,

* Estimation procedure,

* Degree of accuracy needed for the purpose described in the justification,

* Unusual problems requiring specialized sampling procedures, and

* Any use of periodic (less frequent than annual) data collection cycles to reduce burden.

Where a collection is ongoing – i.e. has been conducted previously and is continuing for the 

foreseeable future – a description of any changes that have been made in the procedures or 

statistical methodology of the collection since the last approval should be discussed.]

Vector Psychometric Group relies on item response theory-based methods in its metrics 

development process. Item response theory-based methods are not probabilistic—they do not 

assume that the survey data being analyzed are from a random sample. Item response theorybased analysis does however require a large, socio-demographically diverse sample that 

resembles the US population. Large, diverse samples help ensure stable parameters around a 

wide-range of possible survey responses and enables analysts to test the performance of the 

metrics in different subpopulations (for example, low-, middle- and high-income populations). 

The contractor will work with SSI to obtain data from 11,500 working-age Americans and 5,000 

older Americans whose socio-demographic profiles resemble that of the larger US population of 

their respective age ranges per the procedures described in section 1. 

3. Methods to Maximize Response Rates and Address Issues of Non-Response

[Describe methods to maximize response rates and to deal with issues of non-response. The 

accuracy and reliability of information collected must be shown to be adequate for intended 

uses. For collections based on sampling, a special justification must be provided for any 

collection that will not yield "reliable" data that can be generalized to the universe studied.

This question is somewhat redundant of a portion of question B.1. You should include a more 

thorough discussion of your plan of action for dealing with non-response. If the collection is 

qualitative and does not necessarily employ a sampling frame or other proven statistical 

methods, an explanation of exactly what practical utility the collection will have for the agency 

must be discussed. The discussion should include a listing of the specific uses you contemplate 

for the data collected.]

Survey respondents will come from existing panels managed by Survey Sampling International 

(SSI). Agreements regarding incentive payments were established between SSI and the panelist 

at the time s/he was recruited. For example, when signing up for OpinionWorld, a panel 

administered by SSI, respondents are able to choose from a variety of incentives including 

donations to a preferred charity, entries into a drawing for a monetary prize etc. The incentives 

respondents will receive are not specific to this survey. SSI offers a wide variety of incentives in 

order to increase diversity of its sample frames because different types of rewards will motivate 

different types of respondents to participate in a survey.
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For a survey of this length and type, a typical response rate, defined as opening the email and 

completing the survey, is roughly 3 to 5 percent. This response rate is typical of online panels. 

The participation survey rate or the percent of panelists entering survey (i.e., clicked on the link 

and made it to the survey welcome and introduction) who completed the survey is roughly 80 

percent for SSI panels. 

High response and participation rates for this study will be encouraged through several means, 

including carefully worded and market research tested invitation emails, thoughtful planning of 

the participant experience that capitalizes on the latest survey research (for example, ensuring 

that surveys conducted as part of the panel are short enough to completed before respondent 

fatigue sets in), and follow-up/reminder emails to non-respondents. In addition, SSI has a strong 

set of incentives targeted to appeal to a variety of demographic and behavioral groups to ensure 

participation without biasing results. Ensuring a quality participant experience is central to SSI’s 

survey recruitment strategy.

SSI will also try to maximize survey response rates by emphasizing the importance of this study 

in its participation invitation emails. SSI will also send reminder email to non-respondents 

offering them second and third opportunity to participate. 

Issues of non-response will also be addressed through a comparison of responders to nonresponders to determine whether there were any particular types of consumers who elected to 

respond or not. Consumer characteristics available for non-response analysis will include age, 

gender, income, education, geography, and race/ethnicity. Analyses of drop-out point will also 

be conducted to determine email invitation open rate, survey entry from the invitation, survey

initiation, and high exit points in the survey itself. CFED and its subcontractors will use these 

data to improve the quality of the survey.

4. Testing of Procedures or Methods

[Describe any tests of procedures or methods to be undertaken. Testing is encouraged as an 

effective means of refining collections of information to minimize burden and improve utility. 

Tests must be approved if they call for answers to identical questions from 10 or more 

respondents. A proposed test or set of tests may be submitted for approval separately or in 

combination with the main collection of information.

The response should fully describe any planned tests of the collection, including who is in the 

test sample, how they were chosen, what evaluation criteria for the test will be or were used, and 

specific comments from the participants of the test. If applicable, a summary of how the 

collection instrument.]

The entire purpose and planned process for this information collection is to test and refine data 

collection procedures and methods such as wording of survey questions and answer sets, and 

method of fielding the survey (online vs. telephone vs. paper and pencil). The contractor will 

develop metrics to assess financial well-being and its drivers using item response theory-based 

methods (see DeVellis 2011 and de Ayala 2009). The contractor will begin the process by 

developing a large pool of candidate items (question and answer sets) based on the finding from 

qualitative research, the project literature review, and a review of other financial well-being 
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related surveys. A panel of psychometric and content experts will review and refine the pool of 

candidate items so that the remaining items are targeted and well-worded. During the next stage 

of the research, SSI will field the candidate items online to approximately 7,000 working-age and 

2,000 older Americans. Using these data, the initial item candidates will be examined using item 

response theory and classical test theory methods. Based on the results of these analyses, the 

item pool will be updated as needed (e.g., problem items reworded, additional items added, etc.). 

The items, revised when needed, will be used for a second round of data collection. The second 

round of online surveys will again be fielded to 3,000 working-age and 3,000 older Americans.

Using the full, combined data sets the items will be evaluated using both classical test theory 

methods (e.g., coefficient alpha) and modern measurement theory methods – such as item 

response theory and confirmatory factor analysis (Hu and Bentler 1999; Joreskog and Sorbom 

2006; Netemeyer et al. 2003). The focus of these analyses will be on developing a measure with 

strong psychometric properties that can be used for experimental / intervention and survey 

research. A final implementation assessment will be conducted to validate the survey instrument 

when delivered over-the-phone or in pencil and paper form.

5. Contact Information for Statistical Aspects of the Design

[Provide the names and telephone numbers of individuals consulted on statistical aspects of the 

design and the name of the agency unit, contractor(s), grantee(s), or other person(s) who will 

actually collect and/or analyze the information for the agency.]

[OMB-OIRA has produced a number of documents that may serve as useful reference material 

for completing Supporting Statement B. These can be found at:

http://www.whitehouse.gov/omb/inforeg_statpolicy ]

Missy Amish, Survey Sampling International, 203-246-6051, Darci.Patrick@SurveySampling.com

Anita Drever, Corporation for Enterprise Development, 202-027-0142, adrever@cfed.org

Dee Warmath, Center for Financial Security, University of Wisconsin Madison, 

262-312-0606, warmath@wisc.edu

R.J. Wirth, Vector Psychometric Group, 919-768-7142, RJWirth@VPGCentral.com

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