DRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 1 of 20 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 explanatio n. 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 an y 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.

• T ry 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 :

“ E xplain 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 co ntext around an information collection.

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

.DRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 2 of 20 ABSTRACT: Under the Dodd

- Frank Wall Street Reform and Consumer Protection Act, Public

Law No. 111

- 203, the Bureau’s Office of Financial Education (“OFE”) is responsible for developing and implementing a strategy to improve the financial literacy of consumers that

in cludes measurable goals and initiatives, in consultation with the Financial Literacy and Education Commission, consistent with the National Strategy for Financial Literacy. In addition, the Office of Financial Protection for Older Americans (OA) within th e CFPB is charged with conducting research to identify methods and strategies to educate and counsel seniors, and developing goals for programs that provide seniors with financial literacy and counseling.

The CFPB intends to collect quantitative data thr ough 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 well

being. The primary ant icipated 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 t hat 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 prov ision 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
literac y 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 20DRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 3 of 20 Research, for conducting research related to financial education and counsel ing. 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 program s 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
ed ucation 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 abou t 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 well

being and whether it is relatively more important in this respect than, for example, n umeracy, 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 th e 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 Proje ct 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

fin ancial 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 Challenge s (June 28, 201 1), available at http://www.gao.gov/assets/330/320203.pdf.

3 Financial Literacy and Education Commission, 2012 Research Priorities and Research Question , available at http://www.treasury.gov/resource

- center/financial

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

- %20May%2012.pdfDRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 4 of 20 should significantly increase the ability of the CFPB, other FLE C 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 collect ion:

(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 in form 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 hypot heses 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 educ ation 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 Consum ers,” 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 descri be 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 forDRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 5 of 20 OMB’s approval

.

• How will the information be collected (e.g., forms, non

- forms, electronically, face

- to

face, 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 info rmation 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 eva luated 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, t he
CFPB has contracted with the Corporation fo r Enterprise Development (CFED). CFE D, in turn,
has subcontracted with the Center for Financial Security at the University of Wisconsin

- Madison (CFS) and Vec tor 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 a pproximately 16,500 surveys that will be completed by a sample of Ame ricans 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 p encil

- paper) ;

 1 1,500 surveys will be completed by working

- age Americans (ages 18

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

.

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

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

.

Working

- Age American S amples

SSI will administer three rounds of surveys to working

- age Americans . No respondent will be asked to take more than one survey. The first round will consist of 7,00 0 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 phoneDRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 6 of 20 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 S amples

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

Information to be Collected

E ach 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 dep endent), and general geographic region (urban, suburban, or rural). If SSI already has this information from

resp ondents and it is up to date, SSI will not include these questions in the survey. No personally identifiable information will be collected. In addition to demographic information, each iteration of the survey will ask questions in the following types of conceptual areas :

• financial well

- being ;

• financial and general knowledge;

• financia l behaviors and decisions;

• personality traits; and

• social context.

The goal of these surveys is to de velop a final set of items (question and answer sets) to measure each concept. These items should be easily comprehended by the average American consumer and should provide a statistically reliable measure of each concept. To achieve this goal, an iterative process is used with continuous refinement of the wording of each item , as well as a weeding out of poor or irrelevant items. Individual question and answer sets may change each time the survey is fielded based on the analysis of the results of the pr evious 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 litera ture review and

qua litative research undertaken in a previous phase of the project

.

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

.

Step 3: Fie ld the first round of the survey online to test the items and use psychometricDRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 7 of 20 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 sur vey 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 question s and to determine if the question responses fell within the expected

range. Psychometric analysis will reveal whether survey items are statistically valid and reliable
measures of the ke y 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:

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

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

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

• r ejecting invalid responses or data entries

.

Additionally, the contractor can collect data on the length of time 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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Page 8 of 20 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 i t 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 ans wer 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 knowled ge 4

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

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

measurement

. Many studies in the consumer science literature have focused heavily on explicit financial knowledge or numeracy : e.g. asking respondents to identify the correct answer when

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.: Org anization 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

Wor king 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. 200 9. “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 Finan cial 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., Richa rd 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 Im pacts 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 Ar izona. A Pathway to Life Success for University Students Research Brief Wave 2.DRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 9 of 20 presented with financial word problems on topics such as compound interest or inflation. 7 A
review of the broader literature on k nowledge 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

- bei ng

.

5. Efforts to Minimize Burdens on Small Entities

[

If the collection of information impacts small bus inesses 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 a nd Obstacles to Burden Reduction

[

Describe the consequence to Federal program or policy acti vities 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 s pecified by the Dodd

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

- being

.

7. Circumstances Requiring Special Information Collection

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

in a mann er:

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

• R equiring 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 Lite racy and Retirement Preparedness: Evidence and Implications for Financial Education.” Business Economics 42(1): 35

- 44.DRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 10 of 20 • R equiring respondents to submit more than an original and two copies of any document;

• R equiring respondents to retain records, other than health, medical, government

contract, grant

- in

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

• I n conne ction with a statistical survey that is not designed to produce valid and reliable results that can be generalized to the universe of study;

• R equiring the use of a statistical data classification that has not been reviewed and approved by OMB;

• T hat 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

• R equiring 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 recei ved in response to that notice and in response to the PRA statement associated
with the collec tion 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 b e circumstances that may preclude consultation in a specific situation. These circumstances should be explained. ]DRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 11 of 20 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 coll ect 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 respon dents.”]

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 regardi ng 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 pr eferred 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 i n 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 p anelists, 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 SSI 8

.

8 SSI will not share any personally identifiable information with the research team. Rather, the research team (CFED and it s subcontractors) will only receive information on respondent demographics , along with their responses to the survey questions

.DRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 12 of 20 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 tha t the CFPB does not own and cannot receive personally identifiable information 9 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, n o personally identifiable inf ormation 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 th at 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 Regi ster, 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 co mplete 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.”DRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 13 of 20 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 comple xity, 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 separ ate 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

contractin g 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 requi rements). 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 burd en (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 mul tiple 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 im pact 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 gr oup 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 als o 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 timeDRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 14 of 20 requirements associated with each method of collection. This can als o 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 th an 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 fee ls 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 tim e 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 impleme ntation 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 .)DRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 15 of 20 • 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 p eriod 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 fac ilities.

• 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 rul emaking 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 a ssociated 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 determi ne 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 Gove rnment

[

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 suppor t staff), and any other expense that
would not have been incurred without t his collection of information.DRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 16 of 20 The response should include the ACTUAL costs the CFPB will incur as a result of implementing this information collection. The estimate should includ e 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 materia ls 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

• E mployee (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 sta tement 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 b urden 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 ch ange 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 fu nding 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 toDRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 17 of 20 previous miscalculations in the burden estimate). ]

This is the first request f or 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 develop ing 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 a nd 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 ,0 00 ol der 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, addit ional 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 fie lded to 3,000 working

- age and 3,0 00 older Americans. Using the full, combined data sets the it ems 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 instrum ent when delivered over

- the

- phone or in pencil and paper form.

The CFPB anticipates t hat the survey (all three rounds for working age and two rounds for older
Americans ) will be completed within five months of OMB approval. The contractor will develop
the initial analysis and summary of the study findings after data collection has been completed.
This is to be completed within the four months after data has been collected. The CFPB may choose to 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.DRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 18 of 20 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 exception s, 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) Pi lot 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/resource

center/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: Eviden ce 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 Respo nse Theory to the Assessment of Financial Literacy.” Journal of Consumer Affairs 46(3), 381

- 410.DRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 19 of 20 Hilgert, Marianne A., Jeanne M. Hogarth, and Beverly, Sondra G,. 2003. “Household Financial Management: The Connection between Knowledge and Behavior.” Feder al Reserve Bulletin 89:
309

- 322.

Hu, Li

- tze and Bentler, Peter M. (1999). “Cutoff criteria for fit indexes in covariance structure analysis: Conventional criteria versus new alternatives.” Structural Equation Modeling Vol. 6 (1): 1

– 55.

Joreskog, K., & Sor bom, 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 Research Working Paper 15350. Cambridge, MA: National Bureau of Economic Research.

Linacre, John M. 1999. “Understanding Rasch measurement: Estimation methods for Rasch

measures.” Journal of Outcome Measurement Vol. 3(4): 382

- 405.

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

- 44.

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

- 128.

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

Nunnally, Jum C and Bernstein, Ira H. 1994. Psychometric Theory . New York, New York:

McGraw

- Hill. 1994.

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.

Smith, Everett V and Smith, Richard M. 2004. Introduction to Rasch Measurement: Theory, Models, and Applications. Maple Grove, MN: JAM Press

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.DRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 20 of 20 Van Rooij, Maarten, Annamaria Lusardi and Rob Alessie. 2011. “Financial literacy and stock
mark et participation.” Journal of Financial Economics 101(1): 449

- 472

.DRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

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 ma rked "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 corr esponding 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 th e 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 wi ll 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 th e 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

— theyDRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 2 of 7 do not assume that the survey data being an alyzed are from a random sample. Item response theory

- base d analysis does however require a large, socio

- demographically diverse sample that

resembles the US population

. 1 L arge, diverse samples help ensure stable parameters around a wide

- range of possible survey responses and enabl es 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 socio

demographically 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 st atus, 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 A uditors 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 1 6

, 5 00 Americans (1 1

, 5 00 working

- age and 5,000 older Americans) who resemble the larger U.S. population. The sampling
universe for this study includes the approximately 1 63 million Americans who are age 18 and
older and have access to the internet from some location

. 3 In the future, t he 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 s ample 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 a sks persons who respond to their invitations t o 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 t he 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 a t 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 unobserv able 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

.DRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 3 of 7 panels, but also utilizes relationships with certified partners, which allows them to tap into participants who may not want to be par t of a research panel.

The sampling frame s , 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 en sure that the eventual survey respondents r esemble 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 complet ing 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 to ol 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 th ese different modes

.

Sample Population
universe SSI sampling
frame Persons receiving
an invitation from SSI to participate in the survey Number of SSI

fielded completed

surveys

Working

- age Americans ~140 million
individuals in the US ages 18 and
older who access
the internet from
some location 1. 0 2 million individuals ages
18 and older participating in SSI panels Approximately

28 0,000 SSI panel participants 1 1 ,500 SSI panel participants resembling the US populati o n

age s 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

6 2 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:DRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 4 of 7 * 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 Psychome tric 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 theory

based analysis does however require a large, socio

- demographically diverse sample that
resembles the US population. L arge, diverse samples help ensure stable parameters around a
wide

- range of possible survey responses and enables analysts to test the performan ce of the metrics in different subpopulations (for example, low

- , middle

- and high

- income populations).

The contractor will work with SSI t o obtain data from 11,500 working

- age Americans and 5,000
older Americans whose socio

- demographic profiles resemb le that of the la rger 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" da ta 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 Opini onWorld, 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.DRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 5 of 7 For a survey of this length and type, a typica l 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 m ade 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 te sted 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), an d 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 experienc e 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 s econd and third opportunity to participate.

Issues of non

- response will also be addressed through a comparison of responders to non

responders to determine whether there were any particular types of consumers who elected to respond or not. Consumer char acteristics 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 sub mitted 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 t est 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 pr ocedures 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 we ll

- 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

- beingDRAFT VERSION FOR 60 DAY NOTICE, WILL FINALIZE FOR 30 DAY NOTICE

Page 6 of 7 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 ap proximately 7,000 working

- age and 2,0 00 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 n eeded (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 fie lded to 3,000 working

- age and 3,0 00 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; J oreskog 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 b e 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 name s and telephone number s 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,

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