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BUREAU OF CONSUMER FINANCIAL PROTECTION

PAPERWORK REDUCTION ACT SUBMISSION

INFORMATION COLLECTION REQUEST

SUPPORTING STATEMENT PART B

Generic Information Collection Plan for Surveys Using the Consumer Credit Panel

(OMB CONTROL NUMBER: 3170-XXXX)

1. Respondent Universe and Selection Methods

The CFPB has acquired a nationally representative sample of de-identified consumer credit 

records (the “Consumer Credit Panel” or “CCP”) from one of the three national credit reporting 

agencies. The sample comprises a 1-in-48 random sample of all credit records drawn from the 

credit reporting agency’s archive from December 2012. The resulting sample includes 

approximate 5 million de-identified credit records representing the universe of approximately 

240 million credit records. At the end of each calendar quarter, the CFPB receives updated 

credit records for these sampled consumers (if available) and a 1-in-48 sample of credit records 

that were newly created since the previous quarter. This sampling process was designed to 

provide an ongoing panel of credit records that remains representative of the universe of credit 

records at each point in time. The contract with the credit reporting agency also allows for CFPB 

testing to verify that the panel remains representative. 

The de-identified credit records that the CFPB receives carefully exclude any direct 

identifying information in order to maintain the anonymity and protect the privacy of sampled 

customers. The records include information about the credit accounts, such as mortgages and 

credit cards, which are included in each consumer’s credit record (though the identity of the 

creditor is excluded from the information the CFPB receives). Also included is information about 

non-credit-related debts that have been reported by third-party collection agencies, monetary-related 

public records (such as tax liens and bankruptcy filings), and details of any credit record inquiries 

made by lenders in response to an application for credit. The credit information in the CCP is used 

to monitor conditions in consumer credit markets, to study consumer behavior regarding credit, 
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to evaluate the effects of consumer regulations, or to address other issues in support of the 

Bureau’s research, monitoring, and supervisory missions.1

The potential respondent universe will include borrowers with credit records in the CCP, but 

the specific universe may vary depending on the research question addressed. For example, the 

CCP could be used as a sampling frame for surveys with a target population of U.S. borrowers 

(individuals with a credit record) at a point in time or a target population of borrowers who 

recently took out a specific type of debt. The information available in the CCP would generally 

allow for stratification by, for instance, geography or credit score. Survey weights would reflect 

the sample design and would be adjusted to account for systematic differences in nonresponse 

along dimensions measured in the CCP.

2. Information Collection Procedures

As described above, we plan to randomly survey individuals with credit records that are 

included in the CCP. For each survey conducted under this generic clearance, unique record 

locators assigned to sampled credit records will be sent to the credit reporting agency along with 

a survey instrument that has been designed by the CFPB staff. The credit reporting agency will 

identify the consumers associated with each sampled credit record and will mail the survey 

instrument. The credit reporting agency’s subcontractor will receive the responses that are 

received either by mail or online, remove any direct identifying PII that may have been included 

in the consumer’s response, and send the de-identified data in electronic form to the CFPB. 

This process, which has been successfully pilot tested for the National Survey of Mortgage 

Borrowers (NSMB), allows the Bureau to survey consumers without revealing direct identifying 

PII to the CFPB.

The NSMB also illustrates the types of contact and incentive protocol that might be used for 

surveys conducted under this generic clearance. The field period for the NSMB is eight weeks 

and includes up to four first-class mailings. All sampled consumers receive an initial mailing 

that includes a cover letter introducing the survey along with a paper questionnaire, postage-paid 

return envelope, and five dollar cash incentive. A reminder letter is sent one week later. In week 

 1 Similar datasets are used by the Federal Reserve Board and the Office of the Comptroller of the Currency, so the 

CFPB is not unique among regulatory agencies in collecting this type of information in order to inform its 

policymaking.
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five, consumers who have not yet completed the survey or opted out receive a second reminder 

letter with a replacement questionnaire, postage-paid return envelope, and five dollar incentive, 

and a final reminder letter is sent to remaining nonrespondents in week seven. 

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

Obtaining sufficiently high response rates is a challenge for any survey. The CFPB intends 

to include a cash incentive with each survey to boost response rates. Additionally, the Bureau will 

incorporate lessons learned by the National Mortgage Database (NMDB)2 pilot team, comprised of 

staff from the CFPB, Freddie Mac, and the Federal Housing Finance Agency, which has pilot-tested 

a similar methodology for new or delinquent mortgage borrowers. Further, the Bureau believes that 

response rates can be improved through careful design of survey instrument and clear 

communication to potential respondents about the survey’s purpose, use, and confidentiality 

protections. Finally, because we will have the de-identified credit records of both respondents 

and non-respondents to the survey, we anticipate using this information to model survey 

nonresponse and to adjust sample weights to ensure the results of any analysis are not biased by 

correlation between nonresponse and observable credit characteristics. 

The extensive information from the de-identified credit records for both respondents and 

nonrespondents will provide a strong basis for investigating potential nonresponse bias relative 

to the CCP. The data will, for example, permit us to examine differential rates of nonresponse 

correlated with credit score, dollar amounts of various types of credit lines, and demographics. 

Based on this analysis, the CFPB will also construct survey weights so that the survey will be 

representative of American consumers in the target population for a given survey. The 

nonresponse bias analyses will be of benefit to other federal agencies using samples based on 

commercially-available administrative data.

For survey respondents, the CFPB will additionally be able to compare the self-reported 

demographic information in the survey (for example, education, age, and marital status) to the 

auxiliary demographic information included in the credit-record database. This comparison may 

 2 The National Mortgage Database (OMB No. 2590-0012) is a joint effort of FHFA and the CFPB and is a uniquely 

comprehensive database of information on the residential mortgage origination market. A key purpose of the 

NMDB is to make accessible accurate, comprehensive information for monitoring the residential mortgage market. 

The need for the NMDB grew out of the subprime mortgage crisis that began in the United States in 2007. The 

subprime crisis, and the financial crisis that followed, revealed the extent to which regulators lacked sufficient data 

to foresee and adequately respond to a crisis in the mortgage markets.
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shed light on the reliability of such auxiliary data and, thus, provide information that may be 

valuable to government researchers and others that rely on such data when direct measures of 

these characteristics are unavailable. Further, while the questions are not identical, comparing the 

answers of survey respondents to related credit and debt information in the CCP will shed further 

light on the quality of self-reported data relative to the credit-record database. This analysis will 

be of use to other federal agencies considering supplementing or replacing survey data with data 

from commercially-available administrative sources. 

4. Testing of Procedures or Methods

The CFPB generally plans to test survey instruments on a small scale prior to their use in 

full-scale surveys, for example through cognitive pretesting or by releasing a fraction of the 

surveys initially and reviewing the responses for evidence of serious shortcomings in the 

instrument before sending surveys to the majority of selected respondents. These techniques are 

meant to reduce the total public burden of the information collection by ensuring that large-scale 

information collection is optimized. 

5. Contact Information for Statistical Aspects of the Design

The name and telephone numbers of these individuals will be provided in the clearance 

request for each specific data collection.

The Office of Research is currently staffed with over 20 employees with PhD’s in the social 

sciences, who are trained in relevant methods. For any research studies that employ statistical 

methods submitted for approval under this generic information collection plan, such methods 

will be reviewed by a qualified statistician for scientific rigor; including compliance with the 

OMB’s statistical program and standards prior to submission to OMB.