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CONSUMER FINANCIAL PROTECTION BUREAU

INFORMATION COLLECTION REQUEST –

DEBT COLLECTION SURVEY FROM THE CONSUMER CREDIT PANEL

(OMB CONTROL NUMBER: 3170-XXXX))

Supporting Statement – Part B 

1. Respondent Universe and Selection Methods

The Bureau recently 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. This sample is comprised of 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 approximately 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 on-going 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 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 consumers. The records include information about the credit accounts, such 

as mortgages and credit cards, that 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 thirdparty collection agencies, monetary-related public records (like 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, to evaluate the 
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effects of consumer regulations, or to address other issues in support of the Bureau’s 

research, monitoring, and supervisory missions.1

We plan to randomly select borrowers from the most recent quarter of the CCP to 

receive a survey. This process will oversample credit records with recent third-party 

collections for non-credit-related debts. The sample will also include credit records with 

no evidence of such collection activity; among this group, we are considering 

oversampling credit records with loan payments that are past due or other indicators that 

may indicate a greater likelihood of having debt collections that are not reported to the 

credit reporting agencies. Sample weights for analyzing the survey data will account for 

the sample design.

To the best of our knowledge, no survey like this of debt collections has 

previously been attempted. The closest effort in approach is likely the pilot of the 

“continuation survey” of the National Survey of Mortgage Borrowers conducted by 

Freddie Mac. The continuation survey was sent to mortgage borrowers with an 

oversampling of consumers who were delinquent on their mortgages. Like the survey the 

CFPB seeks PRA approval to conduct, Freddie Mac’s survey was a mail survey sent to 

consumers who were randomly selected from a sample of credit records. The 

continuation survey oversampled mortgage borrowers who were delinquent on a 

mortgage. While this survey remains in the field, the response rate to date has been about 

33 percent. Since we are also surveying consumers who do not have mortgages and who 

therefore may be more mobile and harder to contact, we expect a lower rate of response 

to our survey.

2. Information Collection Procedures

As described in the question above, we plan to randomly select approximately 

10,000 credit records from the CCP. Unique record locators assigned to these credit 

 

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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records will be sent to the credit reporting agency along with a survey instrument that has 

been designed by CFPB staff. The credit reporting agency will identify the consumers 

associated with each sampled credit record, and mail the survey instrument. The credit 

reporting agency’s subcontractor will receive the responses that come in either by mail or 

online, strip off any direct identifying PII that may have been included in the consumer’s 

response, and send the de-identified information to the CFPB. This process, which has 

been successfully pilot tested for the National Survey of Mortgage Borrowers, allows the 

CFPB to survey consumers without revealing direct identifying PII directly to the 

Bureau.

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)2pilot 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, 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 

survey is representative of American consumers. Finally, as noted below, the CFPB is 

considering examining the effects of alternative versions of the required Privacy Act 

Statement on survey nonresponse.

4. Testing of Procedures or Methods

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

 

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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full-scale experiments. These techniques are meant to reduce the total public burden of the 

information collection by ensuring that the large-scale information collection is optimized. 

In addition, the CFPB is considering examining whether differences in, say, the length of the 

Privacy Act Statement affect survey nonresponse. The CFPB understands that there has been 

limited research on this and related questions. If the CFPB concludes it is feasible and 

valuable to conduct this research in the context of this survey, the CFPB anticipates that it 

would likely randomize across two versions of the Privacy Act Statement of differing length 

as well as, possibly, the location of the statement (for example on the inside of the first page 

or the back page). To mitigate the potential effects of this experiment on overall survey 

response rates in the event there are sizable differences in response rates, the majority (say, 

80 or 90 percent) of sample cases would be assigned the version that the CFPB believes is 

more likely to produce a higher response rate.

5. Contact Information for Statistical Aspects of the Design

Ken Brevoort (Supervisory Economist, Office of Research, CFPB) 

Brian Bucks (Economist, Office of Research, CFPB) 

Mick Couper (Research Professor, University of Michigan and Joint Program in 

Survey Methodology)