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BUREAU OF CONSUMER FINANCIAL PROTECTION

PAPERWORK REDUCTION ACT SUBMISSION

INFORMATION COLLECTION REQUEST

SUPPORTING STATEMENT PART A Supporting Statement – Part B

CFPB Generic Information Collection Plan for Studies of Consumers using Controlled 

Trials in Field and Economic Laboratory Settings

(OMB CONTROL NUMBER: 3170-XXXX)

1. Respondent Universe and Selection Methods

The potential respondent universe will vary depending on the research question 

addressed and method of data collection employed. All samples under this generic clearance 

will be purposive and non-representative.

2. Information Collection Procedures

The CFPB plans to gather primary data from purposive samples through controlled 

trials in field and economic laboratory settings. The sections below outline the types of data 

collections that the Bureau plans to conduct.

Trials may be broadly categorized into laboratory and field settings.

A laboratory setting provides researchers with a high degree of control over the 

research environment for a wide range of possible studies. Participants may be placed in 

situations that isolate features of economic activity or decision-making to be studied in 

detail. The researcher may have them interact to provide insight into how people share 

information, solve problems, and make choices in competitive or cooperative environments.

One advantage of the lab setting is standardization. The researcher can ensure that 

participants are given the same instructions, placed in similar contexts, and otherwise treated 

the same way. Respondents are often asked to use computer software or online resources in 
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order to standardize their experience and reduce measurement error in collecting their 

responses. For example, online lab settings are growing in popularity for this reason, and the 

CFPB may employ this type of setting for a lab study.

Another benefit of the lab setting is the quantity and quality of possible observations. 

Researchers may reproduce events in the lab that occur sporadically or unpredictably in a 

real world setting and would otherwise be difficult to observe. A lab setting may also 

facilitate collection of data on gaze (enabling inferences about attention) and on reaction 

times (enabling inferences about the ease of processing information). 

Subjects for lab research are typically recruited using convenience sampling, so the 

samples may not represent the general population, and therefore are not useful for estimating 

specific parameters or the costs and benefits of any given intervention or idea. Although this 

may introduce selection bias that could limit the applicability of the lab findings to other 

contexts, in many cases a laboratory provides a credible economic environment where the 

results of the study can be useful for predicting behavior outside the lab. The sign or 

direction of the effect frequently carries over to a more general population. For example, if a 

laboratory study showed that one disclosure format resulted in decisions different than 

another disclosure format, we could reasonably expect that the pattern may remain among 

other populations. This ability to generalize is important given that particular subpopulations like students, service-members, or older Americans are frequently of interest to 

the CFPB.

A field setting allows researchers to see how economic activity operates in real world 

environments. It generally allows for research studies to occur over a longer period of time 

than in a lab. Respondents may be recruited from a variety of sources, including through 

web panels and existing channels of economic interaction; for example, users of a given 

financial product or service. Outcome data generally comes from some mix of existing 

administrative sources, which do not burden the participants, and from data collection 

instruments that are designed to gather the minimal amount of additional data required to 

conduct the research.

The CFPB plans to use research studies under the proposed clearance to learn about 

behavior in markets and to test research hypotheses. Results and findings from these 
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research studies are designed to be used for developmental and informative purposes. The 

CFPB does not intend to make regulatory decisions solely based on these studies or use 

these studies to develop or evaluate specific policies.

Studies will often take the form of a randomized controlled trial (RCT).

Identifying causation is often essential in research to determine the effects on 

consumers of a particular factor; for example, a financial product, disclosure form, or 

financial education training. In observational studies, there is often reason to believe that 

people who differ in exposure to the factor of interest also differ in other ways. For example, 

consumers who use a particular strategy for managing their finances may, on average, differ 

in many characteristics (education, employment status, income, etc.) from those who do not. 

In such a case, it would be incorrect to conclude that the financial strategy alone accounted 

for differences in outcomes between those who use it and those who do not. 

Failing to account for relevant characteristics leads to bias in a researcher’s estimate 

of whether a causal relationship exists and how strong or statistically significant it is. Since 

many of these characteristics are unobservable to the researcher, observational studies pose 

problems for causal inference.

In general, researchers are unable to observe a counterfactual for a given person; that 

is, they cannot observe what the outcome would have been if a person not exposed to the 

factor had been exposed and vice versa. Randomization of research participants into a 

treatment group that is exposed to the factor and a control group that is not exposed or is 

exposed to a lesser extent allows the researcher to determine whether the observed outcomes 

were caused by the factor.

A randomized controlled trial (RCT) is designed to overcome the selection bias 

problem. It uses a control group as a valid counterfactual for the treatment group. For a 

sufficiently large sample, the treatment and control groups will look very similar to one 

another since no participant characteristics are used in a random assignment, other than 

possibly in a stratified approach where they are in fact balanced by construction. This 

similarity can be verified for observable characteristics and safely assumed for unobservable 
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characteristics. Differences in outcomes observed after comparing treatment and control 

groups are therefore attributable to the treatment factor.

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

Recruitment of subjects for lab research projects typically involves convenience 

sampling, which does not yield a sample that is representative of the general population. 

Small-scale field studies by design will include purposive samples and therefore are not 

necessarily externally valid beyond the population from which those samples are drawn. 

This generic clearance will not be used in cases where it is especially important to be 

representative of a specific population (ex: all Americans or another population of 

regulatory interest). These studies will be used primarily for developmental and informative 

purposes, and will not be intended as the main source for making regulatory decisions or a 

basis for specific policy at the Bureau.

4. Testing of Procedures or Methods

The CFPB plans to use pretesting and cognitive interviewing to test research 

instruments on a small scale prior to their use in full-scale research studies. Respondents will 

be debriefed after pilot to ensure that they understood the instrument, which in turn ensures 

that the resulting data collections are effective. These techniques are meant to reduce the 

total public burden of the information collection by ensuring that the full study 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 twenty employees with PhD’s 

in social science, who are trained in relevant methods. For any research studies that employ 
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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 Office of Management and Budget’s (OMB) statistical programs and 

standards prior to submission to OMB.