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CONSUMER FINANCIAL PROTECTION BUREAU

INFORMATION COLLECTION REQUEST – SUPPORTING STATEMENT

PROGRAM EVALUATION OF 

FINANCIAL EMPOWERMENT TRAINING PROGRAMS

(OMB CONTROL NUMBER: 3170-XXXX)

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

ABSTRACT: The Bureau’s Office of Financial Empowerment (Empowerment) is responsible 

for developing strategies to improve the financial capability of low income and economically 

vulnerable consumers. The proposed collections will focus on evaluating (1) training practices 

and programs that are designed to enhance the ability of caseworkers to inform and educate low 

income consumers about managing their finances and strategies for making choices among 

available financial products and services available to them; (2) the evaluation tool that the 

trainers will use to determine the effectiveness of the training; and (3) the scope of workshop 

participants’ use of the training. The Bureau expects to collect qualitative data through paperbased surveys and focus groups. The information collected through qualitative evaluation 

methods will increase the Bureau’s understanding of what elements of training programs and 

practices can improve caseworker interaction with and assistance to their clients in ways that can 

improve outcomes for consumers, particularly those who have low incomes.

A. JUSTIFICATION 

1. Circumstances Necessitating the Data Collection

The Consumer Financial Protection Bureau’s (CFPB or Bureau) Office of Financial 

Empowerment (Empowerment) is responsible for developing strategies to improve the financial 

capability of low income and economically vulnerable consumers, such as consumers who are 

unbanked or underbanked, those with thin or no credit file, and households with limited savings.

Under the Dodd-Frank Wall Street Reform and Consumer Protection Act, Public Law No. 111-

203 (Dodd-Frank Act), including Section 1013(b)(2), Empowerment has a mandate to “provide

information, guidance, and technical assistance regarding the offering and provision of consumer 

financial products or services to traditionally underserved consumers and communities.” To 

fulfill this mandate, Empowerment has a need to evaluate training programs and practices 

involved in training front-line case managers in order to provide relevant and effective 

information, guidance, and technical assistance designed to improve the financial outcomes and 

capability of these vulnerable consumers.

Through this collection, data will be collected from two sets of respondents. The first is a pilot

cohort of trainers, some of whom will participate in an initial web-based training and others of 

whom will participate in face-to-face training provided by the CFPB’s contractor working with 

Empowerment on this effort. The second respondent group is comprised of front-line case 

managers who will subsequently be trained by members of the cohort. The primary resource 
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used during these trainings will be a financial empowerment training (FET) toolkit that has been 

developed by CFPB. (Note that, while the toolkit is referred to throughout this document as the 

FET Toolkit, it has the working title “Your Money, Your Goals: A Financial Empowerment 

Toolkit for Social Services Programs.”)

Collecting data from these two groups through a pilot implementation of the FET toolkit is a 

necessary step in ensuring that the toolkit is as useful and relevant as possible to the larger 

financial social services community, and that it advances Empowerment’s mission to help 

consumers find and access affordable financial products and services that meet their needs for 

credit, payments and transactions, and savings.

2. Use of the Information

Staff from CFPB will use data from surveys and focus groups of participants to assess the 

effectiveness of the training practices and resources used in this pilot implementation. The 

resources are designed to enhance the ability of caseworkers to inform and educate low income 

consumers about managing their finances and strategies for making choices among available 

financial products and services available to them. The results of this analysis will inform the 

CFPB’s subsequent revisions to the FET toolkit. Data that are collected through case manager 

logs will also provide information about the scope of workshop participants’ use of the training.

Information collected is not meant to be, and will not be treated as, a sample that is statistically 

generalizable to the overall American population, or to the general population of front-line case 

managers working in the United States.

3. Use of Information Technology

Almost all of the data for this collection will be collected will be through paper instruments. 

CFPB determined that asking cohort members and case managers to submit data through paper 

instruments would be less burdensome than asking them to do so electronically, primarily 

because of the respondent burden associated with tracking electronic responses.

4. Efforts to Identify Duplication 

Because this data collection is connected to a pilot implementation of the FET toolkit which 

CFPB have developed over the past seven months, it will not be duplicative of any previous 

research that has been conducted within or outside of the government. CFPB staff are cognizant 

of current research being done in the field of effective case manager training and financial 

empowerment, and this research has informed the development of the toolkit. The CFPB will 

continue to monitor research on these topics to ensure that the techniques used in this data 

collection are informed by those efforts and reflect current knowledge and best practices and are 

not duplicative.
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5. Efforts to Minimize Burdens on Small Entities 

The data collection is not anticipated to burden small entities because all information collection 

will occur from individuals. Further, all instruments have been reviewed to ensure that only 

necessary data are collected.

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

This data collection effort is part of a pilot implementation of a new model for case manager 

financial empowerment training. Because it is part of a pilot study, the data collection will only 

be conducted once; CFPB staff do not plan to collect these data on a regular basis in the future.

Case managers who are using the toolkit will be asked to complete a log both three and six

months after they receive training. CFPB believes it is necessary to collect this information at 

two points in time to measure both persistence and sustainability of use of the toolkit over time 

and changes in participants’ level of comfort and familiarity with the content and resources.

7. Circumstances Requiring Special Information Collection

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

consistent with the guidelines in 5 CFR 1320(d)(2).

8. Consultation Outside the Agency

In accordance with 5 CFR 1320.8(d)(1), on January 29, 2013, the Bureau published a notice in 

the Federal Register allowing the public 60 days to comment on this proposed new collection of 

information (Vol. 78, No. 19, pages 6074-6077). The CFPB received no comments in response

to this notice.

Further and in accordance with 5 CFR 1320.5(a)(1)(iv), the Bureau has published a notice in the 

Federal Register allowing the public 30 days to comment on the submission of this information 

collection request to the Office of Management and Budget.

9. Payment or Gifts to Respondents 

No payments or gifts will be provided to respondents in exchange for submitting data. Members 

of the pilot trainer cohort will each receive $1,000 as a stipend for their participation in the pilot 

study. However, this compensation is in exchange for the significant amount of time that they 

will spend participating in an initial training provided by CFPB and its contractor, as well as 

planning and conducting their own trainings with case managers. The stipend is to be provided at 

the end of the study and will not be provided as a payment in exchange for submitting data.
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10. Assurance of Confidentiality 

The CFPB included appropriate privacy requirements in its contract with the contractor, to the 

extent permitted by applicable laws. The contractor has agreed to comply with all requirements 

and restrictions in the contract about information release, non-disclosure of personal information, 

privacy, and security. 

In the directions for each instrument, respondents will be informed that the data they provide will 

not be associated with their organization in any analysis or reports that derive from the data 

collection.

11. Justification for Sensitive Questions 

This information collection does not include questions of a sensitive nature, such as sexual 

behavior and attitudes, religious beliefs, race/ethnicity, disability, social security numbers, or any 

other matters generally considered private.

12. Estimated Burden of Information Collection

No. of 

Respondents

Annual 

Frequency 

per 

Response

Total 

Annual 

Responses

Burden per 

Response Total Burden

Training 

Evaluation 

Forms from 

Pilot Trainers

55 1 55 20 min 18 hrs, 20 min

Training 

Evaluation 

Forms from 

Case 

Managers

880 1 880 15 min 220 hrs, 

Telephone 

Focus Groups

with Pilot 

Trainers

25 1 25 1 hr 25 hrs

Case Manager 

Logs

880 2 1760 10 min 293 hours, 20 min

Final Survey 

of Case 

Managers

880 1 880 10 min 146 hrs, 40 min

TOTALS 703 hrs, 20 min
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Estimates of the length of time it will take respondents to complete each instrument are based on 

testing conducted by the CFPB’s contractor, ICF. 

13. Estimated Total Annual Cost Burden to Respondents or Recordkeepers 

There are no capital/start-up or ongoing operation/maintenance costs associated with this 

information collection.

14. Estimated Cost to the Federal Government 

There will be no annualized capital/start-up costs for the government to collect these data. It is 

anticipated that costs of $25,000 will be incurred to carry out the data collection, including the 

cost of data management, analysis, and reporting.

The Blanket Purchase Agreement under which this data collection is being conducted was 

awarded through a competitive bidding process. 

15. Program Changes or Adjustments 

The Bureau is requesting a program change of approximately 703hours resulting from this new 

collection of information. 

16. Plans for Tabulation, Statistical Analysis, and Publication 

The CFPB anticipates that data collection will begin within four weeks of OMB approval, at an 

initial training provided to cohort members. Cohort members will complete their first survey 

immediately after that training. Each cohort member will then be responsible for training 25 case 

managers during the subsequent month. Both cohort members and case managers will complete 

surveys immediately following those trainings. Participating case managers will be asked to 

submit logs of their usage of the toolkit both three and six months after they receive their 

training, and will also complete a final survey at the six month mark. After accounting for

potential minor delays in data submission and processing, all data collection will be complete no 

more than 9 months after OMB approval is received.

CFPB’s contractor will conduct the initial analysis and summary of the study findings. 

For qualitative, open-ended questions, ICF will conduct a thematic analysis. For closed-ended 

questions in which respondents are asked to select one of several different response options, the 

contractor will use frequencies and cross-tabulations in its analysis. For questions that ask 

respondents to provide a numerical answer, the contractor will calculate frequencies, means, 

medians, ranges, and standard deviations. CFPB staff intend to use the results of this analysis to 

inform internal processes and decisions regarding the FET toolkit; there are no plans to publish 

the results of the research.
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17. Display of Expiration Date 

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

on all instruments. 

18. Exceptions to the Certification Requirement 

There are no exceptions to the Certification Requirement.