1

BUREAU OF CONSUMER FINANCIAL PROTECTION

PAPERWORK REDUCTION ACT SUBMISSION

INFORMATION COLLECTION REQUEST

SUPPORTING STATEMENT PART A Supporting Statement – Part A 

CFPB Generic Information Collection Plan for Studies of Consumers using Controlled 

Trials in Field and Economic Laboratory Settings

(OMB CONTROL NUMBER: 3170-XXXX)

ABSTRACT: Under the Dodd-Frank Wall Street Reform and Consumer Protection Act, the

Consumer Financial Protection Bureau is tasked with researching, analyzing, and reporting on

topics relating to the Bureau’s mission, including developments in markets for consumer 

financial products and services, consumer awareness, and consumer behavior. The Bureau seeks 

to obtain approval for a generic clearance to collect data from purposive samples through 

controlled trials in field and economic laboratory settings. This research will be used for 

developmental and informative purposes in order to increase the Bureau’s understanding of 

consumer credit markets and household financial decision-making.

1. Circumstances Necessitating the Data Collection

A core component of the Consumer Financial Protection Bureau (CFPB, Bureau)’s 

mission is to understand how consumer financial markets work, the avenues for innovation in 

financial products and services, and potential risks to consumers.1 In order to achieve this 

mission, the Dodd-Frank Wall Street Reform and Consumer Protection Act (Act) and other 

federal consumer financial laws authorize the CFPB to engage in research and general 

market monitoring activities to assess trends and emerging risks in consumer financial 

markets.

2 Section 1013(b)(1) of the Act establishes the Office of Research and assigns to it 

 1 CFPB FY 2013 – FY 2017 Strategic Plan, goal 3, http://www.consumerfinance.gov/strategic-plan/ 2 DFA Section 1013(b)(1) mandates that the Bureau have research staff whose responsibilities include 

“[r]esearching, analyzing, and reporting on (A) developments in markets for consumer financial products or 

services, including market areas of alternative consumer financial products or services with high growth rates and 

areas of risk to consumers; (B) access to fair and affordable credit for traditionally underserved communities; (C) 
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the responsibility of researching, analyzing, and reporting on topics relating to the Bureau’s 

mission, including developments in markets for consumer financial products and services, 

consumer awareness, and consumer behavior. The Act also established the Office of 

Financial Education (OFE) within the CFPB, which is responsible for developing and 

implementing initiatives intended to educate and empower consumers to make betterinformed financial decisions, and, together with the CFPB’s Office of Research, for 

conducting research related to financial education and counseling. Using empirical evidence 

and rigorous research, the Bureau improves its understanding of consumer financial markets 

and is able to provide accurate and comprehensive information to consumers, firms, 

researchers, and policymakers.

The CFPB supports this mission by building an understanding of the markets that the 

Bureau regulates and the nature of consumer behavior in these markets. Research provides a 

scientific basis for policy development, supervision and enforcement, regulation, and

consumer education and engagement activities pursued by the CFPB. 

The CFPB seeks to use this generic information collection plan to collect data from 

purposive samples (that do not necessarily represent the general public or a population of 

regulatory interest) through controlled trials in field and economic laboratory settings. The 

research will be used for developmental and informative purposes, but not directly providing 

a basis for specific policy at the Bureau. 

In general, topics that the Bureau is interested in studying include:

• consumer awareness and decision-making, for example, understanding what financial 

products or features people are aware of and why they choose one product over another;

• consumer experiences and potential risks to consumers, including traditionally 

underserved consumers;

• information disclosure and how disclosure may affect behavior;

 

consumer awareness, understanding, and use of disclosures and communications regarding consumer financial 

products or services; (D) consumer awareness and understanding of costs, risks, and benefits of consumer financial 

products or services; (E) consumer behavior with respect to consumer financial products or services, including 

performance on mortgage loans; and (F) experiences of traditionally underserved consumers, including un‐banked 

and under‐banked consumers.”
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• the effect of educational or other interventions on consumer financial behavior or 

outcomes;

These topics will usually be in the context of consumer financial product markets, 

including mortgages, car loans, student loans, installment loans, small dollar loans and credit, 

debit, and prepaid cards. In addition, research may be related to the CFPB’s mission

regarding financial education, including evaluating the effectiveness of financial education 

programs and understanding financial planning behaviors, including savings and spending 

behavior. The CFPB envisions that the research covered under this generic clearance will be

basic research about consumer credit markets and household finance.

When collecting information about consumer credit markets, the CFPB recognizes

that there are privacy and data security risks. We outline the ways the CFPB plans to 

mitigate these risks when collecting data using this generic clearance later in this supporting 

statement.3

2. Use of the Information

The CFPB requests approval from the Office of Management and Budget (OMB) for 

a generic information collection plan clearance that will allow the Bureau to collect data 

from purposive samples through controlled trials in field and economic laboratory settings.

The specific purpose of this generic clearance is to allow the Bureau to better inform and 

advance scientific understanding of consumer credit markets and household finance. For 

example, the Office of Research envisions a program of data collections, and this generic 

clearance will allow us to monitor and research market developments in a timelier manner. 

The purpose of research conducted under the expected clearance will not be making 

particular regulatory decisions or developing or evaluating specific policies. Studies 

conducted under this generic approval may identify opportunities for enhanced or improved 

 3 On June 30th 2014, the CFPB published a Privacy Impact Assessment (PIA) for Consumer Experience Research 

that covers some of the data that will be collected under this generic clearance. Other PIAs will be published by the 

CFPB in the future that will likely cover data collected under this generic clearance as well.

http://files.consumerfinance.gov/f/201406_cfpb_consumer-experience-research_pia.pdf
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regulatory or other policy actions; however, as noted, the Bureau will not initiate any policy 

changes based solely on these research projects. Instead, the CFPB envisions this generic 

clearance to cover studies with developmental and informative purposes given that research 

studies under this generic clearance will only include purposive samples that do not 

necessarily represent the general public or a population of regulatory interest.

Research projects under this generic clearance may include pretesting and cognitive 

interviewing prior to the data collection. The Office of Research will generally pretest 

questionnaires and other user-interfaces to ensure the collection of reliable information 

while minimizing respondent burden and costs. Cognitive testing ensures that a question 

posed to respondents successfully captures the intent of the question and that it makes sense 

to respondents. It can also be used to better understand research results by providing data 

about why participants responded to questions the way they did. The Bureau may also rely 

on pretesting to ensure that necessary computer hardware and software function 

appropriately.

This generic clearance will allow the Bureau to conduct data collections which will 

achieve our research project goals with the least amount of burden on the public, and while 

ensuring strong privacy and data protections throughout these projects. Collections under 

this clearance will be limited to situations in which sufficient data do not already exist but 

could be collected through data from purposive, non-representative samples.

 

3. Use of Information Technology

The CFPB will employ information technology as appropriate to reduce the burden of 

respondents who agree to participate in its research. Computer-assisted participation will be 

used when feasible and appropriate, including online studies. In general, the Bureau intends 

to incorporate electronic data-collection techniques whenever possible, particularly since in 

many instances they are likely to impose the lowest burden on respondents and may be the 

most cost-effective. However, the extent to which the Bureau will use electronic data 

collection for a given project will be determined by weighing several factors, including 
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response rates and costs. For example, evidence to date suggests that web-only data 

collections tend to have lower response rates than surveys conducted by mail or phone.4 The 

Bureau expects that the most effective mode, including mixed-mode combinations, may also 

vary with the complexity and sensitivity of the information to be collected.

4. Efforts to Identify Duplication

The Bureau will conduct controlled trials in field and economic laboratory settings to 

answer questions that have not yet been satisfactorily addressed in the relevant research 

literature. In some cases it will be appropriate to replicate previous laboratory and field 

studies within a new population of interest to the CFPB, such as service members, students, 

older Americans, or people who utilize specific financial products, such as payday loans or 

remittances. In these cases, the Bureau will detail the relationship between the proposal and 

existing studies and will describe how the data collection supports the CPFB’s mission. A

review of the existing relevant literature will be undertaken before proceeding with a project.

5. Efforts to Minimize Burdens on Small Entities

All of our research projects will be limited to individual consumers, not businesses, 

so there will be no impact on small businesses or other small entities.

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

The proposed generic clearance will allow the Bureau to collect a variety of types of 

data to develop a more complete understanding of consumers’ decision-making regarding 

consumer financial products and the characteristics of markets for these products. This 

knowledge will improve the Office of Research’s ability to inform the Bureau’s policy work 

in developmental and formative ways. Where appropriate, the Office of Research plans to 

disseminate the results of this research by making versions of the data and analysis available

 4 Roger Tourangeau, Fredrick Conrad, and Mick Couper (2013), “The Science of Web Surveys.” USA: Oxford 

University Press.
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publicly. Therefore, the data to be collected under this proposed generic clearance will not 

only improve the CFPB’s understanding of consumer financial markets, but it will also 

increase the knowledge available to other policymakers and researchers. 

The ability to collect data, through controlled trials in field and economic laboratory 

settings, allows the Bureau to control both the timing and direction of the research. By 

contrast, relying on naturally occurring data would leave the timing, content, and sample 

population outside of our control. These research projects allow us to isolate cause and 

effect by using randomization to control for variables that are unknowable or un-measurable 

in natural settings. In addition, these studies may be the best way to explore how consumers 

would behave in transactions environments that are just emerging and therefore novel.

For these reasons, data collections under this generic are important and valuable to 

the CFPB. Without these data collections, CFPB policy development will not be as well 

informed, and the CFPB will not be able to achieve its mission to understand how consumer 

financial markets work, the avenues for innovation in financial products and services, and 

potential risks to consumers.5

In addition, Congress has mandated that the CFPB, in consultation with the Financial 

Literacy and Education Commission and consistent with the National Strategy for Financial 

Literacy, “develop and implement a strategy to improve the financial literacy of consumers 

that includes measurable goals and objectives.” ((12 USC 5493 Sec. 1013(d)(1)). The CFPB 

will be unable to carry out this mandate if it does not have information about consumer 

experiences navigating the financial marketplace and what strategies can in fact improve 

financial literacy. If the CFPB does not have a clear understanding of what informational 

and other financial empowerment needs consumers have, and what financial education 

interventions work, its strategy, goals, and objectives will be without basis. Without periodic 

information collections on consumer experiences and best practices in financial education, 

the CFPB will not have timely information to adjust its programming to meet consumer 

needs.”

 5 CFPB FY 2013 – FY 2017 Strategic Plan, goal 3, http://www.consumerfinance.gov/strategic-plan/
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7. Circumstances Requiring Special Information Collection

Most information collections under this generic clearance will require a single 

interaction between the agency and respondents, but some information collections could 

require multiple interactions. For example, some studies may ask for subjects to return to the 

lab more than once, and this could occur within a single quarter. Note that in such cases the 

respondent would not typically have any burden beyond that single quarter. The CFPB will 

work to limit the burden on respondents and ensure that studies only include repeated 

interactions when the additional information gained is anticipated to be substantial and 

valuable to the study.

8. Consultation Outside the Agency

In accordance with 5 CFR 1320.8(d)(1), the Bureau published a notice Federal 

Register on April 14th, 2014, at 79 FR 20865 allowing the public 60 days to comment on this 

proposed new generic information collection plan. That period closed on June 13th, 2014. 

Two comments were received in response to the notice in the Federal Register.

Both comments received were from industry associations claiming that the generic 

clearance process is not appropriate for the type of controlled trials in field and economic 

laboratory settings described in this document. 

We disagree, and believe that the generic clearance process is appropriate for 

research projects with developmental and informative purposes. One commenter suggested 

that by nature, these studies would influence and inform the CFPB, even if they were not 

used to directly to provide a basis for specific policy at the Bureau. The commenter stated

that “...research is an iterative and cumulative process. The information learned and data 

generated by initial studies inform and influence subsequent hypotheses investigated—and 

ultimately, the substantive policy choices made.” We agree with the commenter’s 

characterization of the research process, but we disagree the implication that a generic PRA 

process is inappropriate. The CFPB is consistently informed by research and market 
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developments from sources both within the Bureau and outside of the agency. The studies 

covered under this generic clearance will be pursued for developmental and informative 

purposes, to advance our scientific understanding of consumer credit markets and household 

finance, not for making regulatory decisions or developing or evaluating specific policies. 

For this reason, we believe that a generic clearance process is appropriate.

Commenters also suggested that a generic clearance process would allow the CFPB 

to be less accountable to the Paperwork Reduction Act, but we strongly disagree. Should 

OIRA approve of the generic clearance, the CFPB would continue to be required to submit 

“specific information collections . . . to OMB for review, in accordance with the terms of 

clearance set upon approval of the plan.”6 In this way, the CFPB would continue to be 

accountable and continue to have effective regulatory oversight by the PRA process. Should 

the CFPB propose an information collection that falls “outside the scope” of the clearance, 

OIRA may require the CFPB to go through the normal clearance process.7

One commenter suggested that the Bureau preferred white papers to peer reviewed 

journals, which would limit public availability of our research. The Bureau feels that peerreviewed journals and CFPB published white papers are different ways to make its research 

available to the public, targeted to different audiences. Although public availability of 

research findings can take longer through the peer-review process, the Office of Research is 

very committed to publishing as much as possible in these types of journals, as well as 

making sure that all of our analysis is rigorous and employing best practices in social 

science research. The CFPB is very committed to making its research public, and wants to 

be open and transparent about the work that we are doing.

9. Payments or Gifts to Respondents

In order to support the mission of the CFPB, Bureau researchers are 

fundamentally interested in questions such as how consumers make choices and how they 

 6 Cass R. Sunstein, OMB. Mem., Paperwork Reduction Act – Generic Clearances at 2 (May 28, 2010). All OMB 

memoranda cited in this supporting statement are available at www.whitehouse.gov. 

7 Id.
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might respond to changes in the rules and regulations that govern a marketplace. 

Controlled trials in field and economic laboratory settings are an important tool for 

addressing these questions. In experiments, the researcher strips away extraneous features 

of the marketplace, leaving only the essence of the economic environment and the 

institutions that govern it, placing these factors under the researcher’s control. 

To ensure that the behaviors exhibited in these environments mirror behavior in 

other settings, the incentives motivating the behavior must be similar. This is difficult to

achieve if subjects are presented with purely hypothetical scenarios since participants’ 

choices may be guided by a variety of motivations.8 For this reason it is standard practice 

in the sub-discipline of experimental economics to compensate subjects.

9 Sometimes 

subjects are paid a fixed amount for their participation, in essence appreciation for their 

time, but also additional money based on their choices in the study. Participants may be 

paid different amounts depending on their performance.10 For each information collection 

request submitted under this generic plan, the amount of any proposed incentive, and a 

detailed justification therefore will be submitted.

10. Assurances of Confidentiality

CFPB shall treat the information in accordance with applicable federal law, 

including but not limited to the Bureau’s confidentiality rules, 12 C.F.R. Part 1070, and the 

federal laws and regulations that apply to federal agencies for the protection of privacy, 

confidentiality, security and integrity. 

The CFPB uses best practices of social science research design to inform the notice 

and consent vehicles. When required and when practicable, the CFPB provides notice to 

individuals that explain how their information will be used through appropriate vehicles, 

such as Privacy Notices, Privacy Act Statements or Informed Consent forms. Such notice is 

 8 Rachel Croson (2005), “The Method of Experimental Economics,” International Negotiation 10: 131-148. 9 Vernon L. Smith (1976), “Experimental Economics: Induced Value Theory,” American Economic Review 66(2): 

274-279. 10 Colin Camerer and Robin Hogarth (1999), "The Effects of Financial Incentives in Experiments: A Review and 

Capital-Labor-Production Framework" Journal of Risk and Uncertainty 19:7-42.
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typically made available prior to the collection of information and explains whether the 

information is mandatory or voluntary; whether there are any opportunities to consent to 

sharing and submission of information; how the information will be secured and when a 

System of Records is created under the Privacy Act. In some instances, research may be 

based on observations or on information collected directly from a third party, and notice and 

consent may not be applicable. 

When the CFPB collects information from third parties, commercial sources, and 

public databases, individuals to whom information may pertain do not have the opportunity 

to consent to uses, decline to provide information, or opt out. In such cases, it is those third 

parties’ responsibility to provide any opportunity that may be required to consent, decline, or 

opt out of how their information may be used. As part of the due diligence process, the 

CFPB reviews the privacy policies or other public disclosures from the third-parties 

regarding their use of the information to verify that there are no contradictions with the 

research, and the CFPB encourages the development of notice and consent opportunities. 

The Bureau also evaluates the potential privacy risk and harm to individuals of specific 

research relative to that authorized purpose, and vets research proposals to ensure that they 

serve an authorized purpose.

The information collected under this generic clearance may include direct identifying 

personally identifiable information (PII). Typically direct identifying PII consists of contact 

information used to facilitate administration of research, and is separated from response data 

generated from the research. When the CFPB does use direct identifying PII in analyses, it 

does so in order to a) match across datasets; b) update data sets; c) weight datasets in order 

to make generalizations regarding a given population; and d) contact potential recipients of 

of our studies to solicit information on consumer experiences with consumer financial 

products and services.

Conducting field and lab studies implicates privacy concerns because a breach of 

confidentiality, or re-identification, could result in an individual suffering harm. To reduce 

the risk of breaches of confidentiality, the CFPB designs recruitment materials so as not to 

disclose sensitive information about those it seeks to recruit, and uses appropriate security 

controls to protect information used in research. There is also risk related to misuse of 
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information collected for research. Misuse might involve secondary types of research that 

are incompatible with the purposes of the initial collection, or a use of the information that 

individuals do not understand or to which they have not provided consent.

To reduce the risk of misuse, the CFPB minimizes access to PII based on need-toknow and stipulates, in most instances, that contractors that collect data on behalf of the 

Bureau remove or redact all direct identifying PII, as defined by the Bureau’s privacy office,

before transmitting data to the Bureau. Any contractor staff assigned to the project also sign 

confidentiality agreements. When appropriate, research results will be presented in 

aggregated form to protect the confidentiality of firms or consumers, and any publicly 

released version of data will use disclosure protection techniques (e.g., rounding, 

imputation, exclusion of some variables, aggregation of categorical responses) to minimize 

the risk of releasing personally identifiable or otherwise sensitive information (12 CFR 

1070.40 et seq.). The Bureau treats the information collected from participating persons and 

institutions in a manner consistent with our confidentiality regulations, and all data and 

analyses are subject to legal and privacy review prior to their release. 

Field and lab research will be conducted consistent with the Privacy Act and the EGovernment Act. The requisite SORNs and PIAs will document the collection, use, 

disclosure, and retention of PII; the technical, administrative, and physical controls used to 

minimize privacy risks. The SORNs and PIAs will so be updated to reflect any changes.11

Specific details regarding information handling will be specified in individual submissions 

under this generic clearance, but will conform to these broad guidelines.

11. Justification for Sensitive Questions

Questions about an individual’s finances, for example, how much a person makes or 

how much their mortgage costs each month, are commonly considered sensitive.

Nonetheless, Office of Research must sometimes ask such questions in order to understand 

consumer behavior and recognize financial trends and emergent risks relevant to consumers. 

 11 The CFPB has two SORNs that will cover field and lab research: CFPB.021 Consumer Education and 

Engagement Records, 77 FR 60382; and CFPB.022 Market and Consumer Research Records, 77 FR 67802.
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The Bureau believes that we are justified in asking these types of sensitive questions 

because they are central to our mission. 

In addition, some people may believe that questions about race or other 

socioeconomic factors may be considered sensitive. However, the CFPB is mandated to 

enforce fair lending laws and focus on the risks to vulnerable populations, including service 

members, older Americans, and lower-income consumers. For this reason, the Bureau often 

needs to ask these types of sensitive questions. For information collections involving 

questions of race/ethnicity, the CFPB will ensure that the OMB standards for Classification 

of Federal Data on Race and Ethnicity (Federal Register, October 30, 1997, Volume 62, 

Number 210, pages 58781-59790) are followed. 

Respondent participation and all activities within the laboratory setting are voluntary, 

and subjects will be made aware of this fact. All respondents are free to opt-out of a data 

collection at any time and for any reason. Respondent participation in certain field studies 

that rely solely on indirect observation may not be voluntary and individual may not receive 

direct notice. In such cases, the Bureau does not intend to identify those individuals; uses 

standard social science research practices, including use of research review boards, to 

minimize risks of negative impacts to the Respondents; and vets field research to ensure 

they serve an authorized purpose. 

The CFPB will ensure that a citation is made to any applicable System of Records 

Notice (SORN), and a Privacy Impact Assessment (PIA) in the individual submissions under 

this generic clearance and published research.

12. Estimated Burden of Information Collection

The following tables present estimates of the total number of respondents and burden 

hours for proposed collections. The number of respondents and average burden per response 

for a specific collection will depend on the methodology used for gathering information. 

These estimates, as well as the mix of collection methods used, may be adjusted. Further 

details on estimated respondents and burden will be provided in each approval request. The 

total number of burden hours estimated under this generic clearance is 34,200 hours.
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For lab research studies, the CFPB estimates conducting five data collections in each of

the three years. For field research studies, the CFPB expects both small and large data 

collections, and expects four data collections in each of the three years. There will be no 

financial burden on the respondents.

Burden Hour Estimate for All Data Collections, 3-yr period

Types of Projects Subtotal

Lab Studies 7,200

Field Studies 27,000

34,200

Burden Hour Estimate for Economic Studies in the Lab, 3-yr period

Number of Projects

Number of 

Participants 

in a Project

Hours per 

Participant Subtotal

15 240 2 7,200

7,200

Burden Hour Estimate for Economic Studies in the Field, 3-yr period

Number of Projects

Number of 

Participants

in a Project

Hours per 

Participant Subtotal

3 3,000 1.5 13,500

9 1,500 1 13,500

27,000

For each specific collection request submitted under this generic plan, a detailed estimate 

of the burdens of that particular request will be submitted.

13. Estimated Total Annual Cost Burden to Respondents or Recordkeepers
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There will be no capital, operating, or maintenance costs to respondents as a result of 

participation in any information collection submitted under this generic clearance plan.

14. Estimated Cost to the Federal Government

For each data collection that falls under this generic clearance, costs to the Federal 

government will be estimated.

15. Program Changes or Adjustments

This is a new data collection.

16. Plans for Tabulation, Statistical Analysis, and Publication

The Bureau’s research projects are intended to expand scientific understanding of 

consumer decision-making in financial domains. Research findings will be published as 

technical articles that are publicly disseminated as working papers, published in peerreviewed journals, or published as CFPB white papers. Collection, analysis, and publication 

of data will span the entire period of the anticipated generic clearance. The Office of 

Research plans to conduct an ongoing program of research and therefore plans to apply for 

an extension to the anticipated generic clearance when it expires.

Because of “publication lag,” a typical academic journal article is published one or

more years after initial submission. The publication process for CFPB in-house products is

shorter than that for external academic publications. Data collection for a professional 

publication typically takes at least three to four months, and in some cases could be longer.

Data analysis and article preparation typically lasts another three to four months. Thus 

professional articles in a peer-reviewed outlet of any kind are estimated to be published from 

12 months to 36 months from the time that data collection can begin.12

 12 P.K. Trivedi (2006), “An Analysis of Publication Lags in Econometrics” Journal of Applied Econometrics 8(1): 

93-100.
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17. Display of Expiration Date

No exemption is requested.

18. Exceptions to the Certification Requirement

The Bureau certifies that this collection of information is consistent with the 

requirements of 5 CFR 1320.9, and the related provisions of 5 CFR 1320.8(b)(3) and is 

not seeking an exemption to these certification requirements.
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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. 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 corresponding 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 has been conducted previously, include the actual response 

rate achieved during the last collection. 

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. Describe the procedures for the collection of information. 

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 
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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 

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 
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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, such as surveys, 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 

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.
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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 

characteristics. Differences in outcomes observed after comparing treatment and control 

groups are therefore attributable to the treatment factor.

3. Describe methods to maximize response rates and to deal with issues of nonresponse. 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” data that can be 

generalized to the universe studied. 

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. Describe any tests of procedures or methods to be undertaken. 

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 
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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. Provide the name and telephone number 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. 

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 

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.