Page 1 of 11 CONSUMER FINANCIAL PROTECTION BUREAU INFORMATION COLLECTION REQUEST

– SUPPORTING STATEMENT Financial Coaching Program for Veterans and Low

- income Consumers (OMB CONTROL NUMBER: 3170

- XXXX)

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

information.

ABSTRACT: Beginning in early 201 5 , the Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) will launch a Financial Coaching project to provide direct financial coaching services to transitioning veterans and economically vulnerable consumers nationwide . Over three years, it i s estimated that ten thousands of consumers will be served. In order for CFPB to understand whether the program is effective and for the financial coaches to be able to deliver efficient services and track clients over time, CFPB will need to take steps to monitor program performance and to evaluate the program. This will ultimately include a process evaluation to

exam ine program implementation and an outcomes evaluation to examine program effects on

clients. Performance monitoring and the process and outcome evaluations will involve three key

data collection efforts: administrative data collected about clients by f inan cial coaches for programmatic purposes; interview data collected by evaluators from key informants such as coaching clients, financial coaches and program administrators; and self

- reported survey data

from coaches and coaching clients. The information to b e collected from clients will include a

combination of personal information (basic contact and demographic information), performance metrics (outputs)

, client

- level outcomes (progress towards financial goals or other relevant

outcomes ) and programmatic and organizational outcomes

. The current information collection request is specifically for the administrative data that will be collected by coaches from financial coaching clients for programmatic and performance monitoring purposes. Additio nal requests

will be submitted at a later date for the process and outcomes component s of the evaluation.

A. JUSTIFICATION

1. Circumstances Necessitating the Data Collection

The Dodd

- Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd

- Frank Act”),

Pub. L. 111

- 203, established the CFPB to regulate the offering and provision of consumer products or services under federal consumer financial laws. Consistent with the purposes of the

Dodd

- Frank Act, the CFPB’s mission includes establish ing and enforc ing clear, consistent rules for the financial marketplace ; protect ing American families from unfair financial practices ; and develop ing and implement ing a strategy to improve the financ ial literacy of consumers. For additional background on the CFPB, please see http://www.consumerfinance.gov/the

- bureau/

.

Secti on 1017(d)(1) of the Dodd

- Frank Act est ablishes a separate fun d in the Federal Reserve, the

Consumer Financ ial Civil Penalty Fund ( “ Civil Penalty Fund ” or “Fund” ), into which the Bureau must depo sit civil penalties it collects fro m any person in any judicial or admi nistrative action

under Federal con sumer financial l aws. 12 U.S.C. 5497(d )(1). Under the Act, amounts in thePage 2 of 11 Fun d may be used ‘‘for payments to the victim s of activities for which civil penalt ies have been imposed under the Federa l consumer financial laws.’’ 12 U.S.C. 5497 (d )(2). In addition, ‘‘[t o ]

the ext ent that such victims cannot be located or such payments are otherwise not practicable,’’

the Bureau may use a mounts in the Fund for the purpose of consumer e ducation and financial literacy programs.

This program represents the first consumer education program funded by the Civil Penalty Fund

. Because of the scope and size of the program, it is crucial that CFPB collect data on the beneficiaries of the financial coaching services in order to understand if the services are working well and how they might be improved upon.

Additionally, the goals of this project are in line with the individual office mandates of both the Office of Servicemember Affairs and the Office of Financial Empowerment. The Dodd

- Frank Act assigns the CFPB’s Office of Servicemember Affairs the responsibility to educate and empower servicemembers and their families to make better informed decisions regarding consumer financial products and services. Similarly, the CFPB’s Office of Financ ial Empowerment seeks to meet the Bureau’s statutory mandate to “provid[e] information, guidance, and technical assistance regarding the offering and provision of consumer financial products and services to traditionally underserved consumers and commu niti es.” 1

New data collection is necessary to help the CFPB and its stakeholders understand whether the program is effective and efficient, and also to gain insights into how the program can be improved.

2. Use of the Information

The information to be collected will include a combination of client personal information (i.e., basic contact and demographic information ), performance metrics (outputs)

, client

- level

outcomes related to financial goals

, as well as other relevant organization

- level outcomes.

The coaches will likely be working with the clients over multiple sessions and their information will be collected and housed in a client management system. In addition to personal information

intended for client management an d follow

- up , the coaches will also be required to document high level information about the client’s financial goals and progress made towards those goals

. T he coaches will also use the client data management system to capture the reason s why clients

are w orking with the coach in the first place (for example, to reduce debt) , and progress made

towards th ose goal s

. Capturing t he outcomes from coaching sessions will help CFPB determine if the sessions, the coach, and program overall are effective in helping c lients achieve their financial goals. CFPB will be able to identify and learn from information that is gleaned from the success of clients and coaches. For example, if one site or coach is particularly effective in working with clients, the other coaches c ould learn from this site or person’s processes or technique s

.

1 12 U.S.C. § 5493.Page 3 of 11 C ommon client outcome measures such as income, savings, debt, and credit, will be collect ed

, based on the stated goals identified by individual client s. In addition, a set of standard outcome

measure s will be collected from clients across all coaching sites, as well as outcomes that vary by site and by the types of populations being served. These site

- specific outcomes will be based

on the existing programs ’ service delivery needs and existing systems and/or processes for collecting and tracking outcomes.

Finally, b eyond client outcomes, CFPB will collect additional information (e.g., from coaches, the delivery organizations/agencies, etc.) to contribute to its knowledge and understanding of what has been effective and how to improve the program moving forward. By understanding the

macro

- level needs of the clients and coaches, the program can, for example, adjust and respond to training needs that coaches may have in response to issues that the clients are presenting. The

bulk of the administrative information collected would be at the time of intake and ca ptured in

the client management system. Each time the client meets with the coach, the coach will

document relevant information to wards goal accomplishment

. At a later date, t here will also be

follow

- up interviews and surveys to capture outcomes data from non

- veteran segments of the

clients being served. These interviews and surveys will fall under a separate OMB data collection request specifically for the follow

- up survey and process study components of the program evaluation

. Veteran clients will receive the same services under this initiative as the economically vulnerable consumers, however they will not be included in any further outcome or impact studies related to this project.

The client

- level raw data will not be s hared outside of CFPB (and its contractors and subcontractors collecting and analyzing the data)

. Directly

- identifying information ( e.g.
, respondent names) will not be made available to CFPB

. CFPB may , however, choose to release

de

- identified results and aggregated analyses of those results (such as trends in financial issues) in public reports it will issue. T hose results would be reported in a way that could not reasonably identify any respondent

. Veteran

- specific data will not be released to the public.

3. Use of Information Technology

Although the administrative data will be collected through conversations that coaches have with their clients, they will be u sing a n electronic client management system to document and report

standardized information about the clients a s well as progress towards their goals. While some interaction between coaches and clients may occur by phone or email, the majority of conversations between coaches and clients will likely occur in person.

More information on data collection and use of technology for the outcomes survey will be provided when separate OMB request s for the follow

- up survey and process study components
of the evaluation are submitted.

4. Efforts to Identify Duplication

This information colle ction would be related to a new CFPB program, therefore, there are no concerns about duplication.Page 4 of 11 5. Efforts to Minimize Burdens on Small Entities

CFPB does not anticipate any small businesses being impacted by this collection of information.

The burden is on clients requesting the financial coaching service

.

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

If the collection is not conducted, CFPB would not be able to know how the program is performing , nor would it know how to improve the program moving forward.

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. 5(d)(2)

.

8. Consultation Outside the Agency

In accordance with 5 CFR 1320.8(d)(1), the Bureau has published a notice in the Federal Register allowing the p ublic 60 days to comment on these proposed new c ollection s of information. Further and in accordance with 5 CFR 1320.5(a)(1)(iv), the Bureau has publish ed 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. While we are requesting comment on the full package, at this time, the Bureau is only seeking approval for the

informat ion collected in association with the client intake process and client management process system. The follow

- up and process evaluation will be submitted to OMB at a later date and will

be announced in Federal Register with an opportunity for public comment

.

T he Bureau engaged in extensive consultation with people outside the Bureau on the design of the coaching program, to include the information collection component.

I n the process of developing the procurement for the financial coaching program for tran sitioning veterans and economically vulnerable consumers, the Bureau:

1) Released a public request for information (RFI) in April 2013 to solicit feedback from organizations, potential vendors, and experts. This was sent out to over 2,000 stakeholders working with military and low

- income consumers. We received comments from 50 different organizations and individuals, including organizations serving these respective populations, experts in financial coaching, financial counselors, and others.

2) Held a pre

- solicitation conference in Washington

, DC with webcasting (August 2013)

after the release of a draft solicitation. That conference was widely attended by vendors and groups with an interest in veterans and other issues. Potential vendors were invited to submit questions before and during the conference, and the Bureau received and addressed over 200 questions

.Page 5 of 11 3) Conducted general outreach to learn more about the coaching approach and understand the best way to deliver services to the respective populations . Specifically, CFPB h eld meetings with more than two dozen experts and leaders from organizations (including non

- profit, for

profit, and government) providing services to th e respective consumer groups. CFPB has also

conducted site visits to existing financial coaching programs and attended coaching trainings.

The 60

- day notice in the Federal Register received two comments . The comments were reviewed, and this information collection request was adjusted where appropri ate. Both

comments provided feedback on the overall program model and goals. CFPB is considering this

feedback as part of the program design and implementation process

. T he two comments are addressed below as they pertain to the information that will be co llected as part of the client intake and case management processes

.

Comment 1

. The comment is from an organization that supports homeowners in or at risk of

financial distress. The commenter notes the unique financial circumstances and educational needs of veterans and how they may differ from those of economically vulnerable consumers

, and emphasizes the specific need for mortgage education as part of the coaching program

curriculum for veterans.

CFPB agrees that veterans may have unique financial coaching needs. The coaching curriculum anticipates a wide range of potential financial goals and concerns for both economically

vulnerable and transitioning veteran consumers

— including the possibility of very diverse goals related to homeownership, mortgage or housing costs

. We expect that financial characteristics

and goals will vary widely by coaching site

, by population, and by individual clien ts. The expected diversity of goals and client characteri stics is reflected in the wide range of information

that will be discussed and collected related to client background, financial characteristics (savings, debt, credit) and financial goals

. Coaches will gather s pecific information about

h omeownership, mor tgage

, or housing

- r elated goals. This information will allow coaches to help clients achieve their goals and to provide access to services or information related to their specific goals

— including mortgage counseling. As appropriate, coaches will refer clie nts to additional supports related to their financial goals, including supports around homeownership or mortgage education.

Comment 2

. The comment is from an organization that works with municipal governments to improve financial stability among low and m oderate income households

— including through

fi n a n c i a l coaching programs . The commenter emphasizes the importance of data for program decision making , and of a robust, transparent and standardized data collection system and protocols. The commenter also re commends specific data points and measures as examples of performance monitoring and outcome measures to be collected and monitored.

CFPB agrees with the commenter, and has included several of the same or similar measures in

in the administrative informa tion that will be collected through the client intake and case management system. These include key demographics for all clients served, data allowing CFPB to track the numbers of clients served by site and in total, self

- reported information on clientPage 6 of 11 cre dit, savings, assets

, and achievement of self

- identified financial milestones.

The commenter also suggest ed several specific measures and processes for capturing the impact of coaching services on financial outcomes (changes in debt, savings accumulated, changes in credit score) . While some of the information to track client outcomes and progress towards goals will be collected by coaches from clients through program administrative data, additional

information related to program impacts will be collected from a sample of economically

vulnerable consumers during the follow

- up client survey and process study components of the

evaluation

. As noted, CFPB will submit separate OMB requests for the process and outcomes components of the program evaluation. stud ie s

.

Finally, commenter #2 suggested that CFPB’s estimate of the total number of hours necessary

for data collection was low , given the need for detailed data and rigorous performance monitoring

. We have adjusted our expectations for data collection to ref lect a higher burden (shown in Exhibit 1, below). Data collection burden estimates are based on feedback from existing coaching programs that follow a similar service delivery model. Not all data collection

items will be relevant to all clients , and the sp ecific number of questions that will be asked on any given client will vary based on their specific financial goals and background. In addition, only a subset of clients will be included in the f ollow

- up process and impact component s of the

evaluation , and will experience a higher data collection burden, which will be described in detail in subsequent OMB requests. However, the anticipated burden for this subset of clients is included in Exhibit 1 in order to provide a more comp rehensive estimate of the tot al data collection burden for the project.

The comments are available on the Federal government ’ s on

- line comment docket at
http://www.gpo.gov/fdsys/pkg/FR

- 2014

- 09

- 04/pdf/2014

- 21112.pdf

.

9. Payments or Gifts to Respondents

No payments or gifts will be provided to responden ts for the collection of the administrative data described in this request

. Appropriate incentives will be provided for the sample of coaching clients who complete an interview and/or survey under the impact and process evaluation portion s of the project , as will be described in detail in additional data collection requests

.

10. Assurances of Confidentiality

The standard confidentiality provisions of the programs of the sponsoring institutions will apply.

Data will be treated in a private manner, and directly

- identifying information ( e.g. , respondent names) will not be made available to CFPB

. A privacy notice will be included in a brochure that all participants will receive at the point they first agree to participate in this program. Further,

any resulting reports on the program will consist only of de

- identified results and aggregated analyse s of those results that will be reported in a way that could not reasonably identify any respondent

.

CFPB and t he service delivery and evaluation team s are committed to securely collecting andPage 7 of 11 using the private information collected under this evaluation

. The evaluation procedures will be reviewed by the evaluation partner’s Institutional Review Board (IRB), which reviews proposed collections of potentially sensitive or private data and associated data security measures. 2 To receive IRB approval for a study, the data collection effort must adhere to the following principles:

• All program participants will be informed of their rights under the Privacy Act of 1974
before collecting administrative data.

• Adequate provision is made to protect the privacy of subjects and to maintain the privacy
of data that are collected, where promised and as appropriate.

• Risks to subjects from the research are reasonable in relation to anticipated benefits, and
are minimized to the extent possi ble.

• The selection of research subjects is as equitable as possible (the burdens and benefits of
the research are fairly distributed), with particular attention paid to research involving
vulnerable populations and protected health information.

As noted, v eteran clients will receive the same services under this initiative

, however they will

not be included in any further outcome or impact studies related to this project.

R eports produced under this evaluation will never identify individual respondents by name or

with directly

- identifying personally identifiable information from the key informant interviews

. Additionally, other personal information, such as outcomes survey or program administrative data, such as date of birth

, will not be included in reports produced . For all report and presentation purposes (e.g. draft reports, final reports, and any presentations of the report findings), primary data that are collected for the evaluation will be aggregated to a level at which

the individual identities of those who provided the information could not reasonably be

discerned

.

N o directly

- identifying personally identifiable information will be shared with anyone outside of

the research team or at CFPB. Only d esignated prog ram evaluators who need the information for research purposes and who have signed a “Data Privacy Pledge” will have access to client

information. The Data Privacy Pledge is a document which stipulates the data security and privacy procedures which must be followed by all those participating in the evaluation. All evaluation staff and consultants will sign this pledge prior to beginning evaluation activities.

Hard

- copy materials containing direct

- identifying PII will be locked up when not in use, and

electro nic materials will be stored on a secured server in password

- protected computers and/or encrypted.

2 The evaluation partner’s IRB requires that the project’s data security measures ensure that: ( 1 ) Access to priva te data will be limited to research team members who need access for evaluation purposes and who have agreed in writing to maintain the privacy of all data

. ( 2 ) Adequat e precautions will be taken to ensure administrative and physical security of personally identifiable information

. ( 3 ) Project findings and reports prepared for dissemination will not contain information that could reasonably be used to identify an individ ual. ( 4 ) Both electronic files and hard copy data materials will be stored securely

. ( 5 ) To protect the privacy of research subjects, the data files submitted to CFPB will be “sanitized” to remove any information that could be used to identify a particular individual. ( 6 ) All hard copy data files and materials containing personal identifiers will be destroyed within six months of project completion.Page 8 of 11 The Consumer Education Privacy Impact Assessment (“ PIA ”) addresses the collection and use of PII related to this project. 3

11. Justification for Sensitive Questions

The coaches will be collecting Personally Identifiable Information (PII) . Coaches will collect

direct

- identifying PII including name and basic contact information to facilitate participation in the counseling program . Additionally, coaches will collect demographic data and respondent data (goals, challenges, outcomes information provided by participa nts as outlined below ) as part

of program evalu ation efforts

. Social Security Numbers (SSNs) will not be collected as a part of the administrative data collection process , and clients will not be required to provide SSNs in order to participate in the program. Instead

, an alternative unique identification number will be developed to track coaching clients and service delivery

.

For the follow

- up survey portion of the evaluation , coaches will collect other directly identifying

information for a subset of the non

- Veteran clients who choose to participate

. More information on this process and selection of th e subset of economically vulnerable consumers will be provided in subsequent OMB request s for data collection.

CFPB has a System of Records Notice (SORN), CFPB.021

– Consumer Education and

E ngagement Records (FR 77 FR 60382) in place which is currently being updated to account for the collection, use, disclosure, and destruction of PII as it relates to this project. This SORN will be published by the end of December 2014.

The project will collect and analyze response data provided by participants when coaches ask questions related to personal financial behavior, such as amount of savings, amount of debt, spending behavior and other personal financial information if applicable to the client’s goals

. Such response data may include sensitive information or be considered, when combined with

other data

, to be personally identifiable. Such data will be stripped of direct identifying PII for analysis purposes. Analysis will include (for exam ple) assess ing financial goals, outcomes and financial behavior relating to participation in the financial coaching program. Because of the individual nature of the program, the vendor, on CFPB ’s behalf, will need to collect the sensitive

information at th e individual level for certain aspects of the program (such as intake for the client management system). However, as note d

, where data is being reported, aggregate data stripped

of direct identifi ers will be reported wherever possible

.

12. Estimated Burden of Information Collection

In Exhibits 1 and 2, we provide estimates of the collection burden on program participants. The project team anticipates a total of 10,000 clients enrolled in coaching services through out this

program . All clients will be walked through their rights under the Privacy Act, and if the client is asked to complete a brief series of questions for the Client Information System to provide

3 The Consumer Education PIA can be found at http://files.consumerfinance.gov/f/201409_cfpb_consumer

educa tion_pia.pdf

.Page 9 of 11 information for further research, they will also be asked to sign an intake/consent form.

Us ing the Bureau of Labor and Statistics Occupational Employment Statistics (OES) survey 37th percentile we estimate an average hourly wage for coaching clients (economically vulnerable and returning veteran) of $13.76. We then multiply this figure by the nu mber of burden hours for each of these activities, which generates estimates of the total annual cost burden.

In addition to these data collection efforts, financial coaches will record information about clients during the course of their meetings (e.g. meeting goal, length, date, etc.) that also will be entered into the Client Management System. The evaluation will make use of these already collected program/administrative data, and as they do not represent new data collection from coaching clients, they are not included in the burden calculations below.

Not all data collection items will be relevant to all clients, and the specific number of questions that will be asked on any given client will vary based on their specific financial goals and background. The time burdens in Exhibit 1 reflect an average estimate for each client. In addition, only a subset of clients will be included in the follow

- up process and impact components of the evaluation and will experience a higher data collection burd en. This additional data collection effort and burden will be described in detail in subsequent OMB

requests and the respective instruments will be submitted to OMB review at that time . The anticipated burden for this subset of clients are included in the Exhibit s in order to provide a more comprehensive estimate of the total data collection burden for the project.

E XHIBIT 1. E STIMATE OF A NNUALIZED T IME B URDEN TO R ESPONDENTS

Number of Respondents Number of Responses

Per Respondent Total

Annual Responses Average Burden per Response (in hours) Total

Annual

Burden

Hours

Client I nfo rmation for the Client Management System (including intake and Privacy Act statement ) ** 10,000 1 10,000

. 50 5,000

Process e valuation interview q uestions 50 1 50

. 75 38

Follow

- up outcome s urvey 1,000 1 800

. 33 267

Total : 10,000 * //////////////// 20, 850 //////////////// 5,305

Total for this Request: 10,000 //////////////// 10,000 //////////////// 5,000

* Respondents to the Intak e, Process evaluation , and Follow

- up survey are a subset of those for the CMS; therefore, the total number of annual respondents is 10,000. ** Only information related to th e case management data collection process and realted burden is being submitted to OMB with this
request. Data colle ction related to t he p rocess evaluation and f ollow

- up survey will be submitted to OMB under this OMB number at a

later time. See above.

E XHIBIT 2. E STIMATE OF A NNUALIZED C OST B URDEN TO R ESPONDENTS

Number of Total annual Average TotalPage 10 of 11 Respondents burden

hours hourly

wage rate 4 annual cost
burden

Client I nfo rmation for the Client Management System (Intake and Privacy Act statement) 10,000 5,000 $13.76 $ 68,800

Process Evaluation Questions 50 38 $13.76 $523

Follow

- up Survey 1,000 267 $13.76 $3,674

Total 10,000 5,305 ////////// $ 72,997 Total for this request 10,000 5,000 ////////// $68,800

13. Estimated Total Annual Cost Burden to Respondents or Recordkeepers

There are no capital/start

- up or ongoing operation/maintenance costs associated wi th this

information collection.

14. Estimated Cost to the Federal Government

The estimated cost for this work is still to be determined

. However, we estimate that CFPB will

need to cover the costs (via the contract) of a client management/outcome tracking system in order to be able to collect and report data , as well as costs associated with the collection, analysis, and reporting of interview and survey data

.

15. Program Changes or Adjustments

This submission to OMB is a new request for approval; therefore, the entire burden is considered a program change

.

16. Plans for Tabulation, Statistical Analysis, and Publication

The period of time for the demonstration phase of the financial coaching project is three years with two additional option years. CFPB, at this time, plans to publish for stakeholders and the public at least one report that would provide basic information about the program’s implementation, the types of issues clients are facing, what their outcomes have been, and general lessons learned to date. All data would be published in the aggregate. CFPB does not know, at this time, what the publication(s) dates wo uld be, but the first publication would occur after the program has been up and running for at least one year.

17. Display of Expiration Date

4 Average hourly wage was derived from the Bureau of Labor and Statistics Occupational Employment Statistics (OES) survey

, using the 37 th percentile (Average hourly rates available at http://www.bls.gov/oes/current/oes_nat.htm ) . Note that many of the

clients will be seeking employment, so an average wage may not reflect the entire distribution

.Page 11 of 11 The Bureau will display the expiration date and OMB control number on all instruments

. T his

information will als o be displayed in OMB’s public docket at www.reginfo.gov

.

18. Exceptions to the Certification Requirement

The Bureau certifies 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 ex emption to
these certification requirements

.