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CONSUMER FINANCIAL PROTECTION BUREAU

INFORMATION COLLECTION REQUEST –

DEBT COLLECTION SURVEY FROM THE CONSUMER CREDIT PANEL

(OMB CONTROL NUMBER: 3170-XXXX))

ABSTRACT: The CFPB plans to conduct a mail survey of consumers to learn about their 

experiences interacting with the debt collection industry. The survey will ask consumers about 

their experiences with debt collectors, such as whether they have been contacted by debt 

collectors in the past, whether they recognized the debt that was being collected, and about their 

interactions with the debt collectors. The survey will also ask consumers about their preferences 

for how they would like to be contacted by debt collectors, opinions about potential regulatory 

interventions in debt collection markets, and about their knowledge of their legal rights regarding 

debt collections. The information collected through this survey will be used to inform a CFPB 

rule making concerning debt collection and research purposes.

The Dodd-Frank Wall Street Reform and Consumer Protection Act and other federal 

consumer financial laws authorize the Consumer Financial Protection Bureau (CFPB or Bureau) 

to engage in consumer protection rule writing. This PRA clearance is to collect survey data in 

support of CFPB rulewriting around debt collection. The CFPB issued an advance notice of 

proposed rulemaking concerning debt collection on November 6th, 2013. In order for the Bureau 

to improve its understanding of the debt collection market, the CFPB proposes a research project

using the Consumer Credit Panel (CCP), a proprietary sample dataset from one of the national

credit reporting agencies, to survey people who may have had debts in collection.

A. JUSTIFICATION

1. Circumstances Necessitating the Data Collection

The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) 

and other federal consumer financial laws authorize the CFPB to engage in research and 
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general market monitoring activities, to assess trends and emerging risks in consumer 

financial markets.

1 ,2

The Bureau relies on empirical evidence and rigorous research to 

improve its understanding of consumer financial markets for regulatory purposes. 

On November 6th, 2013, the CFPB issued an advance notice of proposed rulemaking 

concerning debt collection. This PRA clearance is to collect survey data in support of 

CFPB rulewriting concerning debt collection and for research and market monitoring 

purposes. The main law that governs debt collection and protects consumers is the 1977 

Fair Debt Collection Practices Act (FDCPA). In 2010, the Dodd-Frank Act revised the 

FDCPA, making the Bureau the first agency with the power to issue substantive rules 

under the statute. The Bureau may also address concerns related to debt collection using 

its authority under the Dodd-Frank Act to issue regulations concerning unfair, deceptive, 

or abusive acts or practices and to establish disclosures to assist consumers in 

understanding the costs, benefits, and risks associated with consumer financial products 

and services.3

There are many businesses in the multi-billion dollar debt collection market. Banks 

and other original creditors may collect their own debts or hire third-party debt collectors. 

Original creditors and other owners of debts also may sell their debts to debt buyers, who 

may collect on the purchased debts or hire third-party debt collectors to recover them. It 

is estimated that there are more than 4,500 debt collection firms in the U.S. 

Debt collection has long been one of the most complained-about subject areas to 

government regulators, including the Federal Trade Commission. Since July 2013, when 

 

1 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) 

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.”

2 DFA Section 1022(c)(4) directs that “in order to support its rulemaking and other functions, the Bureau shall 

monitor for risks to consumers in the offering or provision of consumer financial products or services, including 

developments in markets for such products or services.”

3 DFA Section 1031, 1032.
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the CFPB began accepting debt collection complaints, it has been one of the highest 

categories of grievances. Consumers report that some collectors harass them, demand 

amounts they do not owe, or threaten dire circumstances if they fail to pay, such as jail.

The Bureau is interested in learning about the debt collection system, about consumer 

experiences with the debt collection system, and about how rules for debt collectors 

might protect consumers without imposing unnecessary burdens on industry. The CFPB 

is particularly interested in the accuracy of the information used by debt collectors, 

ensuring that consumers know their rights, and the communications tactics employed by 

debt collectors. The survey proposed is designed to elicit this information from 

consumers, who in many cases are the only source of this type of information. 

2. Use of the Information

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

for a clearance that will allow the Bureau to collect data through a survey to support 

rulemaking concerning debt collection and for research and market monitoring regarding 

this industry. Data collected in this survey will be used to inform rulemaking as well as 

for research purposes. 

The clearance includes pretesting the questionnaires to ensure the collection of 

reliable information while minimizing respondent burden and costs. For example, the 

Bureau may use cognitive interviewing or pretesting to gauge the effectiveness of the 

survey questions and whether respondents understand each question.

This survey is a one-time data collection. A sample of consumers in the United 

States will be randomly drawn from the CCP, a 1-in-48 random sample of de-identified 

credit records acquired from one of the three national credit reporting agencies. The 

CFPB will draw the sample, inform the credit reporting agency of which credit records 

were selected, and the credit reporting agency (which unlike the CFPB has access to the 

direct identifying information related to these records) will mail a copy of the survey 

instrument to consumers whose records were selected. Consumers will be able to 

respond to the survey either by mailing back the paper version of the survey instrument 

using a prepaid envelope or online. All responses will be collected by the credit reporting 
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agency, or a subcontractor, which will remove any direct identifying information that 

respondents may have included, convert the responses into an electronic format, and 

transmit the responses to the CFPB. While the respondents will remain anonymous to the 

CFPB, the survey responses will be supplied with a key that allows the responses to be 

matched with the sampled credit record.

In broad terms, the survey will ask consumers about their experiences with debt 

collectors. Consumers will be asked whether they have been contacted by debt collectors 

in the past, whether they recognized the debt that was being collected, and about their 

interactions with the debt collectors. The survey will also ask consumers about their 

preferences for how they would like to be contacted by debt collectors and for the content 

of messages from a debt collector. A copy of the proposed survey instrument is included 

as part of this notice.

The information collected from this survey will be used to support a potential 

Bureau rulemaking on debt collection. As evidenced in the recent advance notice of 

proposed rulemaking, the Bureau is considering rules concerning debt collection under 

the FDCPA and the Dodd-Frank Act. The Bureau is particularly interested in areas of 

consumer harm within the debt collection system. To that end, the CFPB is interested in 

improving the adequacy of information transferred with debts when debts are placed with 

a collector or sold to a debt buyer. The Bureau would also like to improve the validation, 

dispute, and verification processes to ensure that consumers are receiving accurate and 

useful information and have the ability to dispute invalid debts. In addition, the CFPB is 

considering rules governing communications between collectors, consumers, and third 

parties, including issues relating to technologies introduced in the 36 years since the 

FDCPA was enacted. The Bureau may also clarify or expand prohibitions on unfair, 

deceptive, and abusive acts or practices. Finally, the CFPB may issue rules relating to the 

collection of time-barred debt, litigation practices, recordkeeping, or registration of debt 

collectors.

In addition, survey responses may be used in research projects to better 

understand how the debt collection process works for consumers and for creditors. This 

research will take the form of published research studies or articles in academic journals. 
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Additionally, survey responses may be used to estimate the extent to which information 

about debt collections reported in credit records represents the universe of debt collection 

activities, results from which may be used in conjunction with future samples of the CCP 

to monitor activity in debt collection markets.

The CCP credit record data are proprietary and cannot be shared publicly. To 

allow outside researchers and other interested parties to learn about debt collection 

activities from these data, the CFPB may make a version of the survey data publicly 

available to the extent that such release is legally permissible and consistent with 

protecting consumers’ privacy. Any public-release version of the data would be deidentified and would exclude any direct identifying information. In addition, the CFPB 

may withhold some data elements or take other steps to protect the privacy of 

respondents in any publicly available version of the data.

3. Use of Information Technology

Surveys will be sent by mail to sampled consumers, who will have the option of 

filling out the paper survey and mailing it back using a prepaid envelope or completing 

the survey online. Any paper surveys that are received will be electronically scanned by

a subcontractor of the credit reporting agency, stripped of any direct identifying 

information that the respondent may have included, and converted to an electronic 

format. The data will then be transmitted to the CFPB using a secure FTP server.

4. Efforts to Identify Duplication

There is little information available about the debt collection market. Consumer 

complaints are useful for identifying areas of consumer harm, but may be subject to 

selection bias and may therefore not be representative of the average consumer collection 

experience. The credit records that we use as our sampling frame provide perhaps the 

most comprehensive source of information available about debt collection accounts. 

These data include information about the collection account, such as the original dollar 
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amount of the debt, the date the debt was incurred, the current amount owed, and the 

category of expenditure that generated the debt (e.g., medical care, utility bills, 

insurance). Because we have the credit records for each survey respondent (and nonrespondent), we will be able to incorporate this information and avoid having to ask 

respondents detailed information about their collection accounts.

The information that we intend to collect through these surveys, which includes 

detail about each surveyed consumer’s experiences with the debt collection agency and 

potentially information about debts that are not included in the credit records, is not 

available through other sources.

5. Efforts to Minimize Burdens on Small Entities

No small businesses will be impacted by this study, as survey respondents will be 

individuals only.

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

The proposed clearance will allow the Bureau to collect information on the debt 

collection market from consumers, allowing us to develop a more complete 

understanding of this market and consumers’ experiences with it. Without this data 

collection, policy development at the Bureau will not be as well informed, and the CFPB 

will not be able to achieve its mission as effectively. Since this is a one-time data 

collection, less frequent collection is not possible.

Where appropriate, the CFPB plans to make the results of any research conducted 

using these data publicly available. Additionally, where legally permissible and 

consistent with protecting consumers’ privacy, we envision making the collected survey 

data available to researchers outside of the CFPB and to the public. Therefore, the data to 

be collected under this proposed clearance will not only improve the CFPB’s 

understanding of consumer financial markets, but also increase the knowledge of 

researchers and other policymakers. 
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7. Circumstances Requiring Special Information Collection

There are no special circumstances that require the CFPB to conduct the 

information collection in a manner inconsistent with the guidelines provided in 5 CFR 

1320.5(d)(2). 

8. Consultation Outside the Agency

On March 7, 2014, the CFPB published a Notice and Request for Comment (“the 

notice”) on the proposed survey (79 F.R. 13043). 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.

The Bureau received 59 comments in response to the notice. Comments are 

available in full under Docket # CFPB-2014-0005 at Regulations.gov 

(http://www.regulations.gov/#!docketBrowser;rpp=25;po=0;dct=PS;D=CFPB-2014-

0005)

Commenters included about 40 individuals; ACA International; the Consumer 

Bankers Association; Global Debt Registry; the American Financial Services 

Association; and the American Bankers Association.

The individual commenters were generally supportive of this type of information 

collection. Several commenters stated that the survey would have practical utility by 

providing the CFPB with information about, for example, consumers’ experiences with 

debt collectors. Commenters indicated that this information could lead to better rules and 

procedures and may, in turn, lead to more positive experiences for consumers. 

Several individual commenters indicated that the survey might obtain a higher 

response rate if it were conducted online or by email in part, some commenters 

suggested, because consumers may tend to throw out mail surveys. One commenter 

noted that not everyone has Internet access, however, so that the Bureau should retain the 

option to complete the survey on paper. The Bureau agrees that some respondents may 

find it less burdensome to respond to an online survey, and the Bureau plans to provide 
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an online option. The Bureau recognizes that some respondents may be inclined to 

generally discard mail surveys. However, the survey will use credit records as the 

sampling frame, and compliance with the Fair Credit Reporting Act (FCRA) requires that 

respondents for this survey be contacted through mail sent by the credit reporting agency.

Individual commenters further noted that the quality of survey responses and 

response rates would be increased by, for instance, keeping the number of questions to a 

minimum, using clear and succinct language, and making the purpose and importance of 

the survey clear. The Bureau generally agrees with these comments, and in part in 

response to these comments, the Bureau, for example, shortened the revised survey from 

77 to 65 questions and modified the wording and placement of instructions. The 

individual commenters offered suggestions about the extent to which the survey should 

include open-ended questions as opposed to, for example, closed-ended multiple-choice 

questions. Adding open-ended questions has significant cost implications for a mail 

survey, so the Bureau has compromised by giving respondents an opportunity at the end 

of the survey to raise relevant issues in a single comment space. The Bureau has sought 

to convey the survey’s value and purpose and intends to similarly emphasize this 

information in cover letters or other materials for respondents.

One commenter noted that the survey results could be skewed due to misreporting 

or to systematic differences between respondents and nonrespondents. The Bureau 

recognizes that debt and debt collection are sensitive topics for many consumers. 

Misreporting has been found to be less of a concern for mail surveys than for surveys 

administered by interviewers. In addition, to mitigate respondents’ potential concerns 

that their responses may place them in an unfavorable light, the Bureau may note in cover 

letters or other materials that many consumers have debt and experience with debt 

collection. Consumers may also hesitate to respond to questions about sensitive topics 

due to concerns that their responses may not be kept confidential. This comment 

underscores the importance of this issue. The prior version of the survey specifically 

addressed the anonymity of responses on the cover page, and the revised survey gives 

this information greater emphasis by placing it higher on the cover page, where it may be 

more likely to be read. Further, the Bureau believes that people are more likely to 
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respond and to provide accurate information if the survey’s purpose is clear and the 

survey is perceived as contributing to a public purpose. As noted above, the Bureau 

continues to consider ways to convey the importance of the survey. With regard to 

differences between respondents and nonrespondents, given that the sample frame comes 

from credit records, the Bureau intends to analyze the presence and extent of nonresponse 

bias and to correct for such bias, if detected.

The ABA, ACA, AFSA and CBA each stated that the survey did not sufficiently 

distinguish between creditors and third-party debt collectors. For brevity, the 

questionnaire had defined “debt collector” for the purposes of the survey to comprise 

both first- and third parties. The Bureau generally agrees that it may be beneficial to 

maintain this distinction more clearly. To do so, the revised survey refers to “creditor or 

debt collector” throughout, rather than “debt collector.” In addition, question 28 of the 

revised survey will allow for analysis that may highlight differences, if any, in 

consumers’ experiences with creditors compared with debt collectors.

Industry commenters stated that several survey questions were leading questions 

that, consequently, would yield misleading and biased survey responses. For example, 

the ABA and AFSA expressed this concern about, for instance, the introductory portions 

of question 8 (which has been eliminated) and question 15. This prefatory text in these 

and similar cases is intended to offset the potential misreporting of responses to sensitive 

questions, for example, if respondents felt embarrassed that they did not know their legal 

rights (question 8) or that they had paid a debt they did not think they owed (question 15). 

Several industry commenters stated that the survey was too lengthy. The Bureau 

generally concurs, and, as noted above, the revised survey has been shortened from 77 to 

65 questions. The questions that have been eliminated include several that industry 

commenters maintained were less likely to yield reliable or informative responses. For 

example, commenters stated that it was more informative to know whether respondents 

could obtain relevant information if necessary rather than knowing this information at the 

time of completing the survey (question 8). The revised questionnaire also omits 

questions 23 and 24, in part because, as noted by AFSA, the phrasing “At any time... did 

you think about...” is potentially ambiguous and may result in false positives. The 
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revised survey also excludes question 38 in response, to some extent, to the ABA 

comment that this question may not provide reliable information because respondents 

may not have first-hand knowledge of what the creditor or debt collector did or said. 

The ABA also stated that the survey’s reliability may be reduced by recall bias for 

the questions that require respondents to think about their experiences in the past two 

years. The CFPB agrees with this comment and notes, however, that a shorter recall 

period would reduce the number of responses for many questions. Nonetheless, in 

response to this comment and based on an analysis of data in CCP regarding the potential 

reduction in the share of respondents to whom given questions apply, the survey has been 

revised to have a one-year recall period.

Comments from industry included suggestions about doing the survey online, 

including on mobile devices; pretesting the questionnaire; and selecting a stratified 

sample. These comments generally align with the CFPB’s intentions. As noted in 

sections 2 and 3 of Part A, for example, the CFPB expects that the survey will include an 

online option. However, as discussed above, the Bureau believes it cannot conduct the 

survey exclusively online but instead must contact respondents by mail to ensure 

confidentiality and compliance with FCRA. As noted in Part A, Section 2, the clearance 

includes pretesting. Further, the CFPB intends to select a sample that is stratified by the 

type of collection (e.g., medical or non-medical collection) or past-due loan payment 

(e.g., credit card balance or student loan).

9. Payments or Gifts to Respondents

Survey recipients will receive a cash payment, currently expected to be five 

dollars, as an inducement to complete and return the survey questionnaire. Recipients 

who fail to respond to the initial survey solicitation may receive an additional cash 

inducement of a similar amount.

Meta-analyses of mail surveys find that incentives given initially with the 

questionnaire yield significantly higher response rates than do incentives contingent on 

return of the survey or no incentives; furthermore, monetary incentives produce a 
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stronger effect that non-monetary incentives.4,5 Many recurring federally-funded surveys 

use monetary incentives, including the Survey of Consumer Finances, the Survey of 

Income and Program Participation, and the National Survey of Drug Use and Health, and 

self-administered surveys such as the Survey of Doctorate Recipients, the National 

Survey of Recent College Graduates, and the National Survey of Mortgage Borrowers.

6

Incentives have consistently been found to improve response rates across a variety of 

survey topics and modes.7,8 Incentives have been found to be cost-effective in different 

modes, often reducing the effort required to contact and interview sample persons or 

reduce the number of follow-up mailings.9,10,11

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 CFR Part 1070, and the 

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

confidentiality of personally identifiable information (PII) and for data security and 

integrity. These protections include stipulating in most instances that contractors that collect 

data on behalf of the Bureau remove or redact all direct identifying information before 

transmitting data to the Bureau and that any contractor staff assigned to the project sign 

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

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

 

4 Allan H. Church, “Estimating the Effect of Incentives on Mail Survey Response Rates: A Meta-Analysis,” Public 

Opinion Quarterly 57, no. 1 (1993): 62-79.

5

Phil Edwards, Ian Roberts, Mike Clarke, Carolyn DiGuiseppi, Sarah Pratap, Reinhard Wentz, and Irene Kwan, 

“Increasing Response Rates to Postal Questionnaires: Systematic Review,” British Medical Journal324 

(2002):1183-1189.

6

Fan Zhang, “Incentive Experiments: NSF Experiences,” NSF Working Paper, 2010.

7 Eleanor Singer (2002), “The Use of Incentives to Reduce Nonresponse in Household Surveys.” In R.M. Groves, 

D.A. Dillman, J.L. Eltinge, and R.J.A. Little (eds), Survey Nonresponse. New York: Wiley, pp. 163-177.

8 Eleanor Singer, and Cong Ye (2013), “The Use and Effects of Incentives in Surveys.” The Annals of the American 

Academy of Political and Social Science, 645 (1):112–141.

9 Martha Berlin et al. (1992), “An Experiment in Monetary Incentives.” Proceedings of the Survey Research 

Methods Section, American Statistical Association, pp. 393-398.

10 Eleanor Singer, John Van Hoewyk, and M. Patricia Maher (2000), “Experiments with Incentives in Telephone 

Surveys.” Public Opinion Quarterly, 64 (2): 171-188.

11 Gwen L. Alexander et al. (2008), “Effect of Incentives and Mailing Features on Recruitment for an Online Health 

Program.” American Journal of Preventive Medicine, 34 (5): 382-388.
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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 direct identifying PII or otherwise sensitive information (12 CFR 

1070.40 et seq.). 

Consistent with the Privacy Act and the E-Government Act, a Systems of Records 

Notice (SORN),

12 and a Privacy Impact Assessment (PIA)13 has been published, 

respectively.. The SORN and PIA document the ways in which participants’ direct 

identifying information will be collected, stored, and accessed. 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, the CFPB must ask these questions in order to understand consumer behavior 

and recognize financial trends and emergent risks relevant to consumers. Because these 

types of questions are central to the CFPB mission, we believe that we are justified in asking 

these types of sensitive questions. 

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 risks to vulnerable populations, including service 

members, students, older Americans, and lower-income consumers. For this reason, we feel 

justified in asking these types of sensitive questions. For information collections involving 

questions of race/ethnicity, we 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. 

 

12 CFPB.022, Market and Consumer Research Records, https://www.federalregister.gov/articles/2012/11/14/2012-

27582/privacy-act-of-1974-as-amended

13 Consumer Experience Research PIA, June 30, 2014, http://files.consumerfinance.gov/f/201406_cfpb_consumerexperience-research_pia.pdf
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Respondent participation is voluntary; 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.

Administrative data for respondents and nonrespondents will be used to analyze 

nonresponse bias.

12. Estimated Burden of Information Collection

The CFPB plans to mail surveys to up to 10,000 consumers and estimates a 30

percent response rate. For the estimated 3000 consumers who fill out the survey, we 

estimate that completing the survey will take 20 minutes on average, for a total burden of 

1,000 hours.

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. Postage costs to return the survey questionnaire will be 

pre-paid by the survey contractor.

14. Estimated Cost to the Federal Government

Based on the expenses associated with similar survey projects, we expect this 

survey to cost approximately $400,000. This is the only cost to the government of this 

research project.

15. Program Changes or Adjustments

This is a new information collection request.

16. Plans for Tabulation, Statistical Analysis, and Publication
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We expect data collection to take at least two to three months. Once the data have 

been received, we expect data tabulation and preliminary data analyses to last another four

to five months. These tabulations and analytical results will be published in a publicly 

released research paper. We estimate this paper will be released 6–8 months from the time 

that data collection can begin. If any survey responses are released, they will be made 

publicly available at that time as well.

17. Display of Expiration Date

The Bureau plans to display the expiration date for OMB approval of the 

information collection on all instruments. 

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.