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CONSUMER FINANCIAL PROTECTION BUREAU

PAPERWORK REDUCTION ACT SUBMISSION

INFORMATION COLLECTION REQUEST

SUPPORTING STATEMENT PART A

BRIDGES TO FINANCIAL SECURITY: A MULTI-SITE DEMONSTRATION 

PROJECT

(OMB CONTROL NUMBER: 3170-00xx)

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

request.

ABSTRACT: The Consumer Financial Protect Bureau (CFPB), beginning in 2015, will launch a 

multi-site financial education demonstration project to provide one-on-one and group financial 

counseling/coaching services to individuals with disabilities transitioning into the workplace or 

already employed. The goal is twofold: 1) to improve the financial skills of approximately 

15,000 individuals across the spectrum of disability to effectively navigate the financial 

marketplace, resulting in improved credit, reduced debt, and increased savings; and 2) to build 

the capacity of diverse multi-sector systems (non-disability and disability) in up to 14 cities to 

unite around the common purpose of building financial security for individuals with disabilities.

CFPB envisions the need to collect a combination of client personally identifiable information 

(PII), including direct-identifying PII (i.e., basic contact and demographic information), 
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performance metrics (outputs), as well as other relevant organization-level outcomes. Monthly 

qualitative reports and quantitative aggregated individual data will be collected from 

participating sites to document the design, growth and impact of up to 14 integrated diverse 

delivery models serving primarily low-income populations with disabilities. 

PART A. JUSTIFICATION

1. Circumstances Necessitating the Data collection

The Dodd Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd Frank Act”), 

Public Law 111203, established the Consumer Financial Protection Bureau (“CFPB” or the 

“Bureau”) 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 mission 

is to help consumer finance markets work by making rules more effective, by consistently and 

fairly enforcing those rules, and by empowering consumers to take more control over their 

economic lives.

Section 1013(d)(2) of the Dodd Frank Act mandates that the Bureau provide opportunities for 

consumers to access a range of financial activities, including savings and wealth building, 

financial counseling (including community-based counseling), and information to better 

understand credit products and credit histories. Additionally, Section 1013(b)(2) states that a unit 

shall be established whose function includes providing “information, guidance, and technical 

assistance regarding the offering and provision of consumer financial products to traditionally 

underserved consumers and communities”.
3

The Office of Financial Empowerment at CFPB interprets these provisions as the foundation for 

our vision to serve low-income and economically vulnerable consumers, including individuals 

with disabilities who face unique challenges in meeting their financial needs in the marketplace.

The Office of Financial Empowerment is interested in identifying approaches to support the 

financial capability of individuals with disabilities transitioning into the workforce or reentering 

the workforce after a period of time. 

People with disabilities comprise 12 – 19 percent of the U.S. population1 and experience 

significant disparities in employment and participation in the labor force. The employment rate 

for people with disabilities may be low due to lower educational attainment, individual and 

systemic barriers to employment, and discrimination. Among those who do work, people with 

disabilities, on average, earn about $10,0002 less than people without disabilities. The poverty 

rate of people with disabilities is more than double the rate of those without disabilities.3 These 

economic disparities are further exacerbated by higher costs associated with living with a 

disability. The material conditions, including economic hardship, of people with disabilities may 

inhibit access to high quality of life and well-being. Economic hardships have also been linked to 

significant negative health outcomes, ranging from an increased risk of depression or mental 

illness to an increased risk in mortality.4

 1 Conroy, N.D., McDonald, K.E., Morris, M., & Jennings, E. (2014). Financial Capability of Adults with 

Disabilities. Findings from the FINRA Investor Education Foundation 2012 National Financial Capability Study.

2 StatsRRTC, “Annual disability statistics compendium”, (2013), http://disabilitycompendium.org/compendiumstatistics/earnings. 

3 Ibid.

4 Organization for Economic Co-Operation and Development (OECD). “Well-being and the global financial crisis”, 

http://www.keepeek.com/Digital-Asset-Management/oecd/economics/how-s-life-2013 /well-being-and-the-globalfinancial-crisis_how_life-2013-7-en#page25.
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The positive financial or tax situation of an individual with disabilities transitioning into the 

workforce or reentering the workforce after a period, such as good credit or receipt of the Earned 

Income Tax Credit, often contributes to successful placement and stability on the job. However, 

data indicate that people with disabilities have less overall financial capability compared to other 

Americans.5 The National Disability Institute examined the FINRA Investor Education 

Foundation 2012 National Financial Capability Study and found, among other things, that people 

with disabilities reported greater difficulty in covering monthly expenses and lower financial 

literacy and were less likely to have rainy day funds set aside and more likely to carry credit card 

balances6. Further, the first ever reports produced by the IRS in 20077 and 20108 on the 

characteristics and profile of taxpayers with disabilities highlighted multiple discrepancies, such 

as “1.3 to 1.6 more tax returns could be filed from working disabled residents ages 18 to 59” and 

the need to make tax software readily accessible.9 The IRS surveys found that the majority of 

taxpayers with disabilities reported incomes less than $20,000, yet despite the low Adjusted 

 5

 Conroy, N.D., McDonald, K.E., Morris, M., & Jennings, E. (2014). Financial Capability of Adults with 

Disabilities. Findings from the FINRA Investor Education Foundation 2012 National Financial Capability Study p. 7 

(noting that respondents were identified as having disabilities if they selected “permanently sick, disabled, or unable 

to work” in response to the study’s question on work status).

6 Conroy, N.D., McDonald, K.E., Morris, M., & Jennings, E. (2014). Financial Capability of Adults with 

Disabilities. Findings from the FINRA Investor Education Foundation 2012 National Financial Capability Study p. 7 

(noting that respondents were identified as having disabilities if they selected “permanently sick, disabled, or unable 

to work” in response to the study’s question on work status).

7 Disabilities Research Report Characteristics of Disabled Taxpayers Ages 18 to 59: Study of Filing Patterns and 

Preferences for Receiving Tax information & Services Internal Revenue Service Publication 4640 (10-2007). 

Catalog Number 50912H Department of Treasury Internal Revenue Service www.irs.gov. 8

Taxpayers with Disabilities 2010 IRS report Prepared for Stakeholder Partnerships, Education and Communication. 

Wage & Investment Research & Analysis September 2010. Publication 4640 (Rev.9-2010) Catalog Number 50912H 

Department of the Treasury Internal Revenue Service. www.irs.gov. 9 Disabilities Research Report Characteristics of Disabled Taxpayers Ages 18 to 59: Study of Filing Patterns and 

Preferences for Receiving Tax information & Services Internal Revenue Service Publication 4640 (10-2007). 

Catalog Number 50912H Department of Treasury Internal Revenue Service www.irs.gov. p.32
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Gross Income, over 60 percent reported using paid tax professionals to prepare their most recent 

tax returns.

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Additionally, the most economically vulnerable consumers, of whom persons with disabilities 

are frequently numbered, are part of the “traditionally underserved consumers and communities.” 

These persons are typically the hardest to reach and the most difficult to serve. This necessitates 

in person, individualized guidance delivered at a trusted, convenient, and accessible location. 

This first-of-its kind pilot seeks to determine and demonstrate the value of imbedding financial 

capability services in existing service delivery networks, both providing free financial 

counseling/coaching and disability services to individuals with disabilities. The data collection is 

necessary to help CFPB understand the effectiveness of the approaches and delivery model used 

in this project.

2. Use of the Information

The purpose of the demonstration is to integrate financial capability services into existing service 

delivery systems to improve the problem of financial insecurity for individuals with disabilities. 

The goal is twofold: 1) to improve the financial skills of over 15,000 individuals across the 

spectrum of disability to make more informed financial decisions and effectively navigate the 

financial marketplace resulting in improved credit, reduced debt, and increased savings; and 2) to 

build the capacity of diverse multi-sector systems (non-disability and disability) in up to 14 cities 

to unite around the common purpose of building financial security for individuals with 

 10 Taxpayers with Disabilities 2010 IRS report Prepared for Stakeholder Partnerships, Education and 

Communication. Wage & Investment Research & Analysis September 2010. Publication 4640 (Rev.9-2010) Catalog 

Number 50912H Department of the Treasury Internal Revenue Service. www.irs.gov.
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disabilities.

In order to understand the individual and organizational impact of the program, CFPB envisions 

the need to collect a combination of client personal information (i.e., basic contact and 

demographic information), performance metrics (outputs), as well as other relevant organizationlevel outcomes.

A developmental evaluation that utilizes the client information, performance metrics and 

organization-level outcomes will document the design, growth and impact of up to 14 integrated 

diverse delivery models that serve primarily low-income populations with disabilities. 

The instrument that the coaches will use to gather individual data is attached to this 

submission. The information collected includes demographic information, employment status, 

financial information, receipt of public benefits, and financial behaviors, habits, attitudes and 

skills. The instrument includes questions from the FINRA Investor Education Foundation’s 

National Financial Capability study, which is can be found here, 

http://www.usfinancialcapability.org/about.php According to FINRA this study was developed 

in consultation with the U.S. Department of the Treasury, other federal agencies and President 

Obama's Advisory Council on Financial Capability, and the overarching research objectives are 

to benchmark and measure key indicators of financial capability and evaluate how these 

indicators vary with underlying demographic, behavioral, attitudinal and financial literacy 

characteristics. Using these indicators for which there is nationally representative data will 

enable coaches to have an enhanced understanding of their clients’ financial capability. 
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This may include the accompanying Self-Sufficiency Matrix, which will be used to track a 

customer’s progress over time, based on his or her area of focus. This matrix is a modified 

version of the Arizona Self-Sufficiency Matrix, which has been used a basis for evaluating 

outcomes in other social services programs across the country.11 These questions support the 

main strategy of the Bridges project, which is to integrate financial capability services into 

existing programs that serve people with disabilities. As a result, the categories in the matrix are 

intended to capture the complexity and interconnectedness of family and community support in 

the financial stability of people with disabilities. The breadth of the questions will allow 

customers with disabilities who seek services in these organizations to identify and discuss a 

range of their current financial barriers and solicit help from their coaches in getting appropriate 

services from the host organization or referrals to other community groups. 

Some of the questions and information requested through the financial assessment and follow-up 

exercises may be of a sensitive nature. Additional justification for collecting the data can be 

found in Section 11.

Clients, coaches, and supervisors would provide informed consent before participating in any 

interview and/or survey. The client-level raw data will not be shared outside of the financial 

coaches/counselors working with the clients and the CFPB contractor responsible for collecting 

and analyzing the data. CFPB will not receive client-level raw data or any personally identifiable 

information (PII), including direct-identifying PII. CFPB will receive and may choose to release 

 11 See e.g. Omni Institute, Self-Sufficiency Matrix: An Assessment and Measurement Tool for Boulder County 

Community Services and Housing Programs (June 2009), at

http://communityimpact.unitedwaycm.org/epledge/servlet/eAndar.WebExtDocument/313037/31/DenverStudy; 

Greg White et al., TG 5 Sub-Group: Outcomes and Evaluation of Housing Models (no date), at 

http://www.fairfaxcounty.gov/homeless/forums/presentations/outcomes-and-evaluations.pdf
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de-identified results and aggregated analyses of those results (such as trends in financial issues) 

in public reports it will issue. 

3. Use of Information Technology

Individual outcomes survey data will be collected and recorded by subcontractor staff via Social 

Solutions Global, Inc. (SSG) software. SSG will host the service via a SSG-controlled Website. 

SSG will provide help desk, error correction, and maintenance services for the Solution as per its 

most-current published maintenance schedule

3a. Universal Access and Design 

As part of the overall data collection process, and in accordance with applicable federal law 

(American’s with Disabilities Act and Section 508 of the Rehab Act12), all data collection tools, 

disclosures will be made available in alternative formats. Additionally, any online data collection 

tools will be 508 compliant. 

4. Efforts to Identify Duplication

Some of the data points CFPB will be collecting from participants may already be collected if the 

participants are regular clients within partnering disability organizations. CFPB will consult with 

service providers to identify potential duplication of data collection to determine the utility of 

duplicating data already collected from the participants to ensure that unnecessary duplication 

and undue burden does not occur for participants.

 12 American With Disabilities Act of 1990, 42 U.S.C. 12101; http://www.gpo.gove/fdsys/pkg/USCODE-2009 -

title42/htmlUSCODE-2009-title42-chap126.htm. 
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5. Efforts to Minimize Burdens on Small Entities

Not applicable. Respondents are participants in the Bridges demonstration project and, therefore, 

no small entities are impacted by this collection of information. 

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 on behalf of 

individuals with disabilities.

7. Circumstances Requiring Special Information Collection

There are no special circumstances. The proposed data 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 public 60 days to comment on this proposed new collection of information. 

No comments were received in response to this notice. Further and in accordance with 5 CFR 

1320.5(a)(1)(iv), the Bureau 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.

In the process of developing the procurement for this program, CFPB consulted extensively with

people outside the Bureau.
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Specifically, the Bureau released a public request for information (RFI) in late Fall 2013 to 

solicit feedback from organizations, potential vendors, and experts. The RFI was sent to 

hundreds of stakeholders working with individuals and families with disabilities, including 

organizations serving these respective populations, experts in financial coaching, financial 

counselors, and others. CFPB conducted outreach to several Federal agencies including, the IRS, 

Department of Labor, Social Security, and others to learn more about the disability network and 

understand the best way to deliver services to the respective populations. Further, prior to the 

solicitation, the Bureau convened a two-day meeting in Washington, DC with over two dozen 

key national disability leaders to understand existing financial services and products and needs.

9. Payments or Gifts to Respondents

No payment or gifts will be provided to respondents for the administrative data. No payments or 

gifts will be provided to counselors/coaches or supervisor respondents for interview or survey

responses.

10. Assurances of Confidentiality

The Contractor is committed to securely collecting and using the private collected data under this 

demonstration (i.e., financial assessment data, administrative and program data). The Bridges 

Demonstration will convene a respected advisory board of national disability and financial 

capability experts to assist in the review and ongoing oversight of the project.
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Individuals with disabilities will be informed of the nature of the demonstration and opportunity 

to receive individual or group financial counseling/coaching, and how the information being 

collected will be used. CFPB will market to individuals with disabilities through six separate 

model/sites providing established financial counseling/coaching programs and disability benefits 

training. Each site will advertise the availability of financial counseling/coaching services 

through its marketing and communication collateral. The volunteer opportunity will be offered to 

individuals with disabilities who may drop in to a location or make an appointment. Each 

participate will be screened using the Financial Health Assessment Tool and Informed Consent. 

Participants will then be asked to sign their permission to participate in the demonstration.

Reports produced under this demonstration will not include directly-identifying PII collected 

during the demonstration. Additional PII, such as outcome data or program administrative data, 

such as date of birth, will not be included in reports produced. CFPB will be given aggregate, 

rolled up results, and all individual level data will be stripped of the direct identifiers. All Interim 

and Final Reports and any presentations given on the demonstration will ensure that primary data 

is aggregated to a level at which the individual identities of those who provided the information 

could not reasonably be discerned. 

At the time of initial meeting, a PRA and Privacy notice will be provided to the customer before 

any assessment of information is collected. Information collected will be done in accordance 

with the Privacy Act and as described in the Bureau’s System of Records Notice, CFPB.021 –

Consumer Education and Engagement Records. A revised SORN was submitted to OMB in 

December 2014 and is expected to be published shortly. Furthermore, the Bureau has published a 

PIA, Consumer Education, which outlines how it will manage information collected as part of 
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this program. This PIA can be located on CFPB’s website at 

http://files.consumerfinance.gov/f/201409_cfpb_consumer-education_pia.pdf . 

11. Justification for Sensitive Questions

Financial counselors/coaches will collect direct-identifying Personally Identifiable Information 

(PII) including name and basic contact information to facilitate participation in the counseling 

program. In addition, coaches will collect non-direct identifying demographic data and 

financial/benefits/disability data to understand the impact of the demonstration. Two pieces of 

demographic data that may be collected include gender and citizenship. The purpose for 

collecting these pieces of data are to enable the counselors/coaches to effectively serve each 

client and tailor the programs around each client’s individual financial circumstances, goals, 

knowledge and experiences with the financial system. If these characteristics impact the clients’ 

experiences or opportunities, it is important that the counselors/coaches have that information, 

and can respond as appropriate. In addition, the CFPB needs to understand how these programs 

impact consumers with different demographics or characteristics, to evaluate the program 

effectiveness and make changes, as appropriate, to tailor programs to meet the needs of a range 

of consumers. 

Counselors/coaches specifically trained to pull and review credit (consumer) reports and scores 

may collect other directly identifying information, including Social Security numbers (SSN) and 

financial account information (credit reports), providing the individual with a disability 

understands that providing this information is entirely voluntary and has read and signed

Financial Health Assessment Screening Tool and Informed Consent. Clients will also be given 

the option to pull their credit reports themselves, which would eliminate the need for the 

counselors/coaches to collect their SSN. Clients who choose not to provide their SSN, or who 

choose not to pull or review their own credit report will not be kept from participating in the 

program. The choice to review one’s credit report and score is voluntary and does require that 

the participant provide a SSN for that purpose only. Only the counselors pulling the credit

reports and scores will see that information. No SSN will be recorded into the demonstration data 

collection. Only credit score numbers will be recorded and only at the request of the individual 
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requesting the credit pull. The only reason for pulling the credit score is to link other selfreported financial data and outcomes with credit bureau records. After the credit bureau 

information is accessed and linked to self-reported outcome data, the documents containing the 

SSNs will be destroyed. SSNs will not be used as an administrative identifier or tracking number 

to aid in the delivery of services. An alternative identification number will be developed. SSNs 

will not be collected as a normal course of action for program operation purposed. 

All participation in the financial counseling/coaching project is optional. Sites will be required to 

obtain informed consent to collect information from those who choose to participate. All 

participants will be asked to complete a financial assessment intake form. All participating sites 

and staff will take the necessary precautions to ensure that the information provided by 

individuals will remain secure, as described in Section 10 above.

This is the first time that the collection and analysis of financial data (demographics, financial, 

self-sufficiency and disability specific) of individuals with disabilities is being conducted on a 

national scale. Information collected will help frame the needs of individuals with disabilities

and the systems serving them (state, non-profit or private) to:

1) understand the effectiveness and impact of the financial counseling/coaching models on 

individual debt, credit and savings;

2) understand what community-based model and what channels of service delivery most 

impact individuals with disabilities;

3) understand any unique factors that influence outcomes (role of Waivers, receipt of 

means-tested benefits, asset limits for saving, and lack of access to traditional banking 

services);

4) understand what model of financial education - group or one-on-one counseling/coaching 

is most popular with individuals with disabilities;

5) understand top five most popular financial goals set by individuals with disabilities;

6) understand which financial capability services are most frequently utilized and impact;

7) understand how six different site models worked and how well each is integrated into the 

existing service delivery model overall to build scale and sustainability;

8) produce a series of briefs that document individual and systems impact; 
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9) produce a series of Playbooks for other partners in geographic areas to replicate the 

disability inclusive model; and

10) inform the development of new curriculum and products specifically targeted for 

individuals with disabilities. 

12. Estimated Burden of Information Collection

It is estimated that approximately 15,000 respondents will complete the financial assessment, 

which will take approximately thirty minutes. It is expected that a portion of respondents who 

complete the financial assessment will participate in a subsequent individual financial counseling 

session, in-person, follow-up appointment, and a later electronic financial assessment. 

Estimate of Annualized Time Burden to Respondents (Total Project)

Information 

Collection 

Requirement

Number of 

Respondents

Frequency Total 

Responses

Avg. 

Burden per 

Response 

(hours)

Total 

Burden 

Hours

Financial Assessment 15,120 1 15,120 2.0 30,240

Creating Financial 

Counseling (budget & 

action plans)

6,048 1 6,048 1.0 6,048

In-person Follow-up 

(credit report/bank 

statement review)

3,024 1 3,024 1.9 5,746

Electronic Follow-up 

(doc review, no 

appointment)

2,268 1 2,268 0.2 454

Total 15,120* /////// 37,800 /////////////// 42,488

*The estimated number of responses is 15,120. Respondents to Creating Financial Counseling, In-person Follow-up, 

and Electronic Follow-up are a subset of those responding to the Financial Assessment.

To estimate the value of the time invested by the respondents, an hourly wage of $10.90 was 

used. This wage is representative of the current hourly 25% wage of all occupations available 
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from the Bureau of Labor Statistics13

Estimate of Annualized Time Burden to Respondents (Total Project)

Information Collection 

Requirement

Number of 

Respondents

Total Burden 

Hours

Avg. Hourly 

Wage Rate

Total Cost 

Burden

Financial Assessment 15,120 30,240 $ 10.90 $ 329,616

Recording Financial 

Counseling (budget & 

action plans)

6,048 6,048 $ 10.90 $ 65,923

In-person Follow-up 

(credit report/bank 

statement review)

3,024 5,746 $ 10.90 $ 62,631

Electronic Follow-up 

(no appointment)

2,268 454 $ 10.90 $ 4,949

Total 15,120 42,488 ////////// $ 463,119

13. Estimated Total Annual Cost Burden to Respondents or Record-keepers

This collection of information will not result in any costs to respondents other than those costs 

already captured above in Item 12.

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.

 13 May 2013 National Occupational Employment and Wage Estimates, Bureau of Labor Statistics, 

http://www.bls.gov/oes/current/oes_nat.htm, Accessed 9/11/2014.
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15. Program Changes or Adjustments

This is a new information collection request; therefore, the entire burden associated with this 

collection of information is considered a program change.

16. Plans for Tabulation, Statistical Analysis, and Publication Timetable for Project

Demonstration Sites will provide CFPB with monthly qualitative and quantitative updates on the 

individual site models and data collection to understand how, why and what is working. An 

Interim and Final Year Report will provide CFPB with an analysis of the monthly data reports. 

There are no scheduled publication timetables at this time.
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Timeline for Individual and Systems Evaluation

 INDIVIDUAL DATA PROGRAM SITE DATA

Task Date Task Date

Receive OMB 

Approval

February 1, 2015 Pre-Contract: Complete 

site needs self-assessment

October 2014

Program enrollment 

on a rolling basis for 

at least five months of 

treatments

March 1, 2015 –

July 31, 2015

Pre Contract: Complete 

analysis of selfassessment to establish 

training and technical 

assistance needs

November 2014

Administer Financial 

Assessment Survey 

and Collect Informed 

Consent

Ongoing Pre Contract:

Sites provide customer 

flow information to 

inform best intersections 

for service delivery

December 2014

Complete collection 

and provide analysis 

of administrative and 

impact data

July 31, 2015 –

August 31, 2015

Contract Period:

Monthly online reports to 

share what is working 

what is not

January 2015 – July 

2015

Complete Baseline 

Year Report

September, 2015 Contract Period:

Monthly aggregated data 

reports uploaded to 

Bridges portal and shared 

with CFPB.

March 2015 – July 

2015

17. Display of Expiration Date

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

information collection on all data collection materials.

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.