The CFPB has published two Federal Register notices seeking comments on its plans to request approval from the Office of Management and Budget for two new generic information collection plans. Comments on both plans are due on or before May 22, 2015.
One notice requests comments on a “Generic Information Collection Plan for Surveys Using the Consumer Credit Panel.” According to a statement submitted by the CFPB in support of the request, the CFPB has acquired a nationally representative sample of de-identified consumer credit records (Consumer Credit Panel or CCP) from one of the three national credit reporting agencies. The sample includes approximately “5 million de-identified credit records representing the universe of approximately 240 million credit records.” The credit records are updated quarterly.
The CFPB plans to randomly survey individuals with credit records included in the CCP. For each survey conducted under the generic clearance, unique record locators assigned to sampled credit records would be sent to the CRA along with a survey instrument designed by the CFPB. The CRA would identify the consumers associated with each sampled credit record and mail the survey instrument. Responses will be sent to the CRA’s subcontractor who will then remove any direct identifying personal information in a consumer’s response and send the de-identified data to the CFPB.
A second notice requests information on a “Generic Information Collection Plan to Conduct Cognitive Research and Pilot Testing.” The generic clearance is intended to allow the CFPB to pretest research instruments on a small scale prior to their use in full-scale research studies. According to the CFPB’s supporting statement, pretesting will allow the CFPB to develop, test and improve its survey and data collection instruments and methodologies.