information collection

The CFPB published notices in today’s Federal Register seeking comments on the following information collections:

  • “Consumer Response Government and Congressional Boarding Forms.”  The notice states that the CFPB has developed portals  for state and federal agencies and congressional offices to view and search consumer complaint data.  While not expressly stated in the notice, based on the CFPB’s use of other boarding forms, it would appear that the boarding forms would have to be completed by an agency or office seeking access to the portals.  Comments are due on or before August 24, 2015.
  • A  generic information collection plan to conduct surveys of people about their experiences in consumer credit markets using the Consumer Credit Panel (a proprietary sample dataset from one of the national credit reporting agencies).  The notice states that survey responses “will be used for general, formative, and informational research on consumer financial markets and consumers’ use of financial products and will not directly provide the basis for specific policymaking at the Bureau.”  Comments are due on or before
    July 27, 2015.
  • A generic information collection plan to conduct research to improve the quality of data collection by examining  the effectiveness of data collection procedures and processes, including potential psychological and cognitive issues.  The notice states that the research is intended to “improve [the CFPB’s] understanding of how consumers engage with financial marketplaces.”  Comments are due on or before July 27, 2015.

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.

The CFPB has issued a proposal to conduct a new information collection titled “Development of Metrics to Measure Financial Well-being of Working-age and Older American Consumers.”  The proposed collection is intended to support the CFPB’s financial literacy initiatives

The CFPB intends to collect quantitative data through surveys of working-age (age 18–61) and older American (age 62 and older) consumer.  The data will be used to develop and refine surveys that the CFPB can use to measure adult consumers’ financial well-being and develop measures of financial well-being that provide a standardized basis for setting goals and evaluating financial education strategies and programs.  Comments on the proposal are due by
October 7, 2013.

Earlier this week, the CFPB published in the Federal Register a request for comments on its plans to submit a request to the Office of Management and Budget for generic clearance of an information collection to assist the CFPB’s development of financial education initiatives.  According to the CFPB’s notice, the collection “will focus on identifying financial education and empowerment strategies, practices, and experiences that inform or improve consumer financial decision-making.”  Through the collection, the CFPB hopes to better understand what financial education and empowerment strategies are most effective.  The CFPB plans to collect the information through methods that include in-person meetings, focus groups, surveys and online discussion forums.  Comments on the CFPB’s request are due by
March 18, 2013. 

Also related to the CFPB’s financial education initiatives is another proposed information collection clearance already submitted to OMB titled  “Clearance for Consumer Attitudes, Understanding and Behaviors with Respect to Financial Services and Products.”  Initially proposed in March 2012, the proposed collection is a “yearly consumer research survey to better understand the attitudes, understanding, and behaviors of American adult consumers around issues of consumer finance.”  After conducting an initial baseline survey, the CFPB intends to use subsequent survey results to “assess consumers’ awareness of, engagement in, and the ultimate impact of, the Bureau’s efforts to educate and empower consumers to improve their financial decision-making skills and outcomes.” The CFPB plans to conduct the surveys through use of telephone calls and the Internet.  On December 27, 2012, the CFPB published in the Federal Register a renewed request  for comments on the proposed information collection.  Comments are due by January 28, 2013. 

While these proposed collections are unlikely to be controversial,  the CFPB’s request in June 2012 to OMB seeking generic clearance of the CFPB’s collection of information on compliance costs and other effects of regulations generated objections from several industry trade groups.    

 

In a notice published in the Federal Register on October 10, the CFPB is seeking comments on the request it has submitted to the Office of Management and Budget for generic clearance of its collection of information from providers of consumer financial services and products on compliance costs and other effects of regulations.   

In June, the CFPB had published a notice soliciting comments on its information collection plans in anticipation of that submission.  In response to the June notice, the American Bankers Association and the Consumer Bankers Association submitted a joint comment letter opposing the CFPB’s use of a generic clearance to obtain compliance cost information.  

The ABA and CBA had criticized the CFPB’s use of “sweeping generalities” to describe the methods of collection the CFPB plans to use.  The new notice does not provide new details about such methods beyond adding that “[i]n some cases, the Bureau may also conduct case studies to gather more in-depth and granular information from a targeted sample of institutions.” 

In the new notice, the CFPB has raised its estimates of the number of respondents from 1,500 to up to 2,750 institutions and the total annual burden hours from 1,950 to up to 9,008 hours. 

Comments on the new notice are due by November 9, 2012.