On November 2, 2011, the Bureau published a Notice and Request for Public Comment in the Federal Register regarding its collection of generic information in connection with the development and testing of its model forms and related material. This notice, required by the Paperwork Reduction Act, invites the general public and other federal agencies to comment on the proposed information collection. Comments must be received on or before January 3, 2012.

The CFPB expects to collect qualitative data through a variety of collection methods, including interviews and research, to assist in the design, development and implementation of the model form(s), disclosures, tools and other similar related materials. The information collected through qualitative evaluation methods will inform the design and content of the model form(s), using an iterative process to improve the draft disclosures. For example, information collected from consumers will help the CFPB design model forms, disclosures, tools and similar related materials that are responsive to consumer needs and present complex information in an understandable form.  

The CFPB will only submit a collection for approval under this generic clearance if it meets the following conditions:

  • The collection is voluntary;
  • The collection is low-burden for respondents (based on considerations of total burden hours, total number of respondents or burden-hours per respondent) and are low-cost for both the respondents and the federal government;
  • Personally identifiable information is collected only to the extent necessary, subject to privacy protections, and is not retained;
  • Information gathered and released beyond the CFPB will indicate the qualitative nature of the information; and
  • Information gathered will yield qualitative information; the collections will not be designed or expected to yield statistically reliable results or used as though the results are generalizable to the population of study.  

The core objective of the data collection is to help identify, evaluate and refine specific features of the content or design of the model forms, disclosures, tools and other similar related materials to maximize communication effectiveness while minimizing the compliance burden.