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Empire Justice Center Comments on CFPB's Proposal to Survey Consumers

May 23, 2012


May 22, 2012

Consumer Financial Protection Bureau
Attention: Chris Willey, Chief Information Officer
1700 G Street NW., Washington, DC 20552

Submitted electronically via:

Re: Docket No. CFPB–2012–0012. Proposed information collection to better understand the attitudes, understanding, and behaviors of American adult consumers around issues of consumer finance.

Dear Mr. Willey:

Empire Justice Center is responding to the CFPB’s request for comments around its proposed annual survey to better understand consumer attitudes, understanding, and behaviors around issues of consumer finance. 

Empire Justice is a statewide public interest law firm that focuses on “systems change advocacy” – changing the systems under which poor, low income and economically vulnerable New Yorkers live. We do this through three major and interconnected areas of service: providing training, support and technical assistance to legal services and other community-based organizations to strengthen their work; offering legal assistance and undertaking impact litigation; and engaging in policy analysis, research and advocacy.

Creating Assets, Savings and Hope (C.A.S.H.) is a community coalition led by Empire Justice Center and the United Way of Greater Rochester. C.A.S.H. was established in 2002 to help low-income workers make the most of their money and build stronger financial futures. In addition to serving more than 12,000 working families each year at VITA (Volunteer Income Tax Assistance) sites, C.A.S.H. offers free and confidential financial coaching to help lower income consumers manage their money and improve their financial future. Over a period of nine months, a trained volunteer works one-on-one with a consumer to help them: start and keep a budget; develop stronger money management skills; save towards a goal; and better understand credit.

First, rather than create a general survey, we recommend that the CFPB identify one or two key issues of focus by utilizing the research and data already available from a variety of scholarly, legal and advocacy sources on consumer attitudes, understanding and behaviors regarding consumer finance issues. This will help the CFPB to cost-effectively target its initial education and outreach efforts to one or two key issues.

Next, to best utilize limited staff and financial resources, we urge the CFPB to focus its qualitative data collection efforts on the one or two issues chosen for initial education and outreach. This will allow the survey to go deeper on the issue(s), permitting the Bureau to better understand consumer attitudes and behavior on the specific issue(s) within the proposed 20 question limit.

Before doing the survey with the proposed 2500 consumers, we recommend that the CFPB use the resources as proposed in Docket No. CFPB–2012–0011 to draft a prototype survey and conduct a test with actual consumers on the questions you expect to ask. This should help to clarify language and minimize misinterpretation by consumers.  Subsequent annual surveys are not necessarily the only way the CFPB has to evaluate the effectiveness of its education and outreach efforts. We recommend that the CFPB explore ways to have the agencies and community organizations with which the Bureau shares its educational information to gather evaluation data on the changes in attitudes, understanding and behavior of the people with whom these organizations work.

As an additional resource, we are attaching the survey used by the C.A.S.H. Coach Program. Empire Justice Center hopes the CFPB finds these comments useful as it develops its qualitative consumer survey. We look forward to working with the Bureau on these efforts, as well as many others.

Barbara van Kerkhove, Ph.D.
Researcher/Policy Analyst

For more information, please contact:

Barbara van Kerkhove

Empire Justice Center
Telesca Center for Justice
One West Main Street, Suite 200
Rochester, NY  14614

(585) 454-4060
(585) 454-2518


Supporting Documents:

CFPB's Proposal to Survey Consumers