View Information Collection Request (ICR) Package

OMB Control No: 3170-0018	ICR Reference No: 201203-3170-001
Status: Historical Active	Previous ICR Reference No: 201202-3170-002
Agency/Subagency: CFPB	Agency Tracking No:
Title: Qualitative Testing of Mortgage Servicing Related Model Forms and Disclosures
Type of Information Collection: No material or nonsubstantive change to a currently approved collection	Common Form ICR: No
Type of Review Request: Emergency	Approval Requested By: 01/16/2012
OIRA Conclusion Action: Approved without change	Conclusion Date: 04/18/2012
	Date Received in OIRA: 03/22/2012
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	07/31/2012	07/31/2012	07/31/2012
Responses	396	0	396
Time Burden (Hours)	108	0	108
Cost Burden (Dollars)	0	0	0

Abstract: This is a request for emergency clearance by the Consumer Financial Protection Bureau (CFPB or Bureau) to allow for qualitative testing of mortgage servicing related model forms and disclosures. The research will result in the development of, and revisions to, proposed and final model forms and disclosures provided to consumers in connection with mortgage loan obligations after origination. The research activities will be conducted primarily by an external contractor (Contractor) employing cognitive psychological testing methods. This approach has been demonstrated to be feasible and valuable by the CFPB and other agencies in developing disclosures and other forms. The planned research activities will be conducted during FY 2012 with the goal of creating effective disclosures and related materials for consumers regarding mortgage loan obligations after origination.

Emergency Justfication: The Consumer Financial Protection Bureau (CFPB or Bureau) respectfully requests emergency processing and approval of the collection of information to be used for the qualitative testing of mortgage servicing related model forms and disclosures. The collection is needed prior to the expiration of the time periods set out in 5 C.F.R. Part 1320. The Dodd-Frank Wall Street Reform and Consumer Protection Act, Public Law No. 111-203, Title XIV (Dodd-Frank Act), requires the CFPB to publish, in final form, certain mortgage servicing rules by January 21, 2013. These rules implement sections 1418 (Reset of Hybrid Adjustable Rate Mortgages), 1420 (Periodic Mortgage Loan Statements) and 1463 (Force-Placed Insurance Disclosures) of the Dodd-Frank Act. The CFPB has determined that model forms and disclosures are required for these rules. The CFPB has determined that qualitative testing is necessary to effectively test the model forms and disclosures. The CFPB has further determined that the qualitative testing of the forms, as part of the iterative design process, needs to be initiated in January 2012, to allow for three rounds of testing to be conducted in three cities, with sufficient time for analysis and revisions between each round. The aggressive schedule is necessary so that the Bureau can publish the final rules by January 21, 2013, as mandated in the Dodd-Frank Act. In order to meet that deadline, the Bureau must draft proposed rules, complete impact analyses and other applicable requirements, provide commenters with a 60 day comment period with respect to a proposed rule, allow enough time to consider the comments received, and issue the final rules. To meet these requirements, the Bureau needs to be able to publish a proposed rule by July 2012. Without model forms and disclosures printed in final form by January 21, 2013, consumers will not gain the benefit of clear, uniform, and tested forms and disclosures and mortgage servicers will find themselves subject to provisions of the Dodd-Frank Act without the benefit of model forms or disclosures to help them comply with their obligations. The CFPB published a generic clearance for notice and comment on November 2, 2011 and intends to finalize that clearance. However, given the timing constraints of the project, the CFPB cannot reasonably comply with the normal clearance procedures under 5 C.F.R. Part 1320 with respect to this information collection and still meet the January 21, 2013 deadline. Accordingly, the CFPB respectfully requests emergency processing and approval of the collection of information to be used for the qualitative testing of mortgage servicing related model forms and disclosures so that consumer testing may begin by January 20, 2012.

Authorizing Statute(s): PL: Pub.L. 111 - 203 X Name of Law: Wall Street Reform and Consumer Protection Act

Citations for New Statutory Requirements: PL: Pub.L. 111 - 203 X Name of Law: Wall Street Reform and Consumer Protection Act

Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

Federal Register Notices & Comments
30-day Notice:	Federal Register Citation:	Citation Date:
	76 FR 77766	12/14/2011
Did the Agency receive public comments on this ICR? No

Number of Information Collection (IC) in this ICR: 2

IC Title	Form No.	Form Name
Cognitave Think-Aloud Interviews
Screening

ICR Summary of Burden

	Total Approved	Previously Approved
Annual Number of Responses	396	396
Annual Time Burden (Hours)	108	108
Annual Cost Burden (Dollars)	0	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement:

Annual Cost to Federal Government:

Does this IC contain surveys, censuses, or employ statistical methods? Yes Part B of Supporting Statement

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? Yes

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

Agency Contact: Lea Mosena 202 435-7152

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