Justification for Change - Revised Application Form

Consumer Financial Protection Bureau
Paperwork Reduction Act Change Request
Consumer Advisory Boards, Groups and Committees
OMB No. 3170-0037

Overview
The Dodd-Frank Wall Street Reform and Consumer Protection Act mandated that the
CFPB establish a Consumer Advisory Board (CAB) in order to receive input on issues under the
CFPB’s purview such as the creation of regulation or enforcement of existing laws. In addition
to the CAB, the Bureau also established the Academic Research Council (ARC), the Community
Bank Advisory Council (CBAC), and the Credit Union Advisory Council (CBAC). In order to
populate these four groups with a wide array of expertise and diverse representation, the Bureau
asks that interested parties submit an application for review.
In 2012, the Bureau used the application form shown in Appendix 1 to gather candidate
information and received approximately 1,700 applications. Subject to the spirit of the
Paperwork Reduction Act, the Bureau has reviewed the form and believes that a number of
changes, while relatively minor in nature, will substantively reduce the burden of the form for
the vast majority of applicants that choose to apply to any one of the groups. The proposed
form is below in Appendix 2, the changes (many of which are organizational in nature) are
outlined here.
We estimate that the changes proposed below will dramatically decrease the burden on
candidates in terms of both time and effort required. The original version of the form was
estimated to take approximately 60 minutes per response, on average. We estimate that
removing the sections on Assets and Liabilities and swapping in financial institution background
information questions will result in a time saving of 10 – 15 minutes for the vast majority of
applicants. Assuming we have 1,700 applicants (the same number as we had in 2012) we
estimate a total time saving for the public of 425 hours (see Appendix 3 for old vs. new form
comparison).

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Consumer Financial Protection Bureau
Paperwork Reduction Act Change Request
Consumer Advisory Boards, Groups and Committees
OMB No. 3170-0037

Proposed Changes
1) Added “Part 1” header above page 1
Purpose: Clarification

2) Added “(Select only one)” after the words “identify your area of expertise” on page 1
Purpose: Clarification

3) Removed the entire “Assets and Income” section (Part 1 of the old form)
Purpose: Reduce the burden on the public. This is information that we will collect from
a small sub-group of applicants as we move past initial rounds of vetting and reach a
short-list of finalists

4) Combined the “Affiliations and Representations” and “Positions with Boards, Advisory
Councils, and Other Groups” sections into a single unified section
Purpose: Reduces redundancy of the form, potentially eliminating confusion and
reducing the number of pages as well as the amount of time required to complete the
application

5) Removed the entire “Liabilities” section (Part III of the old form)
Purpose: Reduce the burden on the public. This is information that we will collect from
a small sub-group of applicants as we move past initial rounds of vetting and reach a
short-list of finalists

6) Added “Financial Institution Background” section
Purpose: Applicants will be able to provide general information about the financial
institutions they represent. These questions will only concern basic knowledge readily
available to applicants regarding their organization. These pieces of information, such as
financial institution asset size, geographic locale, or credit union designation, will help
the Bureau create diverse representative advisory groups.
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Consumer Financial Protection Bureau
Paperwork Reduction Act Change Request
Consumer Advisory Boards, Groups and Committees
OMB No. 3170-0037

Appendix 1
The currently approved Application Form is available in OMB’s ROCIS system under the IC
titled “Application to Serve on Advisory Board”.

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Consumer Financial Protection Bureau
Paperwork Reduction Act Change Request
Consumer Advisory Boards, Groups and Committees
OMB No. 3170-0037

Appendix 2
Proposed new form is available in OMB’s ROCIS system under the IC titled “Application to
Serve on Advisory Board”.

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Consumer Financial Protection Bureau
Paperwork Reduction Act Change Request
Consumer Advisory Boards, Groups and Committees
OMB No. 3170-0037

Appendix 3
Comparison of estimated average time required to complete old versus new application form. In
all, changing to the new form will save the public 425 burden hours.

Old
Application
New
Application
Difference
(Savings)

Number of
Applicants

Minutes per
Applicant

Total Time
(Minutes)

Total Time
(Hours)

1,700

60

90,000

1,700

1,700

45

67,500

1,275

0

(15)

(25,500)

(425)

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