SPST A - 0167 Unbanked Underbanked Household Survey 2017

SPST A - 0167 Unbanked Underbanked Household Survey 2017.docx

National Survey of Unbanked and Underbanked Households

OMB: 3064-0167

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SUPPORTING STATEMENT

National Survey of Unbanked and Underbanked Households

3064-0167


The Federal Deposit Insurance Corporation (FDIC) is requesting approval from the Office of Management and Budget (OMB) to revise its National Survey of Unbanked and Underbanked Households (“Household Survey”), which is administered as a supplement to the U.S. Census Bureau’s Current Population Survey (CPS). The survey is a key component of the FDIC’s efforts to comply with a Congressional mandate and collects basic data about individuals who do not have an account at a bank or credit union (the “unbanked”) and individuals who have a deposit account but also rely on alternative, non-bank financial service providers (such as check cashing firms) for transaction or credit services (the “underbanked”). Respondents to the survey are classified as unbanked or underbanked based on their responses to the survey questions. When paired with answers to household characteristics questions in the CPS, the survey provides an estimate of the numerical and financial size of the unbanked market in the United States. The Household Survey is the only nationally- and state-representative survey of this type for the United States.


A. JUSTIFICATION


  1. Circumstances and Need


The Federal Deposit Insurance Corporation (FDIC) recognizes that public confidence in the banking system is strengthened when banks effectively serve the broadest possible set of consumers. As a result, the agency is committed to increasing the participation of unbanked and underbanked households in the financial mainstream by ensuring that all Americans have access to safe, secure, and affordable banking services. The Household Survey is one contribution to this end.


The FDIC has administered the Household Survey approximately every two years as a supplement to the CPS since January 2009. The FDIC is requesting approval from OMB to revise the Household Survey instrument scheduled to be administered as part of the June 2017 CPS.


The Household Survey is also a key component of the FDIC’s efforts to comply with a Congressional mandate contained in section 7 of the Federal Deposit Insurance Reform Conforming Amendments Act of 2005 (“the Act”), Pub. L. 109-173, which requires the FDIC to conduct ongoing surveys on “efforts by insured financial institutions to bring those individuals and families who have rarely, if ever, held a checking account, a savings account, or other type of transaction or check cashing account at an insured depository institution (the “unbanked”) into the conventional finance system.” The mandate further requires the FDIC to estimate the size and worth of the unbanked market in the United States and to identify the cultural, language and identification issues and transaction costs that prevent unbanked individuals from establishing conventional accounts.


To obtain this information, the FDIC partnered with the U.S. Census Bureau, which administered the Household Survey supplement to households that participated in the January 2009, June 2011, June 2013 and June 2015 CPS. The results of these surveys were released to the public in December 2009, September 2012, October 2014, and October 2016, respectively.


The Household Survey has yielded nationally-representative data, not otherwise available, on the size and characteristics of the population that is unbanked or underbanked, the use by this population of alternative financial services (AFS), and the reasons why some households do not make greater use of mainstream banking services. The Household Survey is the only population-representative survey conducted at the national level that provides state-level estimates of the size and characteristics of unbanked and underbanked households for all 50 states and the District of Columbia. An executive summary of the results of the previous Household Surveys, the full reports, and the survey instruments can be accessed through the following link: http://www.economicinclusion.gov/surveys/


Based on past survey experience, feedback received in response to the 2015 survey, and recent research focused on economic inclusion topics, the FDIC has revised the Household Survey for 2017. The revisions preserve successful elements of the 2015 survey, reorganize and revise existing questions, and add questions to gain new insights. These new and revised questions provide a comprehensive view of households’ use and sources of financial services related to transactions, credit, and savings. The new questions will increase our understanding of how households meet their banking needs by informing the frequency of bank branch visits, the use of different types of bank mobile activities, and usage of different mainstream credit products (mortgage, student debt, auto loan, and other loans by bank and non-bank providers). In addition miscellaneous changes to language and universe descriptions were made for clarity.


In order to keep the survey instrument short and accommodate the new questions, a number of questions were dropped from the survey. Revisions made to the survey can be found in Attachment A-2.

2. Use of Information Collected


The FDIC uses the information collected from the survey to produce studies on the number and the characteristics of unbanked and underbanked households in the United States and the factors that may inhibit their use of products and services offered by insured depository institutions. The results are published and used to inform policymaking on issues related to economic inclusion and also to inform bank efforts to serve the unbanked and underbanked. The survey results and corresponding data are publicly available at: www.economicinclusion.gov.

3. Use of Technology to Reduce Burden


The Census Bureau collects CPS data using computer-assisted methods. Specifically, it uses computer-assisted personal interviewing (CAPI) for conducting in-person interviews and computer-assisted telephone interviewing (CATI) for conducting telephone interviews.


  1. Efforts to Identify Duplication


Other than the Household Survey, there is currently no single source of national, metropolitan, and state-level data for the United States on the number of unbanked and underbanked households, their characteristics, and the factors preventing or limiting their use of financial services offered by insured depositories. While a number of studies and surveys have been conducted on the general topic of the unbanked and underbanked households, these studies have focused on either narrow geographic areas within the United States, often including limited subsets of the unbanked and underbanked population, or extremely broad, nationally aggregated survey data measures for the unbanked population. In addition, these other studies and surveys do not collect information about households’ use of AFS.


  1. Minimizing the Burden on Small Entities


The collection of information does not involve small businesses or other small entities.

  1. Consequences of Less Frequent Collection


FDIC’s statutory mandate requires the conduct of studies every two years to estimate the size and worth of the unbanked market in the United States and to identify the cultural, language and identification issues and transaction costs that most prevent unbanked individuals from establishing conventional accounts.


7. Special Circumstances


There are no special circumstances.


8. Consultation with Persons Outside the FDIC


On November 25, 2016 (81 FR 85222), the FDIC issued an initial request for comment on possible revisions to the Household Survey. The FDIC received no comments related to this survey effort.



  1. Payment or Gift to Respondents


No payments or gifts will be given to respondents.


10. Confidentiality


The Census Bureau will collect data in compliance with the Privacy Act of 1974 and the OMB Circular A-130. New and returning households receive an advance letter approximately one week before the initial start of the CPS interview (see Attachment B). The letter includes the information required by the Privacy Act of 1974, explains the voluntary nature of the survey, and states the estimated time required for participating in the survey. Field representatives (FRs) must ask if the respondent received the letter and, if not, provide a copy and allow the respondent sufficient time to read the contents. Also, FRs provide households with the pamphlet, How the Census Bureau Keeps Your Information Strictly Confidential and Fact Sheet for the Current Population Survey (Attachments C1 and C2). All information given by respondents to Census Bureau employees is held in strict confidence under Title 13, United States Code, Section 9. Each Census Bureau employee has taken an oath to that effect and is subject to a jail penalty or substantial fine if he or she discloses any information. The FDIC will receive a microdata file containing the full battery of labor force and demographic data along with data from the supplemental survey. The actual identities of survey respondents will not be included in the data file received by the FDIC. Per the Federal Cybersecurity Enhancement Act of 2015, all data is  protected from cybersecurity risks through screening of the systems that transmit the data.



11. Information of a Sensitive Nature


The study conforms to privacy rules and Census Bureau criteria and does not request any information of a sensitive nature.


12. Estimate of Annual Burden



Frequency of Response: Once.

Affected Public: U.S. Households.

Estimated Number of Respondents: 40,000.

Average time per response: 9 minutes (0.15 hours) per respondent.

Estimated Total Annual Burden: 0.15 hours x 40,000 respondents = 6,000 hours.



13. Capital, Start-up, and Operating Costs


There are no anticipated capital, start-up, or operating costs.


  1. Estimates of Annualized Cost to the Federal Government


The estimated annual cost to the FDIC is approximately $850,000.


15. Reason for Change in Burden


The Census Bureau provided actual administration times associated with the 2015 Household Survey, which were lower than the estimate of 12 minutes included in the 2015 request to OMB. We estimate that the revisions made in the 2017 survey instrument did not impact the average response time. The average time of 9 minutes for the survey burden estimate reflects the actual average time spent by 2015 survey respondents, of 8 minutes with a cushion of 1 minute to be conservative. In addition, the number of survey respondents was conservatively adjusted based on 2015 results.


16. Publication


The findings of this survey will be published by the FDIC.


17. Exceptions to Expiration Date Display


The FDIC has been advised that the Census Bureau has requested a waiver of the requirement to display the expiration for the CPS because the respondents’ length of participation in the CPS is not likely to coincide with the expiration date of this clearance. To avoid confusion that may arise from this fact and given that the CPS has been in place for over 50 years and the basic CPS interview has remained relatively unchanged over the past 8 1/2 years, we request a waiver of the requirement to display the expiration date.


  1. Exceptions to Certification


None.



ATTACHMENTS

A1. 2017 FDIC National Survey of Unbanked and Underbanked Households

A2. Redlined version of the survey instrument highlighting differences relative to the 2015 survey.

A3.A. 2015 FDIC National Survey of Unbanked and Underbanked Households Report

A3.B. 2015 FDIC National Survey of Unbanked and Underbanked Households Report- Appendices

B. Current Population Survey – Advance Letter and Frequently Asked Questions

C1. Current Population Survey Confidentiality Brochure

C2. Fact Sheet for the Current Population Survey

D. Current Population Survey Design and Methodology Overview, October 2006 (available at the following link: http://www.census.gov/prod/2006pubs/tp-66.pdf



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