Supporting Statement for 2025 Renewal of Generic Clearance (2025 Renewal)

Supporting Statement for Paperwork Reduction Act Generic Information Collection
Submissions for
“Generic Clearance for the Collection of Qualitative Feedback on Agency Service Delivery”
A. JUSTIFICATION
1. Circumstances Making the Collection of Information Necessary
Executive Order 12862 directs Federal agencies to provide service to the public that matches or exceeds
the best service available in the private sector. In order to work continuously to ensure that our
programs are effective and meet our customers’ needs, Securities and Exchange Commission (hereafter
“the Agency”) seeks to obtain OMB approval of a generic clearance to collect qualitative feedback on
our service delivery. By qualitative feedback we mean information that provides useful insights on
perceptions and opinions but are not statistical surveys that yield quantitative results that can be
generalized to the population of study.
This collection of information is necessary to enable the Agency to garner customer and stakeholder
feedback in an efficient, timely manner, in accordance with our commitment to improving service
delivery. The information collected from our customers and stakeholders will help ensure that users
have an effective, efficient, and satisfying experience with the Agency’s programs. This feedback will
provide insights into customer or stakeholder perceptions, experiences and expectations, provide an
early warning of issues with service, or focus attention on areas where communication, training or
changes in operations might improve delivery of products or services. These collections will allow for
ongoing, collaborative and actionable communications between the Agency and its customers and
stakeholders. It will also allow feedback to contribute directly to the improvement of program
management.

2. Information Collection Purpose and Use
Improving agency programs requires ongoing assessment of service delivery, by which we mean
systematic review of the operation of a program compared to a set of explicit or implicit standards, as a
means of contributing to the continuous improvement of the program. The Agency will collect, analyze,
and interpret information gathered through this generic clearance to identify strengths and weaknesses
of current services and make improvements in service delivery based on feedback. The solicitation of
feedback will target areas such as: timeliness, appropriateness, accuracy of information, courtesy,
efficiency of service delivery, and resolution of issues with service delivery. Responses will be assessed
to plan and inform efforts to improve or maintain the quality of service offered to the public. If this
information is not collected, vital feedback from customers and stakeholders on the Agency’s services
will be unavailable.
The Agency will only submit a collection for approval under this generic clearance if it meets the
following conditions:
•

Information gathered will be used only internally for general service improvement and program
management purposes and is not intended for release outside of the agency (if released,
procedures outlined in Question 16 will be followed);

•
•
•
•
•
•
•

Information gathered will not be used for the purpose of substantially informing
influential policy decisions 1;
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 collections are voluntary;
The collections are 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;
The collections are non-controversial and do not raise issues of concern to other
Federal agencies;
Any collection is targeted to the solicitation of opinions from respondents who have
experience with the program or may have experience with the program in the near
future; and
With the exception of information needed to provide remuneration for participants of
focus groups and cognitive laboratory studies, personally identifiable information (PII) is
collected only to the extent necessary and is not retained.

If these conditions are not met, the Agency will submit an information collection request to
OMB for approval through the normal PRA process.
To obtain approval for a collection that meets the conditions of this generic clearance, a
standardized form will be submitted to OMB along with supporting documentation (e.g., a copy of
the comment card) and communicate any particular timing constraints. The submission will have
automatic approval, unless OMB identifies issues within 5 business days.
The types of collections that this generic clearance covers include, but are not limited to:
•
•
•
•
•
•

Customer comment cards/complaint forms
Small discussion groups
Focus Groups of customers, potential customers, delivery partners, or other stakeholders
Cognitive laboratory studies, such as those used to refine questions or assess
usability of a website;
Qualitative customer satisfaction surveys (e.g., post-transaction surveys; opt-out web
surveys)
Recruitment questionnaires

The Agency has established a manager/managing entity to serve for this generic clearance and
will conduct an independent review of each information collection to ensure compliance with
As defined in OMB Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of
Information Disseminated by Federal Agencies, “influential” when used in the phrase “influential scientific,
financial, or statistical information” means that “the agency can reasonably determine that dissemination of the
information will have or does have a clear and substantial impact on important public policies or important private
sector decisions.” As defined in the Commission’s Final Data Quality Assurance Guidelines, “influential” is a
specialized term that means certain scientific, financial or statistical information that the agency can reasonably
determine will have or does have a clear and substantial impact on important public policies or important private
sector decisions.

1

the terms of this clearance prior to submitting each collection to OMB.

3. Consideration Given to Information Technology
If appropriate, agencies will collect information electronically and/or use online collaboration
tools to reduce burden.

4. Duplication
No similar data are gathered or maintained by the Agency or are available from other sources
known to the Agency.

5. Reducing the Burden on Small Entities
Small business or other small entities may be involved in these efforts but the Agency will
minimize the burden on them of information collections approved under this clearance by
sampling, asking for readily available information, and using short, easy-to-complete information
collection instruments.

6. Consequences of Not Conducting Collection
Without these types of feedback, the Agency will not have timely information to adjust its
services to meet customer needs.

7. Special Circumstances
There are no special circumstances. The information collected will be voluntary and will not be
used for statistical purposes.

8. Consultations with Persons Outside the Agency
In accordance with 5 CFR 1320.8(d), a 60-day notice for public comment was published in the
Federal Register. No public comments were received.

9. Payment or Gift
The Agency will not provide payment or other forms of remuneration to respondents of its
various forms of collecting feedback.

10. Confidentiality
If a confidentiality pledge is deemed useful and feasible, the Agency will only include a pledge of
confidentiality that is supported by authority established in statute or regulation, that is
supported by disclosure and data security policies that are consistent with the pledge, and that
does not unnecessarily impede sharing of data with other agencies for compatible confidential
use. If the agency includes a pledge of confidentiality, it will include a citation for the statute or

regulation supporting the pledge.

11. Sensitive Nature
No questions will be asked that are of a personal or sensitive nature.

12. Burden of Information Collection
A variety of instruments and platforms will be used to collect information from respondents. The
annual number of respondents requested (30,000) and the annual burden hours requested (5,000)
are based on the number of collections we expect to conduct over the requested period for this
clearance.

Estimated Annual Reporting Burden
Type of Collection
Online Form, Phone Call, Email
survey, Post-Event Survey, etc.

No. of
Respondents
30,000

Annual Frequency
per Response

Time per Response

Total Hours

1

10 Minutes

5,000 Hours

13. Costs to Respondents
No costs are anticipated.

14. Costs to Federal Government
The anticipated cost to the Federal Government is approximately $300,000 annually.

15. Reason for Change
There has been an increase in the estimated number of respondents and annual burden hours
previously reported for this clearance. The estimated number of respondents and annual burden
hours have increased to accommodate the existing collections that we expect will be continued
over the requested period for this clearance and to allow for new collections.
The estimated number of respondents has increased from 20,000 to 30,000 and the estimated
burden hours has increased from 3,500 to 5,000 hours.

16. Information Collection Planned for Statistical Purposes
Feedback collected under this generic clearance provides useful information, but it does not yield
data that can be generalized to the overall population. Findings will be used for general service
improvement, but are not for publication or other public release.

Although the Agency does not intend to publish its findings, the Agency may receive requests to
release the information (e.g., congressional inquiry, Freedom of Information Act requests). The
Agency will disseminate the findings when appropriate, strictly following the Agency's
"Guidelines for Ensuring the Quality of Information Disseminated to the Public," and will include
specific discussion of the limitation of the qualitative results discussed above.

17. Approval to Omit OMB Expiration Date
The Commission is not seeking approval to omit the expiration date.

18. Exceptions to Certification
These activities comply with the requirements in 5 CFR 1320.9.

B. STATISTICAL METHODS
Data collection methods and procedures will vary; however, the primary purpose of these
collections will be for internal management purposes; there are no plans to publish or
otherwise release this information.

1. Universe and Respondent Selection
Qualitative surveys are tools used by program managers to change or improve programs,
products, or services. The accuracy, reliability, and applicability of the results of these surveys are
adequate for their purpose.

2. Procedures for Collecting Information
Data collection methods and procedures will vary and the specifics of these will be provided with
each collection request. The Agency expects to use a variety of methodologies for these
collections. For example, the Agency or its contractors may use commercial survey-specific
software to automate its collection and analysis of feedback. In addition to physical copies,
information collection instruments may be electronically disseminated. Telephone scripts,
personal interviews, and focus groups with professional guidance and moderation may also be
used.

3. Methods to Maximize Response
Information collected under this generic clearance will not yield generalizable quantitative
findings; it can provide useful customer input, but it does not yield data about customer opinions
that can be generalized.

4. Contacts for Statistical Aspects and Data Collection
Not applicable. Information collected under this generic clearance will not yield any statistical

aspects. It will only be utilized to improve specific customer service programs.