Ms. Rebecca H.

Ewing
Acting Executive Secretary
United States Department of the Treasury
C/O The Office of Financial Education, and
Financial Literacy and Education Commission

September 19, 2010

Via E-mail: FLECstrategy@do.treas.gov

Comments of PaperChain and Free Community Paper Industry

on the Draft National Strategy for Financial Literacy

PaperChain1 on behalf of its Member Associations2 and the united Free Community Paper Industry, of-
fers the following Comments relating to the Draft National Strategy for Financial Literacy in response to
the Request for Comments issued by Department of the Treasury.3 As a core function of their collective
enterprise, our hometown publishers actively promote and engage the literacy needs of their diverse com-
munities across America. Literacy, itself, is the fundamental building block of Financial Literacy.4

1
PaperChain is a nonprofit association of sixteen (16) state, regional and national associations of free community paper pub-
lishers. We represent 2,673 hometown publications with a combined, audited circulation 65,187,292. http://paperchain.com/

2
The member associations of PaperChain are: Association of Free Community Papers (AFCP), Independent Free Papers
of America (IFPA), Community Papers of New England (CPNE), Mid-Atlantic Community Papers Association (MACPA),
Midwest Free Community Papers (MFCP), Pacific Northwest Association of Want Ad Newspapers (PNAWAN), Southeastern
Advertising Publishers’ Association (SAPA), Southwestern Association of Community Publications (SACP), Community Pa-
pers of Indiana and Illinois (CPI&I), Community Papers of Florida (CPF), Community Papers of Michigan (CPM), Wisconsin
Community Papers (WCP), Texas Community Newspaper Association (TCNA), Minnesota Free Paper Association (MFPA),
Community Papers of Ohio and West Virginia (CPOWV), Free Community Papers of New York (FCPNY).

3
Comment Request for the Financial Literacy and Education Commission on the Draft National Strategy, Entitled National
Strategy for Financial Literacy 2010, Federal Register, Vol. 75, No. 171, Friday, September 3, 2010, Notices.
 -2-

PaperChain applauds the tireless work of the Financial Literacy and Education Commission (FLEC),
and proudly endorses the overriding objectives it is tasked to accomplish. As the Commission notes, this
important work began years before our Nation’s most recent near economic collapse,5 dubbed by many
as “The Great Recession.” No shortage of scholars, economists and journalists have duly noted that sig-
nificant disparities in the financial literacy of our citizens were at least a mitigating factor leading to that
crisis, and we share the hope of many that the critical work ahead will help to prevent future economic
meltdowns.

PaperChain champions the Vision, Mission and Goals detailed in the working Draft of the National Strat-
egy for Financial Literacy. We take keen interest in the first explicit Goal, “Increase Awareness of and Ac-
cess to Financial Education,” as well as the multiple mentions of collaboration and partnerships from the
national down to the most local, community-based level. We are confident that our industry can deliver
critical and unique capabilities to specific objectives set forth in “Goal 1.” At the same time, PaperChain
also welcomes the opportunity to serve as a key partner across action areas, and as bridge-builder across
macro and micro geographic divides.

National Media Campaign

We unequivocally embrace the Draft Strategy’s Vision of “sustained financial well-being for all individu-
als and families in the U.S.” Our publishers operate on the front lines of the economy, providing the glue
that bonds neighbors and the merchants on Main Street. We share a singular perspective on the condition
of truly local commerce, and we can attest that our collective financial well-being is inextricably linked.
Families, and the dependent business community, have together taken a long, hard look at economic les-

4
Financial Literacy assumes, and is predicated on the core competencies of actual Literacy. A basic and enduring standard
for literacy in most societies is the ability to read a newspaper. The United Nations Educational, Scientific and Cultural Or-
ganization (UNESCO) defines literacy as the “ability to identify, understand, interpret, create, communicate, compute and
use printed and written materials associated with varying contexts. Literacy involves a continuum of learning in enabling
individuals to achieve their goals, to develop their knowledge and potential, and to participate fully in their community
and wider society.”

5
The Draft National Strategy that we now offer Comment on, is the product of a continuing series of painstaking activities
that date back to the establishment, by Act of Congress, of the Financial Literacy and Education Commission (FLEC) in
2003.
 -3-

sons learned from the current financial crisis. In order that lessons sink in, and also that collective amnesia
does not, the aim of seeking:

“to foster a culture in which households take periodic stock of their financial situations, individuals
seek information and ask questions before entering into financial transactions, and everyone has
the information and tools needed to help manage debt, save to meet their financial goals, and plan
for secure financial futures”6

is paramount to the long-term sustainability of our inter-dependent local and national economies. Com-
merce cannot thrive without able and informed consumers, and a prosperous Nation depends on that
dynamic harmony.

Cultivating a national habit of taking “periodic stock of their financial situations” will presumably require
an established baseline quantifying both basic knowledge and how it is practiced. From there, the next
critical steps of instilling both an awareness of resources, and the outcome-focused awareness of the need
to actually access these resources, become paramount. None of this can be achieved, however, without
extensive, repetitive and ultimately effective public outreach. The Commission has considered this funda-
mental component of execution, and seeks to: “Promote a national media campaign to raise awareness on
financial literacy, including the use of venues and technologies to reach people where they are.”7

PaperChain strongly agrees that a national media campaign will be vital to the National Strategy. A
multitude of options exist across traditional and emerging platforms, and we envision the Commission
thoughtfully adopting a strategic blend of so-called old and new media in its ultimate campaign. All of
the best efforts, from identifying at-risk groups to developing ideal curricula, simply cannot achieve full
potential if the intended audience is not reached. The Commission must carefully evaluate the possibili-
ties presented by “innovative technologies to reach people,”8 but also maintain constant focus on the most
basic need to “reach people where they are.” At the end of the day, people come home, and they can still be
found most reliably at their residence.

6
Draft National Strategy for Financial Literacy, September 3, 2010, at 6.

7
Draft Strategy at 7.

8
Why and How: Background Report - Developing the 2010 National Strategy, Financial Literacy and Education Commis-
sion, August 2010, at 5.
 -4-

Partnerships

PaperChain welcomes the opportunity to partner with the Commission and all stake-holders in the
execution of the National Strategy for Financial Literacy. The need for collaboration and partnerships is
expressed across the range of objectives relating to specific goals. Ultimately, such dynamic partnering
and close coordination will need to occur effectively from the national down to the most local, commu-
nity level. The very Mission of the National Strategy depends on successful teamwork between all stake-
holders. PaperChain, our member associations and our publishers bring a wealth of experience to the
table. PaperChain has proudly served as national partner to the March of Dimes Foundation, successfully
coordinating numerous campaigns over more than five years, working closely with our associations and
publishers.

Our sixteen member state, regional and national Associations each have vast and wide-ranging histories
of success serving as critical partners with non-profit and government entities from municipal to state,
up to the national level.9 At the same time, our strongest and most enduring bonds are truly grass-roots.
Our hometown publishers are based on Main Street, and bring generations of active community service
expertise and relationships. This is where the rubber meets the road, and together we can help to bring the
National Strategy from an idea formulated in Washington, D.C. to a reality in the communities that make
us America.

Implementation

The Commission asks for specific examples of how organizations would implement the National Strat-
egy.10 PaperChain, carefully coordinating with our sixteen member state, regional and national Associa-
tions, will guide a seamless, national media campaign through 2,673 hometown publications reaching

9
Most recently, MACPA partnered with the U.S. Census Bureau in efforts based in the Mid-Atlantic region, and each of
our member associations has their own laundry list to share. This sampling, from WCP, of their partnerships throughout
Wisconsin are reflective of our organizations: Rawhide Ranch for Boys, securing unwanted vehicles for over 35 years;
Badger Camp for mentally handicapped citizens; Camp Hope a respite for Cancer siblings; the Governor’s Blue Ribbon
Commission for Drug Prevention - a state-level partner of the National effort, Drug Free America, along with, locally, the
Wisconsin Alliance for Youth; Wisconsin Public Radio; Wisconsin Y2K Commission; Wisconsin Consumer Protection;
and Wisconsin DNR, among others.

10
Request for Comment at No. 6.
 -5-

65,187, 292 families “where they are.” That is to say, at their homes.11 Taking direction from the Com-
mission, and working closely with partner Agencies and stake-holders, we will ensure delivery and raise
measurable awareness of the campaign’s message. This will be achieved with equal precision on national
themes as well as any regionalized or hyper localized targeting that might involve distinct messaging, and
correspondingly, geographic or demographically-targeted delivery.

The Commission will be statistically assured that this aspect of execution of the National Strategy will
achieve 97.1% receivership and 76.9% readership in the vast and diverse tapestry of communities served
by our hometown publishers. We understand that future messaging for the anticipated national media
campaign has yet to be formulated, however we would like to offer a possible suggestion that might help
in quantifying a national baseline in levels of financial literacy, as well as the potential pre-awareness of
the need to access existing resources and those under formulation. Our idea is a “Financial Literacy Quiz”
campaign, based on a rotating set of basic but essential financial literacy concepts, and should include calls
to action and outreach contact information.

PaperChain would also help to orchestrate, in conjunction with our sixteen member free community
paper associations, collaboration between all partners and stake-holders, from the national down to the
community-based levels. At the most basic level, this would involve the dissemination of public service
announcements for publication in print and online. More can, and will need to be done, and our publish-
ers are perfectly positioned and experienced with multifaceted outreach in their respective communities.
We, as an industry, are open to all opportunities and suggestions, and offer our hometown facilities as sites
for disseminating collateral materials and other engagement, and volunteer for peer to peer and other
dynamic forms of outreach.

11
One statistic that merits the consideration of the Commission is the comparison of local readerships: Over two-thirds of
our readers do not subscribe to a daily newspaper.
 -6-

In conclusion, PaperChain, on behalf of the united free community paper industry, offers our full support
for the Vision, Mission and Goals of the Draft National Strategy for Financial Literacy. We back that sup-
port with the pledge to provide incomparable performance in the execution of the national media cam-
paign. Further, we welcome any and all opportunities to partner with the Commission and those organiza-
tions likewise engaged in the effective implementation of the National Strategy.

Respectfully Submitted,

Brian Gay
Chairman, PaperChain
Executive Director, Midwest Free Community Papers
briangay@mchsi.com
319-341-4352

On Behalf of the Member Associations of PaperChain:

Association of Free Community Papers

Mid-Atlantic Community Papers Association
Independent Free Papers of America
Community Papers of New England
Midwest Free Community Papers
Pacific Northwest Association of Want Ad Newspapers
Southeastern Advertising Publishers’ Association
Southwestern Association of Community Publications
Community Papers of Indiana and Illinois
Community Papers of Florida
Community Papers of Michigan
Wisconsin Community Papers
Texas Community Newspaper Association
Minnesota Free Paper Association
Community Papers of Ohio and West Virginia
Free Community Papers of New York