Last week, a group of representatives from across a variety of industries met to discuss the formation of a Research Integrity Council (RIC), the purpose of which will be to make recommendations to improve the quality and veracity of the research being conducted by the CFPB to inform its rulemaking process. The CFPB has emphasized its goal of being a “data-driven” agency, but the effectiveness of any rules driven by the CFPB’s data could be at risk without a research process being conducted using scientifically sound, peer-reviewable, unbiased, open, and repeatable methods.
The RIC, a proposed voluntary coalition of industries subject to the CFPB’s jurisdiction, plans to seek out bipartisan experts with knowledge of effective research methodologies that have been adopted at other federal agencies. This panel of experts would review the research already released by the CFPB, in the form of reports and white papers, to identify any areas of improvement. The RIC will then develop a comprehensive research framework that could be adopted by the CFPB to produce the type of quality economic research that should be informing the CFPB regulatory process.
Despite the existence of an Academic Research Council, the RIC believes that more could be done to improve the process by which the CFPB conducts research, especially due to the lack of transparency into the activities of the Academic Research Council. Questions were posed as to why no meeting minutes for the Academic Research Council have been made available to the public since 2012, and why the minutes that have been posted on the CFPB website consist of only a single paragraph.
The RIC plans to advocate for the CFPB’s strict adherence to evidence-based regulations. Due to the potentially widespread impact of CFPB rules, the RIC will call on the CFPB to accept data from appropriate stakeholders during the research process as well as a strong review process for any research findings, both internally at the CFPB, but also through reviews by external experts. Regardless of CFPB adoption of the RIC’s recommendations, the RIC also plans to further the public discourse about the CFPB’s research by publishing reviews of future CFPB research.