Looking to hold itself accountable for the decisions that are made based on the research it conducts, the Consumer Financial Protection Bureau has announced it will have some of its research reviewed by the Bureau’s Academic Research Council, an external panel of researchers with experience in consumer finance. What is the first piece of research that is being subjected to this peer review process? A report on the results of a survey that the CFPB conducted testing different disclosure notices associated with collecting on time-barred debt. Interestingly enough, the ARC had a number of questions about the survey and its results.
Acknowledging the “highly technical” nature of some of its research that goes into the policymaking process, the CFPB said it is using the peer review process to provide “objective feedback” that will help ensure the underlying data that is being used to influence policy decisions is based on sound scientific and statistical principles.
The survey about time-barred debt disclosures likely influenced the details of the CFPB’s Supplemental Notice of Proposed Rulemaking related to time-barred debt disclosures; the CFPB referenced the report when it announced the proposed rule.
The CFPB released the results of its time-barred disclosure survey this February. The results of the survey indicated that “a validation notice without a time-barred debt disclosure can leave consumers with the misleading impression that debt collectors would be legally allowed to sue to collect the debt,” according to the CFPB.
Complimenting the CFPB on the design and implementation of the survey, as well as the care that the report’s authors took to make sure even a non-expert could understand the report, the ARC did note some possible limitations, most notably that the survey did not include what would qualify as a “successful” disclosure.
“Addressing questions such as these are clearly beyond the scientific goals of the report, but they may be relevant before applying the results to public policy,” the ARC wrote in its review. “Additional research may be necessary to address these and other issues relevant for particular public policy applications of the study.”