CFPB Outlines Commitment to Gold Standard Science in New Report

Richard J. Andreano, Jr. and John L. Culhane, Jr. of Ballard Spahr LLP report that the Consumer Financial Protection Bureau (CFPB) has issued a Report on Actions Taken to Implement Gold Standard Science (GSS), following the May 2025 Executive Order “Restoring Gold Standard Science.” The report outlines both current efforts and future plans to align CFPB research practices with GSS principles, emphasizing transparency, rigor, and accountability.

According to the authors, the CFPB has formed a cross-Bureau working group to develop formal policies and procedures for producing and using scientific information. While most CFPB research is descriptive or inferential, staff are expected to adapt GSS requirements to both approaches. 

The report addresses nine key tenets: reproducibility, transparency, communication of error and uncertainty, collaboration, skepticism of findings, falsifiability of hypotheses, unbiased peer review, acceptance of negative results, and avoidance of conflicts of interest.

The CFPB advises that it is building policies to support reproducible research through open data repositories, promoting transparent disclosure of methodologies, and formalizing processes to communicate uncertainty. It also prioritizes interdisciplinary collaboration and fosters skepticism by encouraging early feedback. Additionally, the CFPB is strengthening conflict-of-interest safeguards, requiring financial disclosures and ethics approvals for outside activities.

While comprehensive, the report does not directly address the consumer financial industry’s concern that cost/benefit analyses of regulations often underestimate compliance burdens. Nor does it detail the implications of GSS for fair lending analysis, particularly in light of the April 2025 executive order limiting disparate-impact liability.

The CFPB is committing to embed scientific rigor into its processes. The details will matter, but regulated entities should anticipate more structured, transparent research practices shaping future CFPB policy decisions.