In “Think Tank Paper Faults Research Behind CFPB’s Vacated Medical Debt Rule,” Mike Gibb of AccountsRecovery.net reported on a white paper by Andrew Rodrigo Nigrinis, PhD, a Senior Fellow at the Southwest Public Policy Institute (SPPI), on the Consumer Financial Protection Bureau’s medical-debt reporting rule. The rule, which would have kept medical debt out of credit reports and lending decisions, was vacated in July 2025 before it took effect.
The story reported Nigrinis’s finding that the Bureau had no adequate empirical basis for concluding the rule would improve consumer welfare: its own research supported lower scoring weights and targeted measures, not a prohibition. It also reported that the paper set the Bureau’s estimate of about $900 million in reduced collections over ten years against the roughly $24 billion in first-year losses Nigrinis projected in a 2024 comment to the Bureau, and traced the gap to three modeling choices. The paper faulted the Bureau’s June 2024 Technical Appendix for looking at delinquency only among accounts that lenders had approved, and placed responsibility for the shortcomings with the Bureau’s leadership and research management, not its economists.
The full analysis is in White Paper No. 13, The Misuse of Government Research.