Improving U.S. Financial Regulation Through OIRA Review & Robust Regulatory Analysis

Author: 

Robert W. Greene

By eliminating the Office of Thrift Supervision and reclassifying the Office of the Comptroller of the Currency’s legal status, the Dodd-Frank Act left the United States financial regulatory system almost entirely in the hands of “independent regulatory agencies.” Unlike executive agencies – such as the Environmental Protection Agency (EPA), Department of Health and Human Services (HHS), or Department of Transportation (DOT) – “independent” agencies, and thus most federal financial regulators, are subject to neither Executive Orders 12,866 and 13,563 nor to Office of Management and Budget (OMB) Circular A-4, which together establish a number of regulatory best practices, including the review of proposed regulatory actions by the Office of Information and Regulatory Affairs (OIRA), housed within OMB. View More