Jan. 23, 2013 – NAFCU’s Carrie Hunt, referring to a Government Accountability Office report issued Tuesday, said stakeholders are less concerned about how regulators respond to comments received on rules than the methods they use to ensure the benefits of those rules outweigh the costs of implementation.
The GAO issued a report Tuesday that says the Office of Management and Budget should provide regulators guidance that encourages them to respond to comments on major final rules that are issued without a prior notice of proposed rulemaking. GAO made the recommendation following an analysis of a sampling of rulemakings that were issued without prior NPRMs and the reasons given for such action.
NAFCU has been urging NCUA, CFPB and other regulators on the importance of ensuring all the rules they issue fulfill a necessary objective. “We are less concerned with agencies responding to every single public comment on rules and more interested in the weight they give comments in general and the agencies’ ability to perform a valid cost-benefit analysis,” said Hunt, NAFCU’s general counsel and vice president of regulatory affairs.