Republican Senators from the Banking, Housing, and Urban Affairs committee sent a letter to federal regulators urging them to "employ fundamental principles of good regulation" in how they are implementing new rules mandated by the Dodd-Frank Act.

Noting that a recent review of Dodd-Frank rule making found that the public comment period on recent rules has been a little over 40 days, the letter reminds regulators that minimum comment period generally required is 60 days.  The Senators suggest that failure to provide sufficient time to evaluate new rules can potentially cause considerable harm to an already weak economy.


To encourage that sound regulatory principles are incorporated into the Dodd-Frank rulemaking activities, the Senators call on regulators to respond to five questions about how they are approaching these rules:

  1. Will your agency provide at least 60 days for public comment on all proposed rules and required studies?
  2. Explain the steps taken to ensure that rules adopted are the least burdensome way to achieve the statutory mandate.
  3. Explain how empirical data and economic analysis submitted by commenters is thoroughly considered.
  4. What steps are the agencies taking to ensure that interagency coordination is occurring as mandated by many of the Dodd-Frank requirements?
  5. What additional time allowance to consider cost-benefit and economic impact analysis, along with due consideration of public comments, would improve the rulemaking process?

Recognizing the "unprecedented scope and pace of agency rulemakings," the letter encourages regulators to "deliberative and rational" in the rule making process.  It serves as a warning of potential negative impact on long-term economic growth from such a pace of new rules.

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