Date: April 19, 2013

IssueRegulatory Reform

To: Administrative Conference of the United States

Filing TypeRegulatory

Description: The Administrative Conference of the United States (ACUS) is currently studying the role of cost-benefit analysis in regulations generally and its application to financial services regulation.  CCMC sent a letter to ACUS highlighting the Center’s recent study on the importance of cost-benefit analysis and particular aspects of the report that may be of interest to ACUS including the following:

  • Financial regulators have a statutory requirement to perform a cost-benefit analysis when writing regulations;
  • The Courts, Inspector General reports, and General Accounting Office reports have found that financial regulators are either ignoring these requirements or performing inadequate cost-benefit analysis;
  • And all financial regulators should use a broader, wider and more rigorous application of cost-benefit analysis to ground proposals in facts, ensure they achieve the desired benefits, and better understand the possible costs and consequences that may result from their actions.

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