Date: April 19, 2013
Issue: Regulatory Reform
To: Administrative Conference of the United States
Filing Type: Regulatory
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.