Date: January 29, 2016
Issue: Fiduciary Duty
To: The Honorable Shaun Donovan, Director, Office of Management and Budget & the Honorable Howard Shelanski, Administrator, Office of Information and Regulatory Affairs, Office of Management and Budget
Filing Type: Regulatory
Description: The Chamber believes that it is incumbent on OMB to direct the DOL to republish a Supplemental IRFA, and in doing so, accept the SBA Office of Advocacy’s invitation to conduct a SBREFA panel review of the Proposed Rule. In the alternative, we request that OIRA conduct an independent economic impact analysis on the Proposed Rule’s impact on small businesses. The obvious deficiencies in the Department’s RIA and failure to consider the full extent of impacts on small business to avoid a legally deficient rule that could do more harm than good to retirement savers and the infrastructure on which they rely to build to ensure financial security.