Public Participation

Centralized Regulatory Review

The  Information (Data) Quality Act

Insoluble Insolvency

The Indisputable Threat to Banks: Deficit Financing

There is room for discussion regarding the threat posed by AI, but presently the United States is continuing on the path of the last twenty-five years to treat continued deficit financing as an issue to be addressed by a surreptitious increase in the money supply. If in fact such an event materializes the threat posed by AI will, in our opinion, become a second level concern.

I served as the Assistant Director of OMB as part of a career working for five Presidential Administrations. Additional background on the aforementioned issue is available through the following links on the website of the Center for Regulatory Effectiveness (CRE).

Under conditions of “Insoluble Insolvency“, regulatory policy must operate within binding sovereign capacity constraints. Centralized regulatory review shall function not only as an efficiency gatekeeper but as a protector of long-term fiscal solvency and intergenerational equity. History

02/17/2026  ChatGPT

DID JIM TOZZI COIN THE TERM CENTRALIZED REGULATORY REVIEW?

Yes — James (Jim) Tozzi is widely credited with coining the term “centralized regulatory review.”

Tozzi, a longtime Office of Management and Budget (OMB) official and one of the architects of modern regulatory oversight, used the term in the 1970s to describe the process of reviewing agency regulations through a centralized body within the Executive Office of the President. He played a key role in developing what later became the Office of Information and Regulatory Affairs (OIRA).

The phrase “insoluble insolvency” is not a traditional legal or accounting term. It is a modern conceptual expression used primarily in U.S. fiscal policy discussions to describe a condition in which insolvency cannot be resolved through conventional remedies such as borrowing, restructuring, inflation, tax increases, or regulatory reform.

Based on available public discussions and policy commentary, the term is most closely associated with:

• Jim Tozzi

• The Center for Regulatory Effectiveness

1️⃣ Traditional Insolvency: The Baseline

Historically, insolvency has meant one of two things:

• Balance-sheet insolvency: liabilities exceed assets

Here’s a formal mapping of insoluble insolvency into a centralized regulatory review (CRR/OIRA-style) framework—treating it as a regime condition that changes what “good” regulatory review can accomplish, what metrics are valid, and what governance levers remain.

1) Formal definitions

Centralized Regulatory Review (CRR)

Let CRR be a governance function that reviews significant agency actions to improve coherence and net benefits.

• Inputs: proposed rule $r$, agency analysis $A(r)$, statutory constraints $S$, macro/fiscal context $M$

• Process: valuation, alternatives, interagency coordination, quality control (benefit-cost / risk / distribution)

• Output: decision $d\in \{\text{approve, return, revise, withdraw}\}$ plus required changes.

1. The United States government is going broke and it has passed the point of no return because of Insoluble Insolvency

Observers:  Musk  Grokipedia    

AI states: “Tozzi uses the phrase to describe a condition in which insolvency cannot be resolved through conventional financial, regulatory, or policy remedies — implying a structural or systemic condition that makes recovery effectively impossible under existing frameworks.”

Jim Tozzi

NB