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®: CRE Regulatory Action of the Week

OMB Issues Memorandum on Cumulative Effects of Regulations
A March 20, 2012 "MEMORANDUM FOR THE HEADS OF EXECUTIVE DEPARTMENTS AND AGENCIES," from Cass R. Sunstein, Administrator. Office of Information and Regulatory Affairs, states that

    "Consistent with Executive Order 13563, and to the extent permitted by law, agencies should take active steps to take account of the cumulative effects of new and existing rules and to identify opportunities to harmonize and streamline multiple rules. The goals of this effort should be to simplify requirements on the public and private sectors; to ensure against unjustified, redundant, or excessive requirements; and ultimately to increase the net benefits of regulations."
This OMB Memorandum specifies steps which agencies should "carefully consider…where appropriate and feasible, and to the extent permitted by law." These steps are
  • Early consultation with, advance notice to, and close engagement with affected stakeholders to discuss potential interactions between rulemakings under consideration and existing regulations as well as other anticipated regulatory requirements;

  • Early engagement with state, tribal, and local regulatory agencies to identify opportunities for harmonizing regulatory requirements, reducing administrative costs, avoiding unnecessary or inconsistent requirements, and otherwise improving regulatory outcomes;

  • Use of Requests for Information and Advance Notices of Proposed Rulemaking to obtain public input on potentially overlapping rulemakings and on rulemakings that may have significant cumulative effects;

  • Specific consideration of the cumulative effects of regulations on small businesses and start-ups;

  • Identification of opportunities to increase the net benefits of regulations and to reduce administrative and other costs, while meeting policy goals and legal requirements;

  • Careful consideration, in the analysis of costs and benefits, of the relationship between new regulations and regulations that are already in effect;

  • Identification of opportunities to integrate and simplify the requirements of new and existing rules, so as to eliminate inconsistency and redundancy;

  • Coordination of timing, content, and requirements of multiple rulemakings that are contemplated for a particular industry or sector, so as to increase net benefits; and

  • Consideration of the interactive and cumulative effects of multiple regulations.
  • Click here to read Cumulative Effects Memorandum