79–006 

115TH CONGRESS REPORT " ! HOUSE OF REPRESENTATIVES 2d Session 115–573 

COMPREHENSIVE REGULATORY REVIEW ACT 

FEBRUARY 23, 2018.—Committed to the Committee of the Whole House on the State 

of the Union and ordered to be printed 

Mr. HENSARLING, from the Committee on Financial Services, 

submitted the following 

R E P O R T 

together with 

MINORITY VIEWS 

[To accompany H.R. 4607] 

[Including cost estimate of the Congressional Budget Office] 

The Committee on Financial Services, to whom was referred the 

bill (H.R. 4607) to amend the Economic Growth and Regulatory Paperwork Reduction Act of 1996 to ensure that Federal financial regulators perform a comprehensive review of regulations to identify 

outdated or otherwise unnecessary regulatory requirements imposed on covered persons, and for other purposes, having considered the same, report favorably thereon without amendment and 

recommend that the bill do pass. 

PURPOSE AND SUMMARY

Introduced by Representative Barry Loudermilk on December 11, 

2017, H.R. 4607, the ‘‘Comprehensive Regulatory Review Act’’ 

amends the Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA) to require the Federal Financial Institutions Examination Council (FFIEC) and each of the federal financial regulators—including the Consumer Financial Protection Bureau (CFPB) and National Credit Union Administration (NCUA)— 

to conduct, at least once every seven years, a comprehensive review 

of all regulations prescribed by the council or the regulator. The review shall include all regulations issued after December 31, 2006, 

in order to identify outdated or otherwise unnecessary regulations 

and tailor other regulations related to insured depository instituVerDate Sep 11 2014 02:32 Feb 24, 2018 Jkt 079006 PO 00000 Frm 00001 Fmt 6659 Sfmt 6602 E:\HR\OC\HR573.XXX HR573
2 

1 Appropriate Federal banking agencies as codified to 12 U.S.C. 1813(q), include the Board of 

Governors of the Federal Reserve System (Federal Reserve), the Office of the Comptroller of the 

Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC). 2https://www.ffiec.gov/pdf/2017_FFIEC_EGRPRA_Joint-Report_to_Congress.pdf 3 Id. 

tions or entities that engage in offering or providing a consumer financial product or service and affiliates who provide services to 

them. 

BACKGROUND AND NEED FOR LEGISLATION

The Economic Growth and Regulatory Paperwork Reduction Act 

of 1996 (EGRPRA) requires the Federal Financial Institutions Examination Council (FFIEC), together with each appropriate Federal 

banking agency 1, to conduct a joint review of existing regulations 

every 10 years to determine whether any rules are outdated, unnecessary, or unduly burdensome, and consider how to reduce regulatory burden while, at the same time, ensuring the safety and 

soundness and the safety and soundness of the financial system. As 

part of the review, EGRPRA requires these agencies to, at regular 

intervals, provide notice and solicit public comment on a particular 

category or categories of regulations. 

The EGRPRA also requires the publication of a report that summarizes any significant issues raised by public comments received 

and the relative merits of such issues, as well as an analysis of 

whether the appropriate Federal banking agency is able to address 

the regulatory burdens associated with issues by regulation, or 

whether such burdens must be addressed by legislative action. 

The first EGRPRA review began in 2003, and its findings were 

subsequently published in a July 31, 2007 report to Congress. The 

most recent EGRPRA review, which began in 2014, included six 

Federal Register notices seeking public comment. In March 2017, 

the agencies published their final report detailing the conclusions 

of their review.2 The report noted that the regulators received over 

230 written comments and 120 oral comments and the ‘‘report sets 

forth the initiatives the agencies have or will be undertaking to reduce regulatory burden while still promoting the safety and soundness of insured of insured depository institutions and promoting 

consumer protection.’’ 3 The March 2017 report articulated that topics that received the most comments relates to (1) capital, (2) Call 

Reports, (3) appraisals, (4) frequency of safety-and-soundness bank 

examinations, (5) the Community Reinvestment Act, and (6) Bank 

Secrecy Act/Anti-Money Laundering. 

Under current law, the EGRPRA does not require either the Consumer Financial Protection Bureau (CFPB) or the National Credit 

Union Administration (NCUA) to participate in the review process, 

because the statute does not included them in the definition of an 

‘‘appropriate Federal banking agency.’’ In testimony before the Subcommittee on Financial Institutions and Consumer Credit on December 7, 2017, Mr. Brian Ducharme, President and CEO of MIT 

Federal Credit Union, headquartered in Cambridge, Massachusetts, testifying on behalf of the National Association of Federally 

Insured Credit Unions (NAFCU) stated, ‘‘NAFCU appreciates that 

NCUA has been voluntarily participating in the EGRPRA review 

process and we are pleased to see the legislation extending it to the 

CFPB.’’ 

3 

Title X of the Dodd-Frank Wall Street Reform and Consumer 

Protection Act (P.L. 111–203) requires the CFPB to review its significant regulations and report on them five years after they become final. Testifying at the same December 7, 2017 hearing, 

Christopher George, President and Chief Executive Officer, CMG 

Financial, on behalf of the Mortgage Bankers Association (MBA) 

noted that adding the CFPB and the NCUA to EGRPRA review, 

‘‘improves upon this structure by requiring an ongoing review during five-year cycles rather than a one-time review.’’ Even though 

the NCUA has concurrently and voluntarily conducted its own review in a manner consistent with EGRPRA, H.R. 4607 ensures that 

all financial regulators are statutorily required to review—in concert—their regulations on a regular basis. As the MBA testified 

about H.R. 4607’s effects to extend EGRPRA to the CFPB and the 

NCUA ‘‘will eliminate ambiguity and ensure that they undertake 

reviews of their regulations consistently in the future. This is particularly important for the CFPB given its expansive regulatory jurisdiction and the frequently high costs incurred by regulated entities to comply with some of its regulations.’’ 

HEARINGS

The Committee on Financial Services’ Subcommittee on Financial Institutions and Consumer Credit held a hearing examining 

matters relating to H.R. 4607 on December 7, 2017. 

COMMITTEE CONSIDERATION

The Committee on Financial Services met in open session on 

January 17 and 18, 2018, and ordered H.R. 4607 to be reported favorably by a recorded vote of 38 yeas to 17 nays (Record vote no. 

FC–142), a quorum being present. 

COMMITTEE VOTES

Clause 3(b) of rule XIII of the Rules of the House of Representatives requires the Committee to list the record votes on the motion 

to report legislation and amendments thereto. The sole recorded 

vote was on a motion by Chairman Hensarling to report the bill favorably to the House without amendment. The motion was agreed 

to by a recorded vote of 38 yeas to 17 nays (Record vote no. FC– 

142), a quorum being present. 

4 


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5 

COMMITTEE OVERSIGHT FINDINGS

Pursuant to clause 3(c)(1) of rule XIII of the Rules of the House 

of Representatives, the findings and recommendations of the Committee based on oversight activities under clause 2(b)(1) of rule X 

of the Rules of the House of Representatives, are incorporated in 

the descriptive portions of this report. 

PERFORMANCE GOALS AND OBJECTIVES

Pursuant to clause 3(c)(4) of rule XIII of the Rules of the House 

of Representatives, the Committee states that H.R. 4607 will ensure that Federal financial regulators regularly perform a comprehensive review of regulations to identify outdated or otherwise 

unnecessary regulatory requirements. 

NEW BUDGET AUTHORITY, ENTITLEMENT AUTHORITY, AND TAX

EXPENDITURES

In compliance with clause 3(c)(2) of rule XIII of the Rules of the 

House of Representatives, the Committee adopts as its own the estimate of new budget authority, entitlement authority, or tax expenditures or revenues contained in the cost estimate prepared by 

the Director of the Congressional Budget Office pursuant to section 

402 of the Congressional Budget Act of 1974. 

CONGRESSIONAL BUDGET OFFICE ESTIMATES

Pursuant to clause 3(c)(3) of rule XIII of the Rules of the House 

of Representatives, the following is the cost estimate provided by 

the Congressional Budget Office pursuant to section 402 of the 

Congressional Budget Act of 1974: 

U.S. CONGRESS, 

CONGRESSIONAL BUDGET OFFICE, 

Washington, DC, February 22, 2018. 

Hon. JEB HENSARLING, 

Chairman, Committee on Financial Services, 

House of Representatives, Washington, DC. 

DEAR MR. CHAIRMAN: The Congressional Budget Office has prepared the enclosed cost estimate for H.R. 4607, the Comprehensive 

Regulatory Review Act. 

If you wish further details on this estimate, we will be pleased 

to provide them. The CBO staff contact is Stephen Rabent. 

Sincerely, 

KEITH HALL, Director. 

Enclosure. 

H.R. 4607—Comprehensive Regulatory Review Act 

Once every 10 years, four federal banking agencies review all the 

regulations that they have issued and identify outdated or unnecessary regulatory requirements on banks and credit unions. H.R. 

4607 would require those agencies and the Consumer Financial 

Protection Bureau (CFPB) to complete that review more frequently—once every 7 years. The bill also would increase the scope 

of the required regulatory review to include requirements imposed 

6 

on individual people or on companies that offer consumer financial 

products or services. The agencies would be required to tailor regulations to reduce the burden on such entities. 

Using information from the affected agencies, CBO estimates 

that enacting H.R. 4607 would increase direct spending by $3 million over the 2018–2027 period for the CFPB to hire three additional employees to conduct the required reviews and analyses. The 

CFPB is permanently authorized to spend amounts transferred 

from the Federal Reserve. 

In addition, CBO estimates that enacting those provisions would 

increase costs for the Federal Deposit Insurance Corporation, the 

Office of the Comptroller of the Currency, and the National Credit 

Union Administration to complete additional analyses and to do so 

more frequently. Costs incurred by those agencies are recorded in 

the budget as increases in direct spending, but they are authorized 

to collect premiums and fees from the financial institutions they 

regulate to cover such administrative expenses. Thus, CBO estimates that enacting H.R. 4607 would have no significant net effect 

on direct spending over the 2018–2027 period. 

Costs incurred by the Federal Reserve System for the same purposes would reduce remittances to the Treasury, which are recorded in the budget as revenues. CBO estimates that enacting 

H.R. 4607 would decrease revenues by less than $500,000 over the 

2018–2027 period. 

Because H.R. 4607 would affect direct spending and revenues, 

pay-as-you-go procedures apply. 

CBO estimates that enacting H.R. 4607 would not increase net 

direct spending or on-budget deficits by more than $2.5 billion in 

any of the four consecutive 10-year periods beginning in 2028. 

The bill contains no intergovernmental mandates as defined in 

the Unfunded Mandates Reform Act (UMRA). 

If federal financial regulators increase fees to offset the costs associated with implementing the bill, H.R. 4607 would increase the 

cost of an existing mandate on private entities required to pay 

those fees. Based on information from the affected agencies, CBO 

estimates that the incremental cost of the mandate would fall well 

below the annual threshold for private-sector mandates established 

in UMRA ($156 million in 2017, adjusted annually for inflation). 

The CBO staff contacts for this estimate are Stephen Rabent (for 

the CFPB), Nathaniel Frentz (for the Federal Reserve), Sarah Puro 

(for the other banking regulators), and Rachel Austin (for mandates). The estimate was approved by H. Samuel Papenfuss, Deputy Assistant Director for Budget Analysis. 

FEDERAL MANDATES STATEMENT

This information is provided in accordance with section 423 of 

the Unfunded Mandates Reform Act of 1995. 

The Committee has determined that the bill does not contain 

Federal mandates on the private sector. The Committee has determined that the bill does not impose a Federal intergovernmental 

mandate on State, local, or tribal governments. 

7 

ADVISORY COMMITTEE STATEMENT

No advisory committees within the meaning of section 5(b) of the 

Federal Advisory Committee Act were created by this legislation. 

APPLICABILITY TO LEGISLATIVE BRANCH

The Committee finds that the legislation does not relate to the 

terms and conditions of employment or access to public services or 

accommodations within the meaning of the section 102(b)(3) of the 

Congressional Accountability Act. 

EARMARK IDENTIFICATION

With respect to clause 9 of rule XXI of the Rules of the House 

of Representatives, the Committee has carefully reviewed the provisions of the bill and states that the provisions of the bill do not 

contain any congressional earmarks, limited tax benefits, or limited 

tariff benefits within the meaning of the rule. 

DUPLICATION OF FEDERAL PROGRAMS

In compliance with clause 3(c)(5) of rule XIII of the Rules of the 

House of Representatives, the Committee states that no provision 

of the bill establishes or reauthorizes: (1) a program of the Federal 

Government known to be duplicative of another Federal program; 

(2) a program included in any report from the Government Accountability Office to Congress pursuant to section 21 of Public 

Law 111–139; or (3) a program related to a program identified in 

the most recent Catalog of Federal Domestic Assistance, published 

pursuant to the Federal Program Information Act (Pub. L. No. 95– 

220, as amended by Pub. L. No. 98–169). 

DISCLOSURE OF DIRECTED RULEMAKING

Pursuant to section 3(i) of H. Res. 5, (115th Congress), the following statement is made concerning directed rulemakings: The 

Committee estimates that the bill requires no directed rulemakings 

within the meaning of such section. 

SECTION-BY-SECTION ANALYSIS OF THE LEGISLATION

Section 1. Short title 

This section cites H.R. 4607 as the ‘‘Comprehensive Regulatory 

Review Act.’’ 

Section 2. Definitions and Amendments to the Economic Growth 

and Regulatory Paperwork Reduction Act of 1996 

This section amends Section 2001(c) of the Economic Growth and 

Regulatory Paperwork Reduction Act of 1996 to clarify the definition of ‘‘covered person’’ has the same meaning given in section 

1002 of the Consumer Financial Protection Act of 2010. This section also clarifies the term ‘‘federal financial regulator’’ includes the 

Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, the Bureau of Consumer Financial Protection, and 

the National Credit Union Administration Board. 

8 

Section 3. Ensuring a comprehensive regulatory review 

This section amends Section 2222 of the Economic Growth and 

Regulatory Paperwork Reduction Act of 1996 to require, not less 

frequently than once every 7 years, the ‘‘federal financial regulators’’ to conduct a review of all regulations prescribed such appropriate Federal banking agency, respectively, in order to identify 

outdated or otherwise unnecessary regulatory requirements imposed on insured depository institutions. 

Section 4. Considerations for comprehensive regulatory review 

This section amends Section 2222 of the Economic Growth and 

Regulatory Paperwork Reduction Act of 1996 to require the ‘‘federal 

financial regulators’’ to tailor other regulations related to ‘‘covered 

persons’’ in a manner that limits the regulatory compliance impact, 

cost, liability risk, and other burdens, unless otherwise determined 

by the regulators. 

Section 5. Reviews conducted by the Bureau 

This section amends Section 2222 of the Economic Growth and 

Regulatory Paperwork Reduction Act of 1996 to make certain technical and conforming changes related to assessment conducted by 

the Bureau of Consumer Financial Protection under section 1022(d) 

of the Consumer Financial Protection Act of 2010. 

CHANGES IN EXISTING LAW MADE BY THE BILL, AS REPORTED

In compliance with clause 3(e) of rule XIII of the Rules of the 

House of Representatives, changes in existing law made by the bill, 

as reported, are shown as follows (existing law proposed to be omitted is enclosed in black brackets, new matter is printed in italics, 

and existing law in which no change is proposed is shown in 

roman): 

CHANGES IN EXISTING LAW MADE BY THE BILL, AS REPORTED

In compliance with clause 3(e) of rule XIII of the Rules of the 

House of Representatives, changes in existing law made by the bill, 

as reported, are shown as follows (existing law proposed to be omitted is enclosed in black brackets, new matter is printed in italic, 

and existing law in which no change is proposed is shown in 

roman): 

ECONOMIC GROWTH AND REGULATORY PAPERWORK 

REDUCTION ACT OF 1996 

DIVISION A 

* * * * * * * 

TITLE II—ECONOMIC GROWTH AND 

REGULATORY PAPERWORK REDUCTION 

SEC. 2001. SHORT TITLE; TABLE OF CONTENTS; DEFINITIONS. 

(a) SHORT TITLE.—This title may be cited as the ‘‘Economic 

Growth and Regulatory Paperwork Reduction Act of 1996’’. 

9 

(b) TABLE OF CONTENTS.—[Table omitted.] 

(c) DEFINITIONS.—Except as otherwise specified in this title, the 

following definitions shall apply for purposes of this title: 

(1) APPRAISAL SUBCOMMITTEE.—The term ‘‘Appraisal Subcommittee’’ means the Appraisal Subcommittee established 

under section 1011 of the Federal Financial Institutions Examination Council Act of 1978 (as in existence on the day before 

the date of enactment of this Act). 

(2) APPROPRIATE FEDERAL BANKING AGENCY.—The term ‘‘appropriate Federal banking agency’’ has the same meaning as in 

section 3 of the Federal Deposit Insurance Act. 

(3) BOARD.—The term ‘‘Board’’ means the Board of Governors 

of the Federal Reserve System. 

(4) CORPORATION.—The term ‘‘Corporation’’ means the Federal Deposit Insurance Corporation. 

(5) COUNCIL.—The term ‘‘Council’’ means the Financial Institutions Examination Council established under section 1004 of 

the Federal Financial Institutions Examination Council Act of 

1978. 

(6) INSURED CREDIT UNION.—The term ‘‘insured credit union’’ 

has the same meaning as in section 101 of the Federal Credit 

Union Act. 

(7) INSURED DEPOSITORY INSTITUTION.—The term ‘‘insured 

depository institution’’ has the same meaning as in section 3 

of the Federal Deposit Insurance Act. 

(8) COVERED PERSON.—The term ‘‘covered person’’ has the 

meaning given such term in section 1002 of the Consumer Financial Protection Act of 2010 (12 U.S.C. 5481). 

(9) FEDERAL FINANCIAL REGULATOR.—The term ‘‘Federal financial regulator’’ means the Office of the Comptroller of the 

Currency, the Federal Deposit Insurance Corporation, the 

Board of Governors of the Federal Reserve System, the Bureau 

of Consumer Financial Protection, and the National Credit 

Union Administration Board. 

* * * * * * * 

Subtitle B—Streamlining Government 

Regulation 

* * * * * * * 

CHAPTER 2—ELIMINATING UNNECESSARY 

REGULATORY BURDENS 

* * * * * * * 

SEC. 2222. REQUIRED REVIEW OF REGULATIONS. 

(a) IN GENERAL.—Not less frequently than once every ø10 years¿ 

7 years, the Council and øeach appropriate Federal banking agency 

represented on the Council shall conduct a review¿ the Federal financial regulators shall each conduct a comprehensive review of all 

regulations prescribed by the Council or by any øsuch appropriate 

Federal banking agency¿ such Federal financial regulator, jointly 

or otherwise,, respectively, in order to identify outdated or otherVerDate Sep 11 2014 02:32 Feb 24, 2018 Jkt 079006 PO 00000 Frm 00009 Fmt 6659 Sfmt 6601 E:\HR\OC\HR573.XXX HR573
10 

wise unnecessary regulatory requirements imposed on insured depository institutions or covered persons. 

(b) PROCESS.—In conducting the review under subsection (a), the 

Council or øthe appropriate Federal banking agency¿ the appropriate Federal financial regulator shall— 

(1) categorize the regulations described in subsection (a) by 

type (such as consumer regulations, safety and soundness regulations, or such other designations as determined by the 

Council, or øthe appropriate Federal banking agency¿ the appropriate Federal financial regulator); and 

(2) at regular intervals, provide notice and solicit public comment on a particular category or categories of regulations, requesting commentators to identify areas of the regulations that 

are outdated, unnecessary, or unduly burdensome. 

(c) COMPLETE REVIEW.—The Council or øthe appropriate Federal 

banking agency¿ the appropriate Federal financial regulator shall 

ensure that the notice and comment period described in subsection 

(b)(2) is conducted with respect to all regulations described in subsection (a) not less frequently than once every ø10 years¿ 7 years. 

(d) REGULATORY RESPONSE.—The Council or øthe appropriate 

Federal banking agency¿ the appropriate Federal financial regulator shall— 

(1) publish in the Federal Register a summary of the comments received under this section, identifying significant issues 

raised and providing comment on such issues; øand¿ 

(2) eliminate unnecessary regulations to the extent that such 

action is appropriateø.¿; and 

(3) tailor other regulations related to covered persons in a 

manner that limits the regulatory compliance impact, cost, liability risk, and other burdens, unless otherwise determined by 

the Council or the appropriate Federal financial regulator. 

(e) REPORT TO CONGRESS.—Not later than 30 days after carrying 

out subsection (d)(1), the Council shall submit to the Congress a report, which shall include— 

(1) a summary of any significant issues raised by public comments received by the Council and øthe appropriate Federal 

banking agencies¿ the appropriate Federal financial regulator 

under this section and the relative merits of such issues; and 

(2) an analysis of whether øthe appropriate Federal banking 

agency¿ the appropriate Federal financial regulator involved is 

able to address the regulatory burdens associated with such 

issues by regulation, or whether such burdens must be addressed by legislative action. 

(f) REVIEWS CONDUCTED BY THE BUREAU.—The Bureau of Consumer Financial Protection shall— 

(1) use any relevant information from an assessment conducted under section 1022(d) of the Consumer Financial Protection Act of 2010 (12 U.S.C. 5512(d)) in conducting the review 

required under subsection (a); and 

(2) conduct such review in accordance with the purposes and 

objectives described in subsections (a) and (b) of section 1021 of 

such Act (12 U.S.C. 5511). 

* * * * * * * 

(11) 

1https://egrpra.ffiec.gov/about/the-law.html 

2 Available at: https://www.ffiec.gov/pdf/2017_FFIEC_EGRPRA_Joint-Report_to_Congress.pdf 3 Available at: https://www.ffiec.gov/pdf/2007_FFIEC_EGRPRA_Joint-Report_to_Congress.pdf 

MINORITY VIEWS 

The Economic Growth and Regulatory Paperwork Reduction Act 

of 1996 (EGRPRA) requires the federal banking regulators (Federal 

Reserve Board, FDIC and OCC) that serve on the Federal Financial Institutions Examination Council (‘‘FFIEC’’ or ‘‘Council’’) to 

conduct a review not less frequently than every ten years, ‘‘of all 

regulations prescribed by the Council or by any such appropriate 

Federal banking agency, respectively, in order to identify outdated 

or otherwise unnecessary regulatory requirements imposed on insured depository institutions.’’ 1 To date, there have been two 

EGRPRA reviews and reports, the most recent of which was completed in March 2017.2 The first report was issued in July 2007.3

While the National Credit Union Administration (NCUA) is not 

covered as one of the appropriate federal banking agencies and, 

therefore, not subject to EGRPRA, the NCUA did participate in the 

EGRPRA process in the March 2017 report. The regulators also 

publish in the Federal Register a summary of the comments that 

they have received identifying the significant issues raised by 

stakeholders along with the agencies’ comments on these issues. 

H.R. 4607 would amend EGRPRA to shorten the time period that 

federal regulators would have to conduct a comprehensive review 

of its regulations from ten to seven years and expand the obligation 

to participate in this review from just the Federal Reserve, OCC 

and FDIC to the NCUA and the Consumer Financial Protection 

Bureau (Consumer Bureau). In addition, H.R. 4607 would expand 

the EGRPRA analysis to address the impact on a ‘‘covered person,’’ 

as this term is defined under section 1002 of the Dodd-Frank Wall 

Street Reform and Consumer Protection Act (Dodd-Frank Act). A 

‘‘covered person’’ includes a wide range of financial companies, including payday lenders and debt collectors, not just depository institutions like community banks that are currently the focus of 

EGRPRA reviews. The bill would go beyond the current EGRPRA 

review criteria of identifying ‘‘outdated, unnecessary, or unduly 

burdensome regulations’’ to also require regulators to ‘‘tailor other 

regulations related to covered persons in a manner that limits the 

regulatory compliance impact, cost, liability risk, and other burdens, unless otherwise determined by the Council or the appropriate Federal financial regulator.’’ 

This would mean that regulators would have to determine the 

impact of previously issued rules on the financial industry, a lopsided standard that could lead to rolling back any and all rules 

that may be considered burdensome but may also benefit consumers, shareholders, and the economy to be included in an 

EGRPRA review. For example, while Wall Street may complain 

12 

4For example, see https://www.yalelawjournal.org/article/cost-benefit-analysis-of-financial-regulation. 

about compliance costs associated with stress testing and resolution planning for the nation’s largest banks, these rules provide 

enormous benefits to promoting financial stability that better protects our economy. Furthermore, experts have noted the industry 

often uses cost-benefit analyses to challenge and block various 

rulemakings in court,4 so further requirements that emphasize the 

cost to industry from various rules will make it harder for regulators to put meaningful safeguards in place to better protect consumers. 

Under section 1022(d) of the Dodd-Frank Act, the Consumer Bureau already has to review its significant rules five years after they 

take effect and is subject to numerous restrictions on its rulemaking authority, such as the ability for the Financial Stability 

Oversight Council to repeal its final rules under certain circumstances and the additional consideration of the impact of any 

proposals on small businesses. Given that the Consumer Bureau is 

already subject to multiple and unprecedented checks on the use of 

its rulemaking power, which the other federal banking regulators 

do not have to comply with, we believe it is wholly inappropriate 

to require the Consumer Bureau to also participate in the EGRPRA 

process. Moreover, H.R. 4607 is inconsistent with the statutory 

mission of the Consumer Bureau. The Bureau was established to 

protect consumers from financial predation. However, the review 

required under H.R. 4607 would force the Consumer Bureau to 

evaluate the costs and liability risks of its rules on the regulated 

industry without also instructing it to consider the potential benefits to the public or ways to improve the effectiveness of the overall 

regulatory framework. 

In addition, we note that in the most recent EGRPRA process, 

the participating federal agencies took several years to conduct the 

extensive review that went into the most recent report. For example, the federal banking agencies initially sought public comment 

to identify outdated, unnecessary, or unduly burdensome regulations imposed on insured depository institutions in June 2014, and 

announced in November 2014 that they were conducting a round 

of outreach meetings to consider stakeholder input into the review. 

The most recent EGRPRA report was sent to Congress and published in March 2017, nearly three years after the review was initiated. Increasing the frequency of this extensive regulatory review, 

as H.R. 4607 does, would redirect federal agency resources away 

from supervisory and other responsibilities that are important. 

We are also concerned that the bill would revise the EGRPRA 

process to go beyond identifying ‘‘outdated, unnecessary, or unduly 

burdensome regulations’’ to also require the agencies to limit the 

‘‘impact, cost, liability risk, and other burdens’’ related to regulated 

entities without considering the benefits from these rules. According to testimony on H.R. 4607 from Dr. Marcus Stanley, Policy Director with Americans for Financial Reform, ‘‘The language inserted into EGRPRA by the Act would significantly slant regulatory consideration away from a true comparison of the costs and 

benefits of regulation and toward an attempt to minimize costs for 

13 

5 Available at: https://financialservices.house.gov/uploadedfiles/hhrg-115-ba15-wstate-mstanley20171207.pdf 

regulated entities, without considering benefits to the public. . . . 

The Comprehensive Regulatory Review Act is unnecessary and 

harmful.’’ 5

Any comprehensive regulatory review should not be one-sided 

and focused on deregulating the industry, but rather seek a holistic 

approach to improve the overall regulatory framework to ensure it 

is truly working in the public’s interest. This means ensuring the 

review criteria is balanced, and the process encourages regulators 

to strengthen protections for consumer, investors and taxpayers, 

not simply weaken regulations for megabanks and other large financial businesses. Unfortunately, H.R. 4607 does not provide such 

a balanced regulatory review approach. 

For these reasons, we oppose H.R. 4607. 

MAXINE WATERS. 

NYDIA M. VELA ́ ZQUEZ. 

CAROLYN B. MALONEY. 

MICHAEL E. CAPUANO. 

Æ