Magazine article The Small Business Advocate

Advocacy Releases Updated Legislative Priorities

Magazine article The Small Business Advocate

Advocacy Releases Updated Legislative Priorities

Article excerpt

This month, the Office of Advocacy released its statement of Legislative Priorities. These priorities are meant to highlight the important areas of the Regulatory Flexibility Act (RFA) that I, in consultation with Advocacy staff, believe could be strengthened. It has been slightly more than 35 years since the signing of the RFA and much in our regulatory system has changed. At the Office of Advocacy we continue to strive to be the most effective voice for small business. These additions and alterations to the RFA will, if enacted into law, give small businesses a stronger voice. The legislative priorities are briefly summarized below.

Indirect Effects

Under the RFA, agencies are only required to examine entities directly impacted by the rule. Advocacy believes that indirect effects should be part of the RFA analysis, but that the definition of indirect effects be specific and limited so the analytical requirements of the RFA remain reasonable

Scope of the RFA

In some cases, federal agencies use different rulemakings than the more familiar notice and comment. I believe that requiring RFA analysis on interim final rules, and expanding the analysis to include special conditions for the IRS would allow for greater small business consideration in federal rulemakings.

Quality of Analysis

Currently agencies are not required to estimate cost savings in their Final Regulatory Flexibility Analysis (FRFA). I believe that federal agencies should not only include these estimates but also clearly state the elements of the Initial Regulatory Flexibility Analysis and FRFA in the preamble to the proposed and final rule, respectively. …

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