A detailed intake process without a decision standard
The three federal banking agencies’ current regulatory review uses four Federal Register notices covering 12 categories, 90-day comment periods and four public outreach meetings. Yet GAO found the agencies lacked completed, documented procedures for deciding which rules are outdated, unnecessary or unduly burdensome and whether comments warrant action.
The contrast is the accountability finding: the process specifies how comments enter but not a common, reviewable test for how they produce a regulatory decision. Two agencies had draft procedures, but they had not been fully developed or demonstrated in practice.
| Element | Count/status |
|---|---|
| Federal Register notices | 4 |
| Regulatory categories | 12 |
| Current-cycle outreach meetings by April 2026 | 4 |
| Agencies with completed documented decision procedures | 0 of 3 |
| GAO recommendations | 6 open |
Six of eight outside organizations questioned results
Representatives from six of the eight organizations GAO interviewed said the reviews do not often produce changes to unnecessary rules—75% of that selected interview group. The group was not a statistical sample of all banks, consumers or commenters, so the percentage describes the audit interviews only.
GAO also found the 2017 report included actions initiated for other statutory reasons or before the review, making it difficult to determine what EGRPRA itself caused. A list of later changes is not automatically an outcome measure for the review.
The review occurs only once a decade
The agencies completed reviews in 2006 and 2017 and began the third cycle in 2024. Because the statutory cycle is at least every 10 years, missing procedures cannot be quickly tested and corrected through an annual rerun.
The agencies did demonstrate coordination: staff met regularly, divided comment summaries and worked toward consensus. GAO’s finding does not erase those practices; it says coordination did not supply rule-prioritization, cost-benefit or cumulative-burden frameworks.
Equal recommendations reflect a shared gap
GAO issued two recommendations to each agency—six total—covering documented decision procedures and a framework for prioritization, cost-benefit analysis and cumulative burden. The agencies neither agreed nor disagreed. This newsroom’s calculation of the 75% interview share and zero-of-three completed-procedure comparison adds a concise cross-agency view without claiming that any specific rule should be repealed.