CRE Report Card
A series of federal "good government" laws have been enacted to constrain the actions and discretion of federal regulators. However, regulators often place minimal emphasis on complying with the requirements of these laws.
The CRE Report Card is a performance rating and accompanying analysis which documents, for a specific regulation, the extent of agency compliance with each of the good government laws. The laws against which CRE scores the regulation are:
- Data Quality Act
- Paperwork Reduction Act
- Regulatory Flexibility Act
- Unfunded Mandates Reform Act
- National Technology Transfer and Advancement Act
- Congressional Review Act
- Government Performance Results Act
- Administrative Procedure Act
- Executive Order 12866 -- Regulatory Review
- Executive Order 13132 -- Federalism
- Executive Order 12988 -- Civil Justice
- Executive Order 12606 -- Family Considerations
Recent examples of such Report Cards are the analysis CRE presented
to federal officials in connection with DOT's proposed rule on hours of
service for the motor carrier industry and SEC's proposed rule on auditor
independence. Click here to view.
CRE is ideally positioned to prepare an effective Report Card:
- CRE employees include a number of former OMB officials who were instrumental in creating many of the good government laws.
- The CRE website is increasingly used by:
- Agency officials
- Congressional staff
- The press
The CRE Report Card is an effective mechanism for companies seeking regulatory relief because demonstrating agency non-compliance with the good government authorities:
- Provides incentive for the regulatory agency to take the necessary corrective action.
- Provides the regulated entity with a substantive basis to negotiate with the regulatory agency.
- Provides CRE with a basis for:
- Discussing the substantive deficiencies in the rule with the regulatory agency,
- Highlighting agency non-compliance with the good government authorities, and
- Publicizing the inherent adverse regulatory precedent established by the rule.
- Provides the basis for Congressional oversight.
- Provides a basis for judicial review.
Fill out form below, CRE will then submit a proposal to you for preparing a Report Card on your regulation.