It’s a Wrap: First 100 Days in Regulatory Changes
April 29, 2025
The Office of Management and Budget’s Office of Information and Regulatory Affairs (OIRA) issued initial implementation guidance on April 17 to bring historically independent agencies into compliance with President Donald Trump’s February Executive Order (EO) “Ensuring Accountability for All Agencies.”
OIRA notes that it is likely to issue additional guidance as more clarification is needed. The initial guidance clarifies that these independent agencies’ regulatory actions are subject to OIRA’s review:
- The guidance explains that independent regulatory agencies must involve OIRA at all stages of rulemaking (e.g., advanced notices of proposed rulemaking, notices of proposed rulemaking, and final rules) and are subject to this centralized review.
- It applies to at least 20 boards, commissions and other agencies, including the Federal Reserve, the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the Securities and Exchange Commission (SEC).
- However, it does clarify that the February EO shall apply to the Board of Governors of the Federal Reserve System “only in connection with its conduct and authorities directly related to its supervision and regulation of financial institutions”; i.e., shall not apply to its monetary policy activities.
To comply with the February EO, each agency is directed to designate employees to fulfill two positions:
- Regulatory Policy Officer (RPO): As a direct report to the agency head, the RPO will be a political appointee with the authority to approve (or obtain the approval of) policy positions on behalf of the agency; and
- Regulatory Second is a less formal but crucial role played by a senior agency official (traditionally a career employee) who coordinates or leads an office in coordinating agency work on all regulatory actions reviewed under the EO.
Although the appointments of the above positions were to have taken place by April 21, information has not yet been made public.
As reported in previous CREFC
Policy and Capital Markets Briefings, market watchers have speculated that the Trump administration might be considering consolidating the banking agencies.
- According to the American Banker, however, Treasury Secretary Scott Bessent, who has said that the banking agencies should be “singing in unison from the same song sheet,” might be looking to this detailed guidance as a substitute for agency consolidation.
New Regulatory Leadership Developments: On April 21, Paul Atkins was sworn in as the new SEC Chair. Other leadership confirmations remain outstanding. Please see here for CREFC’s Regulatory Tracker.
Contact Sairah Burki (sburki@crefc.org) with any questions.