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Greetings,

Congress plans to be in session for just one more week between now and Election Day. Yet, in that short time, Wall Street interests hope to mount a stealth attack on the Dodd-Frank Act and the cause of financial reform.

Their vehicle is the Independent Agency Regulatory Analysis Act (S. 3468), backed by Sens. Susan Collins (R-Maine), Mark Warner (D-Va.), and Rob Portman (R-Ohio), and slated for markup next week in a committee headed by Sen. Joe Lieberman (I-Ct.). This innocent-sounding measure would impose an unnecessary, costly, and time-consuming layer of new requirements for cost benefit analysis on financial watchdog agencies such as the Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), and the newly created Consumer Financial Protection Bureau (CFPB).

Existing cost-benefit analysis requirements, and related legal challenges, are already a major source of delay in financial rulemaking. S. 3468 would add at least thirteen new resource-intensive analyses of regulatory costs before a rule can be finalized. In addition, the Office of Information and Regulatory Affairs (OIRA) would get to review any significant new rule, guidance, or policy – a process could add far more time and possibly lead to new rules being abandoned altogether. OIRA has a long standing reputation for blocking environmental and safety regulations, as well as generally being sympathetic to industry arguments that regulation is excessively costly. The big banks could use their influence to turn this tiny office into a bottleneck for all financial regulation. Wall Street lobbyists would have another powerful set of tools to delay and derail the implementation of the safeguards that are needed to protect our banking system and the wider economy.

Please urge your senators to oppose S. 3468.

It is especially important to contact members of the committee considering the bill:

  • Joe Lieberman (I-Ct.) – 202-224-4041
  • Susan Collins (R-Maine) – 202-224-2523
  • Carl Levin (D-Mich.) – 202-224-6221
  • Daniel Akaka (D-Hawaii) – 202-224-6361
  • Tom Coburn (R-Okla.) – 202-224-5754
  • Scott Brown (R-Mass.) – 202-224-4543
  • Thomas Carper (D-Del.) – 202-224-2441
  • Mark Pryor (D-Ark.) – 202-224-2353
  • John McCain (R-Ariz.) – 202-224-2235
  • Ron Johnson (R-Wis.) – 202-224-5323
  • Mary Landrieu (D-La.) – 202-224-5824
  • Claire McCaskill (D-Mo.) – 202-224-6154
  • Rob Portman (R-Ohio) – 202-224-3353
  • Rand Paul (R-Ky.) – 202-224-4343
  • Jon Tester (D-Mont.) – 202-224-2644
  • Mark Begich (D-Alaska) – 202-224-3004
  • Jerry Moran (R-Kan.) – 202-224-6521

(Or you can call the U.S. Capitol at 1-888-291-9824 and ask for the Senator of your choice.)

Thank you for your commitment to financial reform.

Sincerely,

Americans for Financial Reform