GAO: Regulators’ decennial banking burden reviews lack follow-through

Brian Bateman — Sat, 25 Jul 2026 01:03:24 +0000

GAO released a new report July 23, 2026 finding that federal banking agencies’ decennial reviews of “regulatory burden” under the Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA) often leave it unclear how—and whether—the review’s findings translated into specific regulatory changes.

For readers who want accountability in how paperwork-reduction efforts are managed, the audit’s core message is straightforward: regulators can describe the review process, but GAO says they don’t consistently document what outcomes followed, or connect issues raised in the reviews to concrete actions.

What EGRPRA requires

EGRPRA requires the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) to review their regulations at least once every 10 years. The statute also calls for a joint report to Congress.

GAO says the agencies were in their third such review cycle as of July 2026.

GAO’s finding: outcomes are hard to connect to subsequent actions

GAO says the connection between EGRPRA reviews and later regulatory actions is often unclear. In GAO’s account, some actions described around the EGRPRA effort were initiated in response to other statutory requirements, while others were started before or while the review was underway.

GAO also found documentation gaps about attribution. In a review of Federal Register final rulemakings that cited EGRPRA from January 2014 through December 2023, GAO identified 41 final rulemakings meeting its criteria—but GAO says only seven of those (17%) specifically cited comments received during the EGRPRA review. For the remaining 34 rulemakings, GAO says agencies either did not explain how the action connected to EGRPRA or used broader language without describing how the EGRPRA work contributed.

What’s missing inside the review process

Beyond the attribution problem, GAO says the agencies don’t have fully documented procedures for key decision steps—particularly: (1) identifying which rules are outdated or unduly burdensome, and (2) determining whether issues raised in the reviews warrant action.

GAO also says the review processes don’t fully incorporate leading-practice analytical elements for retrospective reviews, including a framework for (a) prioritizing which rules to analyze, (b) conducting cost-benefit analysis (where practicable), and (c) assessing the combined or cumulative burden of multiple regulations.

Six recommendations—what agencies are being asked to do next

GAO makes six recommendations, with two each directed to the Federal Reserve, FDIC, and OCC. GAO’s recommendations ask each agency to implement documented procedures for identifying outdated, unnecessary, or unduly burdensome regulations and deciding on actions during EGRPRA reviews, and to incorporate a framework for prioritization, cost-benefit analysis, and cumulative-burden assessment.

GAO reports that the agencies neither agreed nor disagreed with the recommendations, and it lists them as open.

Why this matters to everyday finance

Even when the end result is “no change,” paperwork requirements affect compliance workflows, staffing, and operating costs for banks—and those costs can ultimately affect customers and businesses that rely on financial services.

GAO’s focus here is accountability and transparency: the next EGRPRA cycle is a key test of whether regulators build a decision record that makes review outcomes easier to evaluate and harder to dismiss as process without measurable follow-through.