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Board Report: 2013-AE-B-008 July 1, 2013

Board Should Enhance Compliance with Small Entity Compliance Guide Requirements Contained in the Small Business Regulatory Enforcement Fairness Act of 1996

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Appendix D Management's Response


June 24, 2013

Mark Bialek, Inspector General
Federal Reserve Board of Governors
Mail Stop 300
20th Street & Constitution Ave., NW
Washington, D.C. 20551  

Dear Inspector General Bialek:
Thank you for providing the Federal Reserve Board an opportunity to comment on your draft Evaluation Report regarding Small Entity Compliance Guide requirements.  We appreciate your review of this process and that you identified guides prepared by the Federal Reserve that you consider to be appropriate models for future guides.  Your report includes two recommendations that we concur with and will take steps to implement.

First, you reviewed a number of small business compliance guides issued by the Board since 2008 in light of the requirements of the Small Business Regulatory Enforcement Fairness Act ("Act").   The Act requires an agency "in its sole discretion" to "take into account the subject matter of the rule and the language of relevant statutes, [and] ensure that the guide is written using sufficiently plain language likely to be understood by affected small entities."1 Although it is natural for the complexity of these guides to vary based on the complexity of the regulation at issue, you observed that, at times, the substantive and stylistic differences observed among guides was a result of the Board's decentralized approach to guide creation.  You have recommended that the compliance guides prepared by the Board follow a standard method or approach.  We agree, and will work to adopt a consistent, centralized approach toward the preparation of small business compliance guides that will draw on the qualities that you found helpful in your review, and improve the overall usefulness of the small business compliance guides.Second, you note that the Act requires the Board to issue annual reports to Congress on the Board's compliance with the requirement to produce small business compliance guides. We will work with the Congressional Liaison Office to confirm and ensure that such reports are filed on a timely basis.



Scott G. Alvarez
General Counsel and CommunityAffairs


Sandra F. Braunstein
Director, Division of Consumer