This bill amends section 2222 of the Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA, 12 U.S.C. 3311). It replaces the phrase “appropriate Federal banking agency” with the broader statutory term “Federal financial institutions regulatory agency,” shortens the review cycle from once every 10 years to once every 5 years, and adds a mandatory internal ‘‘cumulative impact’’ review for each covered agency.
The new internal review must (among other things) assess effects on consumer access, availability of products to financial and nonfinancial firms, credit availability and market liquidity, and the balance of benefits and costs for safety, soundness, and the broader economy; it must quantify direct and indirect costs “to the extent practicable” and include recommendations to streamline or eliminate duplicative or outdated requirements. Agencies must summarize these findings in the Council’s EGRPRA reports and may use them when proposing regulatory changes.
The change imposes new analytic tasks on agencies and creates a formal loop for identifying regulations for simplification or elimination.
At a Glance
What It Does
The bill revises EGRPRA (12 U.S.C. 3311) to require each agency listed in section 1003 of the FFIEC Act to perform an internal five‑year review of the cumulative impact of that agency’s regulations. Reviews must evaluate access, availability, credit and liquidity effects, balance benefits and costs, quantify costs where practicable, and propose streamlining actions.
Who It Affects
The statute applies to the ‘‘Federal financial institutions regulatory agencies’’ as defined in section 1003 of the FFIEC Act (the set of federal banking and thrift regulators covered there) and therefore affects their rulewriters and supervision shops. Regulated entities — commercial banks, community banks, credit unions, nonbank lenders, and fintech firms — will feel the downstream effects because reviews can lead to regulatory revisions or eliminations. The FFIEC itself will receive expanded, agency‑level material for its periodic reports.
Why It Matters
The bill forces more frequent, agency‑level accounting for cumulative regulatory burdens and demands quantified economic analysis. That changes the informational baseline for future rulemaking and could increase administrative pressure to streamline or rescind rules; it also creates measurable workload and methodological requirements that agencies must satisfy to comply.
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What This Bill Actually Does
The REVIEW Act rewrites EGRPRA’s review mechanics so that every federal financial regulator named in the FFIEC statute must do a formal internal audit of the cumulative effects of the rules it issues. Agencies keep the existing public comment solicitation, but must supplement public input with an agency‑led review that focuses on market access, firm access to products, credit availability and market liquidity, and the trade‑offs between regulatory benefits and economic costs.
The statute explicitly asks agencies to quantify direct and indirect costs where practicable and to identify candidate regulations for streamlining, simplification, or elimination.
Practically, an agency’s review will look like an internal policy and economic memo: inventory the agency’s rules, assemble public comments and supervisory inputs, estimate how those rules interact to affect consumers and markets, and produce recommendations. Those findings must be summarized and handed to the EGRPRA Council for inclusion in its report; the bill tells the Council to consider both public comments and these internal reviews when deciding whether to reduce regulatory burdens by regulation.The law does not create a new independent reviewer or an enforcement pathway that forces agencies to implement the suggested streamlining; it requires reporting, quantification “to the extent practicable,” and recommendations.
Because the change also shortens the cadence from ten years to five, agencies face a recurring obligation to update their inventories and analyses on a tighter schedule. The definition of which agencies must comply is drawn directly from the FFIEC Act, so the statutory scope mirrors the FFIEC membership rather than the older ‘‘appropriate Federal banking agency’’ phrasing.That combination — more frequent reviews, explicit quantification duties, and mandated recommendations — raises both operational tasks (data collection, analytic standards, interagency coordination) and strategic consequences (a sustained record of internal findings that can be used in deregulatory or streamlining efforts).
Agencies will need to choose methods for measuring cumulative effects; the statute leaves those methodological choices to agencies but makes the results part of the official EGRPRA record.
The Five Things You Need to Know
The bill amends Section 2222 of EGRPRA (12 U.S.C. 3311) to replace “appropriate Federal banking agency” with the FFIEC‑defined term “Federal financial institutions regulatory agency.”, It shortens the statutory review cycle from once every 10 years to once every 5 years for both agency reviews and the Council’s reporting obligations.
Each covered agency must conduct an internal review that (A) assesses consumer access and firm access to products, (B) assesses credit availability and market liquidity effects, (C) weighs safety‑and‑soundness benefits against costs to the economy, (D) quantifies direct and indirect economic costs to the extent practicable, and (E) recommends streamlining or eliminating duplicative or outdated rules.
Agencies must summarize the findings of their internal cumulative‑impact reviews and include those summaries in the materials the Council submits under EGRPRA; the Council must consider both public comments and the agencies’ internal findings when addressing regulatory burdens.
The statute adds an explicit definition hook: it references section 1003 of the Federal Financial Institutions Examination Council Act of 1978 to define which regulators are covered, tying this review duty to the FFIEC membership list.
Section-by-Section Breakdown
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Short title
Provides the bill’s official name: the “Regulatory Efficiency, Verification, Itemization, and Enhanced Workflow Act of 2025” or “REVIEW Act of 2025.” This is a housekeeping provision that does not alter substance but frames downstream references to the statute.
Scope and terminology changes
Replaces every instance of “appropriate Federal banking agency” with “Federal financial institutions regulatory agency,” thereby aligning EGRPRA review obligations with the roster of regulators listed in section 1003 of the FFIEC Act. That change broadens the statutory phrasing to the FFIEC membership and reduces ambiguity about which agencies must perform reviews.
Review frequency and Council representation language
Deletes the phrase that limited reviews to agencies “represented on the Council” and shortens the mandated cadence for the statutory review process from once every 10 years to once every 5 years. The practical result is that both individual agencies and the EGRPRA reporting cycle will operate on a more frequent timetable, creating a recurring compliance and analytic burden.
Internal cumulative‑impact review requirements
Adds a stand‑alone internal review requirement listing six discrete elements: assessments of consumer access, availability to firms, credit availability and market liquidity, a benefits‑versus‑costs assessment tied to safety and economy, practicable quantification of direct and indirect costs, and recommendations to streamline or remove duplicative rules. The text leaves methodological choices and the scope of quantification to the agencies but makes these outcomes mandatory content of the review.
Integration into the EGRPRA reporting process
Directs agencies to supply summaries of their internal review findings to the Council and requires the Council to consider both public comments and the agencies’ internal findings when identifying regulatory burdens to address ‘‘by regulation.’’ The bill therefore creates a formal channel for agency self‑assessments to influence the Council’s deregulatory or simplification actions, while preserving the Council’s existing public‑comment role.
Definition reference to FFIEC Act
Adds an explicit cross‑reference defining “Federal financial institutions regulatory agency” by pointing to section 1003 of the Federal Financial Institutions Examination Council Act of 1978. That ties the statutory duties directly to the FFIEC membership list and avoids creating a new definitional framework inside EGRPRA itself.
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Explore Finance in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Consumers who face access constraints: the bill forces agencies to identify and report rules that reduce consumers’ ability to obtain accounts, credit, or payment services, which could lead to targeted simplifications that expand access.
- Smaller financial firms and nonbank providers: by directing agencies to identify duplicative and unnecessarily burdensome regulations, the bill creates a documented rationale for easing compliance costs that disproportionately affect community banks, credit unions, and some fintechs.
- Regulatory policy teams and Congressional staff: more frequent, agency‑level assessments create a richer evidence base for legislative or executive oversight, making it easier to locate candidates for targeted reform or harmonization.
- Compliance and legal operations in regulated firms: if agencies act on recommendations, firms may see fewer overlapping requirements or clearer compliance expectations, reducing recurring compliance expenses over time.
Who Bears the Cost
- Federal financial institutions regulatory agencies: agencies must allocate staff, buy analytic tools, and develop methodologies to perform recurring cumulative‑impact reviews and cost quantification on a five‑year cadence.
- Taxpayers/agency budgets: unless Congress provides new funding, agencies will need to redirect resources from other priorities (rulewriting, supervision, enforcement) to meet these analytic demands.
- Regulated entities during the review period: firms will likely face additional data requests and information‑gathering burdens as agencies try to quantify direct and indirect costs and measure market effects.
- Economists and outside analytics vendors: demand for specialized economic analyses, data aggregation, and modeling will rise, increasing consultancy and contracting costs for agencies and possibly for industry participants that want to influence or respond to reviews.
Key Issues
The Core Tension
The central dilemma is the trade‑off between improving transparency and efficiency (by forcing frequent, quantified reviews that can identify unnecessary burdens) and preserving the agencies’ statutory missions to protect safety, soundness, and consumers; relying on agency self‑assessment can surface real simplification opportunities but also creates incentives and methodological gaps that may downgrade protections or produce uneven, politicized results.
Measuring ‘‘cumulative impact’’ is analytically difficult. Rules interact across agencies and markets in non‑linear ways; attributing changes in credit availability or market liquidity to a specific agency’s rule set requires counterfactuals, robust data, and methodological choices that the bill leaves unspecified.
The phrase “to the extent practicable” limits judicial reviewability but opens the door to widely divergent quality of analysis across agencies and review cycles.
The law relies on internal, agency‑conducted reviews rather than independent evaluation. That preserves institutional knowledge but also creates incentives for framing findings in ways that align with an agency’s existing policy posture.
The statutory mandate to recommend streamlining creates a built‑in political vector: a documented list of costly rules can be used to justify rollbacks even where the public‑safety rationale is contested. Finally, because the bill mandates reporting and recommendations but does not require agencies to adopt changes, it may produce a steady stream of identified burdens without resolving them — and the new five‑year cadence could strain already limited analytic and supervisory resources, potentially delaying other regulatory work.
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