Comments to OMB on the Proposed Revisions to Circular A-4

To the Office of Management and Budget on proposed revisions to Circular A-4.



June 1, 2023


Testimony and Public Comments

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OMB’s proposed revisions to Circular A-4 represent an essential and important step to update 20-year-old guidance. Much has changed in financial markets and in economic and scientific understanding in the past two decades, which merits updates to regulatory analysis—in particular regarding approaches to discounting. Our comments below focus on three key issues that have been updated in the proposed revision to Circular A-4: (1) approaches to discounting; (2) the scope of analysis; and (3) the newly proposed approach to distributional weighting. We conclude by noting the important role of OMB guidance for ensuring analytical consistency across agencies.


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