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[UIGEA] Letter - Chamber of Commerce (11/20/07)

[UIGEA] Letter - Chamber of Commerce (11/20/07)

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05/09/2014

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CHAMBER OF COMMERCE

OF THE

UNITED STATES OF AMERICA
R. BR U C E J O S T E N
EXECUTIVE VICE PRESIDENT GOVERNMENT AFFAIRS

1615 H STREET, N.W. WASHINGTON, D.C. 20062-2000 202/463-5310

November 20, 2007

The Honorable Jim Nussle Director Office of Management and Budget Eisenhower Executive Office Building 1650 Pennsylvania Avenue, NW Washington, DC 20503 Re: Implementation of the Unlawful Internet Gambling Enforcement Act of 2006 Dear Director Nussle: The U.S. Chamber of Commerce, the world’s largest business federation representing more than three million businesses and organizations of every size, sector, and region, takes no position on internet wagering. The Chamber notes that the Unlawful Internet Gambling Enforcement Act (UIGEA) itself does not alter “any Federal or State law or Tribal-State compact prohibiting, permitting, or regulating gambling within the United States.” Similarly, we are not seeking any changes to federal, state or tribal gambling policies. The Chamber does believe, however, that the federal “good government” laws that regulate the regulatory process need to be adhered to regardless of the specific issues involved. Although these “good government” laws include the Regulatory Flexibility Act, the Information Quality Act, and Executive Order 12866 as amended, the Chamber writes specifically regarding the Paperwork Reduction Act (PRA) since the Chamber has been a strong supporter of the PRA from its inception. One reason for the Chamber’s long-standing involvement with the implementation of this law is that it provides unique authority to OMB— authority that is separate and distinct from agency regulatory development and promulgation functions, and from other OMB regulatory review responsibilities. With respect to the PRA, the Chamber understands that the Center for Regulatory Effectiveness (CRE) has formally raised concerns to OMB regarding the Treasury Department’s (Department) compliance with their legal responsibilities to a proposed collection of information. The concerns expressed by CRE include an assertion that the Department did not provide OMB with the statutorily required “specific, objectively supported estimate of burden” as part of their proposed information collection. Among the specific authorities provided by the PRA to the Director of OMB are those contained in § 3504 which states that “the Director shall– (1) review and approve proposed agency collections of information.” OMB has sole authority for approving, or not approving, a

proposed collection of information, it is essential that you closely review the Department’s Information Collection Request before discharging your statutory authority in this matter. OMB’s unique authority over proposed information collections is not shared with any other agency. Accordingly, it is incumbent on OMB’s leadership to set the standard for regulatory review through the exercise of their PRA responsibilities. Thus, the Chamber strongly encourages you not to approve the proposed collection of information associated with the UIGEA unless and until it fully complies with all statutory requirements. Sincerely,

R. Bruce Josten

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