[Senate Hearing 113-91]
[From the U.S. Government Publishing Office]
S. Hrg. 113-91
NOMINATIONS OF: WANDA FELTON AND KATHERINE M. O'REGAN
=======================================================================
HEARING
before the
COMMITTEE ON
BANKING,HOUSING,AND URBAN AFFAIRS
UNITED STATES SENATE
ONE HUNDRED THIRTEENTH CONGRESS
FIRST SESSION
ON
NOMINATIONS OF:
Wanda Felton, of New York, to be First Vice President, Export-Import
Bank of the United States
__________
Katherine M. O'Regan, of New York, to be an Assistant Secretary,
Department of Housing and Urban Development
__________
SEPTEMBER 10, 2013
__________
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COMMITTEE ON BANKING, HOUSING, AND URBAN AFFAIRS
TIM JOHNSON, South Dakota, Chairman
JACK REED, Rhode Island MIKE CRAPO, Idaho
CHARLES E. SCHUMER, New York RICHARD C. SHELBY, Alabama
ROBERT MENENDEZ, New Jersey BOB CORKER, Tennessee
SHERROD BROWN, Ohio DAVID VITTER, Louisiana
JON TESTER, Montana MIKE JOHANNS, Nebraska
MARK R. WARNER, Virginia PATRICK J. TOOMEY, Pennsylvania
JEFF MERKLEY, Oregon MARK KIRK, Illinois
KAY HAGAN, North Carolina JERRY MORAN, Kansas
JOE MANCHIN III, West Virginia TOM COBURN, Oklahoma
ELIZABETH WARREN, Massachusetts DEAN HELLER, Nevada
HEIDI HEITKAMP, North Dakota
Charles Yi, Staff Director
Gregg Richard, Republican Staff Director
Laura Swanson, Deputy Staff Director
Pat Grant, Counsel
Beth Cooper, Professional Staff Member
Brian Filipowich, Professional Staff Member
Colin McGinnis, Policy Director
Greg Dean, Republican Chief Counsel
John O'Hara, Republican Senior Investigative Counsel
Travis Hill, Republican Counsel
Dawn Ratliff, Chief Clerk
Kelly Wismer, Hearing Clerk
Shelvin Simmons, IT Director
Jim Crowell, Editor
(ii)
C O N T E N T S
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TUESDAY, SEPTEMBER 10, 2013
Page
Opening statement of Chairman Johnson............................ 1
Opening statements, comments, or prepared statements of:
Senator Crapo................................................ 2
NOMINEES
Wanda Felton, of New York, to be First Vice President, Export-
Import Bank of the United States............................... 3
Prepared statement........................................... 16
Biographical sketch of nominee............................... 18
Katherine M. O'Regan, of New York, to be an Assistant Secretary,
Department of Housing and Urban Development.................... 5
Prepared statement........................................... 26
Biographical sketch of nominee............................... 27
Responses to written questions of:
Chairman Johnson......................................... 38
Senator Crapo............................................ 38
NOMINATIONS OF:
WANDA FELTON, OF NEW YORK,
TO BE FIRST VICE PRESIDENT,
EXPORT-IMPORT BANK OF THE UNITED STATES;
KATHERINE M. O'REGAN, OF NEW YORK,
TO BE AN ASSISTANT SECRETARY,
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
----------
TUESDAY, SEPTEMBER 10, 2013
U.S. Senate,
Committee on Banking, Housing, and Urban Affairs,
Washington, DC.
The Committee met at 10:04 a.m., in room SD-538, Dirksen
Senate Office Building, Hon. Tim Johnson, Chairman of the
Committee, presiding.
OPENING STATEMENT OF CHAIRMAN TIM JOHNSON
Chairman Johnson. I call this hearing to order. Today we
consider two nominations: the Honorable Wanda Felton, to be
First Vice President of the Export-Import Bank of the U.S.; and
Dr. Katherine O'Regan, to be Assistant Secretary for Policy
Development and Research at the U.S. Department of Housing and
Urban Development.
Ms. Felton has been renominated to be the First Vice
President of the Export-Import Bank. Ms. Felton was previously
confirmed by the Senate by voice vote for her first term in
2011. During her first term, Ms. Felton helped lead the Export-
Import Bank's efforts in promoting the President's National
Export Initiative to double exports by 2015. She was critical
to the Bank's efforts in emerging markets, particularly Sub-
Saharan Africa. Ms. Felton has also participated in multiple
global access events to expand U.S. companies' export
opportunities. Prior to joining the Export-Import Bank, Ms.
Felton spent nearly 25 years working in the financial sector in
a variety of positions, including operating MAP Capital
Advisors, a financial advisory firm. Ms. Felton started her
career as a loan officer at the Export-Import Bank.
Dr. Katherine O'Regan has been nominated to be Assistant
Secretary for Policy Development and Research at HUD. The
Office of Policy Development and Research performs policy
analysis, research, and evaluations to help Congress and HUD
make informed policy decisions. Dr. O'Regan is currently a
professor of public policy and planning and director of the
Public and Nonprofit Management and Analysis Program at the
Wagner Graduate School of Public Service, New York University.
She holds a Ph.D. in economics from the University of
California at Berkeley and spent 10 years teaching at the Yale
School of Management. Dr. O'Regan's current research includes
work on a variety of affordable housing, community development,
and nonprofit management topics. She serves on the board of the
Reinvestment Fund, the advisory board for NYU's McSilver
Institute for Poverty Policy and Research, and the editorial
board for the Journal of Policy Analysis and Management.
Ms. Felton and Dr. O'Regan both have impressive backgrounds
and are well qualified for the positions to which they are
nominated. I hope we can move them through the Committee in a
timely manner.
I now turn to Ranking Member Crapo for his opening
statement.
STATEMENT OF SENATOR MIKE CRAPO
Senator Crapo. Thank you, Mr. Chairman.
Today the Committee is considering two important
nominations for two different organizations, and you have been
very thorough in your explanation of our nominees, and so I
will be brief.
Ms. Wanda Felton is being reappointed by the President, as
you have said, Mr. Chairman, to her position as the First Vice
President and Vice Chair of the Export-Import Bank of the
United States. In that position, Vice Chair Felton stands ready
to step into the shoes of President and Chairman when required,
and she has held that position, as you indicated, since May of
2011.
Ms. Katherine O'Regan was recently nominated by the
President to be Assistant Secretary for Policy Development and
Research at the U.S. Department of Housing and Urban
Development. Ms. O'Regan's position requires a critical
understanding of housing markets and issues that homeowners
face from both a quantitative and policy angle during a period
that may prove to be among the most pressing and complex of our
time.
While each nomination is unrelated to the other, the two
still share at least one critical requirement in their
respective jobs, and that critical point here going forward is
that each of the nominees must today be committed to greater
transparency and accountability in the work they do for their
agencies.
Equally important is that each nominee understands the
importance of having a well-run institution and commit
themselves to accomplish their goals without burdening the
American taxpayer.
I look forward to hearing for the nominees and working with
Chairman Johnson to move these nominations through the process
and to the floor.
Thank you, Mr. Chairman.
Chairman Johnson. Thank you, Senator Crapo.
Would any other Senator like to make an opening statement?
[No response.]
Chairman Johnson. The record will remain open for Senators
who wish to submit an opening statement.
We will now swear in the nominees. Will the nominees please
rise and raise your right hand? Do you swear or affirm that the
testimony that you are about to give is the truth, the whole
truth, and nothing but the truth, so help you God?
Ms. Felton. Yes.
Ms. O'Regan. Yes.
Chairman Johnson. Do you agree to appear and testify before
any duly constituted committee of the senate?
Ms. Felton. Yes.
Ms. O'Regan. Yes.
Chairman Johnson. Please be seated. Please be assured that
your written statement will be part of the record. I invite you
to introduce your family and friends in attendance before
beginning your statement.
Ms. Felton, please proceed.
STATEMENT OF WANDA FELTON, OF NEW YORK, TO BE FIRST VICE
PRESIDENT, EXPORT-IMPORT BANK OF THE UNITED STATES
Ms. Felton. Thank you, Chairman Johnson. My husband,
Michael Owens, is sitting directly behind me, and my cousin,
Reginald Felton, is here as well. Thank you.
Thank you Mr. Chairman. Chairman Johnson, Ranking Member
Crapo, and the Members of the Committee, thank you for inviting
me to testify today. I am extremely gratified that President
Obama has nominated me to serve a second term as First Vice
President and Vice Chair of the Export-Import Bank of the
United States. If confirmed, I look forward to working with you
to continue growing exports and supporting U.S. jobs.
I want to, as I had previously done, acknowledge again my
husband, Michael Owens, and my other family member who is here.
Eximbank is the official export credit agency of the United
States. The Bank's mission is straightforward: to promote U.S.
job growth and job retention through exports. The Bank provides
financing to help U.S. companies expand into overseas markets
when financing is not available in the private sector. Eximbank
also steps in when there is a need to level the playing field
because U.S. exporters are facing foreign competitors with
financing from their Governments. The goal is to take financing
off the table as a competitive factor so that American
companies can compete for exports fair and square. Importantly,
Eximbank operates at no cost to U.S. taxpayers. The Bank
generated $1.1 billion for U.S. taxpayers in fiscal year 2012
alone.
Eximbank is central to the National Export Initiative to
double exports by 2015. President Obama's goal in announcing
this initiative was to stimulate job growth and position our
economy for sustained competitiveness and prosperity. I am
passionate about this mission, and there is good reason for my
enthusiasm.
``Made in the USA'' remains the world's strongest brand.
However, the global economy has never been more competitive. I
believe we have a responsibility to do what we can to help
American companies win the battle for international market
share. In fiscal year 2012, Eximbank supported an estimated
255,000 jobs at 3,600 companies.
During my first term, I traveled to 20 cities and towns
across the United States to engage small businesses and other
business leaders in an effort to promote the President's
National Export Initiative. If confirmed, I will continue this
outreach because small businesses are the bedrock of our
economy and their prosperity is essential to job creation.
In fiscal year 2012, Eximbank authorized $6.1 billion of
direct support for small businesses, and this represented 88
percent of our transaction volume that year. When indirect
exports are taken into account, Eximbank provided a total of
$7.5 billion to support small business.
It is a fact that large exporters win sales that feed a
huge but hidden chain of small and middle-market companies.
Eximbank recognizes the potential of this economic leverage and
has sought to amplify it.
In addition to small business outreach, I led the
President's--I am sorry. I led the Bank's effort to increase
commercial engagement between the United States and Sub-Saharan
Africa. Eximbank has a congressional mandate to promote trade
with Africa, and the President has made this a centerpiece of
his trade policy.
I have worked to advance our congressional mandate and
promote the President's agenda. I worked closely with the
Bank's Sub-Saharan Africa Advisory Committee to develop a
strategic plan to help the Bank achieve more robust results in
Africa--without taking undue risk.
I look at every transaction through the lens of financial
merit. Is the transaction creditworthy? Is there a reasonable
assurance of repayment? That is always my starting point.
For 15 years I worked in private equity. Many of my clients
invested in small and middle-market growth companies, so I have
had the opportunity prior to joining Eximbank to steer capital
to small businesses, including companies owned by women and
minority entrepreneurs. I also did business in Latin America,
India, Africa, and parts of Asia. These are some of Eximbank's
most important markets.
Let me close by noting that I began my career at Eximbank.
I learned credit analysis at the Bank, and I have worked in
finance ever since. I have approximately 25 years of experience
in credit and financial analysis which brings a perspective
that is valued by board members and career staff.
Finally, it is impossible for me to convey how much it has
meant to me to be able to return to Eximbank. The Bank has
changed dramatically under Chairman Hochberg's leadership. In
many ways, it is unrecognizable from the place I worked in the
early 1980s. The commercial vitality and energy are palpable.
Eximbank is reaching many more small businesses and supporting
more U.S. jobs than ever before.
However, one thing has not changed: The Bank has world-
class employees. They take their fiduciary duty to protect the
public trust very seriously, and these public servants care
deeply about Eximbank's mission. They could work anywhere
making a lot more money, and yet they choose Government
service. They work long hours to provide financing that keeps
American workers employed. It is personal to them.
If confirmed, it would be a privilege for me to continue
working with such a fine group of people.
Thank you.
Chairman Johnson. Thank you, Ms. Felton.
Dr. O'Regan, please proceed.
STATEMENT OF KATHERINE M. O'REGAN, OF NEW YORK, TO BE AN
ASSISTANT SECRETARY, DEPARTMENT OF HOUSING AND URBAN
DEVELOPMENT
Ms. O'Regan. Chairman Johnson, Senator Crapo, and Members
of the Committee, I am honored to appear before you today as
you consider my nomination as the Assistant Secretary for the
U.S. Department of Housing and Urban Development's Office of
Policy Development and Research. I would like to start with
some acknowledgments of family and friends. In addition to
those watching from a distance, my brother Bill and his son,
Billy, are seated behind me today. And watching with several
sisters of mine, I want to specifically acknowledge my mother,
Mary O'Regan, whose own career so greatly shaped my path to
this hearing. Through her work in public health and my father's
work in education, I was taught early the tremendous value of
public service.
My mother is a nurse who spent most of her professional
career running a health clinic located in a HUD-funded public
housing project. I spent formative years witnessing the
importance of place, how neighborhoods and communities matter
in the lives of families, and how very important policies and
community institutions can be when well run.
My career has focused on such communities, policies, and
institutions, so I would like to briefly highlight three
aspects of my background most relevant for this position that
also shed light on how I see this role.
First, my training and research are well aligned with HUD
broadly and this office specifically. For more than 20 years, I
have taught and conducted research on a range of issues related
to housing policy, urban areas, and community development. This
includes work focused on how and why neighborhoods and
communities change, what policies might drive economic
improvements, and research evaluating the various effects of
housing policies. As an economist who does quantitative work, I
am a frequent user of the data this office collects. As a
researcher whose own work speaks directly to policy, I
appreciate the critical contribution of this office in driving
data-driven policy decisions. Part of the office's charge is to
link to the broader research community, of which I am a
longstanding member.
Second, the Office of Policy Development and Research has a
much broader and more important set of constituents, namely,
the wide array of Federal, State, and local actors in the
housing and community development fields. I have been actively
engaged with members of these groups far beyond my research,
from advising and collaborating with local agencies to formal
and informal work with community development organizations. My
experience with these groups and agencies provides me with a
much better understanding of their needs and how HUD may better
serve them.
Finally, I have extensive administrative and managerial
experience. Over my career, I have undertaken a range of
leadership roles, including more than a decade leading the
largest Master's program at NYU's Wagner School for Public
Service. My most significant managerial role was as associate
dean of faculty during a time of momentous change at the
school. This position required working collaboratively within
the school, across the university, and with external
stakeholders. I chose to do this work because having well-run
institutions matters, and having managed has improved how I
think about the design of effective policies.
Achieving HUD's mission requires the data and knowledge to
make sound, evidence-based choices about using our limited
resources well, and this is the office's main role: to create
such knowledge, and to participate in policy decisions that
make good use of evidence. Secretary Donovan has emphasized
this approach throughout his tenure and its importance to the
continued transformation of HUD. If confirmed, I look forward
to working tirelessly on this goal, with the Secretary, the
administration, and Members of this Committee, and I would be
honored to have the opportunity to serve.
Thank you, and I look forward to your questions.
Chairman Johnson. Thank you, Dr. O'Regan.
We will now begin asking questions of our witnesses. Will
the clerk please put 5 minutes on the clock for each Member?
Ms. Felton, during the most recent economic crisis, the
Bank was able to help American exporters who were finding it
difficult to acquire private financing. As the economy
continues to improve, how do you see the Bank's role changing?
Ms. Felton. Thank you, Chairman Johnson. The Bank has had
record growth in the last 4 years, and that is a reflection of
the economic conditions that existed. It is true that the Bank
tends to be countercyclical and become more active during
difficult economies. I would expect that as the economy
improves that the Bank's activity would level off. I think we
have already begun to see that with respect to the number of
applications that we are receiving to finance aircraft, and
that would continue in all likelihood as the economy improves.
Thank you.
Chairman Johnson. Ms. Felton, can you describe how the Bank
has worked to meet the goal of the President's National Export
Initiative, which seeks to double U.S. exports by 2015?
Ms. Felton. Yes, sir. Eximbank is really, I think, at the
center of the President's National Export Initiative. One of
the things that the Bank has done is tried to focus very
actively on bringing more small businesses into exporting, help
them understand the opportunities that are available to them
outside the United States and how to use Eximbank's financing
to support their growth.
There are statistics that abound: 95 percent of the world's
consumers are outside the United States. Some 200 million
people enter the middle class globally each year. There is an
expectation that there will be $2 trillion worth of spending
every year for the next 20 years on infrastructure. These
create enormous opportunities for American businesses, both
large and small, and one of the things the Bank has done is led
a very proactive outreach effort that included 60 what we call
Global Access Forums in the last year in order to make sure
American companies are aware of these opportunities and going
out and seeking them.
Chairman Johnson. Dr. O'Regan, as you mentioned, you have
had considerable experience as a researcher, both producing and
consuming the kind of information that the Office of Policy
Development and Research, PD&R, makes available. How has this
experience informed your goals for your time as the head of the
office, if confirmed?
Ms. O'Regan. Thank you, Chairman. I have been very involved
in research in this area and know PD&R, as it is called, well
and its work. I think the current circumstances in housing
markets have only elevated the importance of having a strong,
independent analytical arm within HUD that can and that does
collect current information on housing markets and has the
capacity to conduct timely evaluations on what is going on in
housing markets and to be active as housing reforms come
through and other policies to see their impact in the market.
So I see that as one of the biggest areas that PD&R should be
focusing on going forward. If confirmed, that would be my
highest priority.
Chairman Johnson. Dr. O'Regan, in addition to your public
policy research credentials, you also bring both research and
experience in management to your nomination. How would this
experience shape your management agenda at PD&R?
Ms. O'Regan. Thank you, Chairman. Yes, that is the other
side of the research agenda that I have. It was driven in part
by observations that I made in the field, but also having spent
10 years at the Yale School of Management, and it gave me
experience that my training in economics had not. And it has
taught me the role of strong governance, transparency and
accountability, and paying as much attention to the
implementation side of developing policies that could work
along with the policies themselves. If you focus on only one,
you can fail.
Chairman Johnson. Ms. Felton, during your time on the
Board, you have focused on increasing American exports to
Africa. Can you explain why increasing exports to Africa is
good for American businesses and workers?
Ms. Felton. Yes, Mr. Chairman. I think it is vitally
important, actually. Consistent with my earlier comment about
the growth that is taking place in emerging markets in
particular more broadly, in Africa there is a projection and
expectation of enormous growth. Seven of the ten fastest-
growing economies in the next 5 years are expected to be in
Africa. We have already seen over the last decade real growth,
not just economic growth but demographic changes and political
stability that create a business climate in many countries that
should be very attractive for investment and trade.
My observation is that if American companies participate in
this, again, not just in Africa but globally, that offers the
opportunity to stimulate real economic growth at home with the
opportunity to create jobs and lasting prosperity.
Finally, with respect to Africa, American companies have
not been as active as they could be because, I think, of real
risk aversion and perceptions about risk. However, there are
ways to do business in a way that contains risk and is
thoughtful about the risk that doing business in any foreign
country can present. And, importantly, if we do not put our
stakes down now, we risk being marginalized for a very, very
long time, if not forever. There is a lot of competition from
other countries, particularly coming from Asia, and China
especially; and many of the large infrastructure projects that
need to get built get built once. And if you miss that
opportunity, you are locked out, probably for a generation or
more. And you miss the after sales, the maintenance; you miss
the next opportunity to build a project. And it also relates to
the consumer sector. Consumer brands get established early, and
consumer loyalties get established early. So there is a huge
opportunity across an array of sectors for American companies
to participate and grow jobs.
Chairman Johnson. Senator Crapo.
Senator Crapo. Thank you very much, Mr. Chairman.
Ms. Felton, at the outset I want to thank the Eximbank for
their outreach to small businesses around the country. As I am
sure you are aware, Idaho was the beneficiary just recently of
one of the efforts that the Eximbank is making to help bring
small businesses into a greater understanding of the potential
that is available for us to increase our exporting. And that
was something that was very well attended, and I think it is
going to be very beneficial to the small businesses in Idaho.
And I appreciate the fact that I see that going on around the
country. I think that is important.
Could you repeat again--I think you said something about
this in your opening statement. But the level of success that
we are now achieving among small businesses with the Bank's
efforts, could you discuss that again briefly?
Ms. Felton. Yes, and let me say the Bank was very excited
to have the opportunity to do a Global Access Forum in your
State, Senator.
The Bank, when Chairman Hochberg joined, did about $3.2
billion--I think in his first year, in 2008 did $3.2 billion of
support for small businesses. And in the last year, we reported
$6.1 billion of direct support for small business, and that
does not include an additional amount that was done of indirect
support. By that I mean support that went to larger exporters
who, because they want a sale, were able to participate in the
growth outside the United States and received Export-Import
Bank financing indirectly. It is very important.
That is just our small business number. We have in the last
year authorized $35.8 billion of total authorizations for U.S.
exports.
Senator Crapo. All right. Thank you. And I want to
highlight another point that you made in your statement because
one of the issues that we face with regard to virtually every
agency today is what burden they bring to our budget,
particularly to the impact on the American taxpayer. And as you
have indicated, the Eximbank operates as a self-sustaining
entity and has for some years now. Could you give us those
figures again?
Ms. Felton. Yes. In the last year, Eximbank generated $1.1
billion for the taxpayer.
Senator Crapo. I wish every single one of our Federal
programs could operate in the same way. We would not have the
same problems. But I think that it is notable, and it is
important to make that note as we go into the budget battles
that we will, unfortunately, be getting deeply into--and I
guess fortunately. We need to get into them, and we need to get
them resolved in some good ways.
Another question I have is: You mentioned in your testimony
that one of the first if not the first questions you asked with
regard to any proposal is whether there is a reasonable
assurance of repayment. In that context, one of the questions I
would like to have you respond to is what I have noticed over
the years in observing the Eximbank's operations, which I think
have been handled very well, is that often, as you just
indicated, there are suppliers as well as major manufacturers,
and many others in the chain of production of a product or
delivery of a service, and they are not always all U.S.
companies or all non-U.S. companies. And so a loan could be
proposed for an entity with the basis of the loan being that it
is a U.S. company or that it is going to have suppliers who are
U.S. companies. But other competitors, other competitor
suppliers or other competitor producers, might not be U.S.
companies. And I think it might get a little bit complicated in
trying to make sure that we are not using the Eximbank to
subsidize companies that are not American made, if you will.
Do you understand the question I am asking? It has got to
be an issue that comes up as we deal with the different supply
lines and allocations of production.
Ms. Felton. Yes, sir, I think I understand the question. I
think there may be two questions embedded in there. The
Eximbank is careful--I think you are alluding to content.
Senator Crapo. Yes.
Ms. Felton. The Export-Import Bank has a requirement, a
policy in place that requires that we finance the lesser of 85
percent of the U.S. content or 100 percent of the contract
value. We managed that policy--there are some critics that say
that we should lower our content requirements. However, if we
did that, we might find ourselves in a position of supporting
foreign jobs and production.
We do think it is important to make sure that American
companies are able to compete. And as I noted in my comments,
the global economy is very, very competitive, and many foreign
Governments are providing export finance for their companies,
and we have to be mindful of that. But we also see that as an
opportunity to cofinance with other countries.
And I can provide one example, I think, that is very
illustrative. There is a company that makes crop dusters in
Texas called Air Tractor, and Air Tractor, most of the
production, 70 percent of it, is done in the United States.
However, they build the engines in Canada, and so 30 percent of
the content is Canadian. We cofinanced exports for Air Tractor
with the Canadian export credit agency, EDC, and that way Air
Tractor was able to receive full financing for its exports, and
at the same time Eximbank did not use American taxpayers'
dollars to support the Canadian content.
Senator Crapo. Thank you. I appreciate that, and I do have
some questions for Dr. O'Regan, but I will wait for my next
chance, Mr. Chairman.
Chairman Johnson. Senator Warren.
Senator Warren. Thank you, Mr. Chairman. Thank you. Thank
you both for being here.
Ms. Felton, I very much appreciate the focus in your
original testimony on small businesses and the importance of
the Eximbank and how it is that it can support small businesses
and give them access to markets they might not otherwise have.
And I, like the Ranking Member, am very pleased to see some of
the good news that you are able to bring us that the number of
dollars that have gone into small business lending has
increased from 2008 to 2012.
But the bad news seems to show that over the last 5 years,
the Bank has dedicated a smaller proportion of its lending to
small businesses, and so while small business lending made up
22 percent of Eximbank's lending back in 2008, by 2012,
according to your published reports, it is down to 17 percent.
So I am a little concerned here about the trend. Can you
give us some explanation about what is going on?
Ms. Felton. Yes, Senator. Thank you for the question. It is
a very good one. We are mindful that we have a congressional
mandate to finance or allocate 20 percent of our financing to
small businesses. And what I should have noted is that
although, as you correctly pointed out, the dollar amount that
has gone to small business relative to our total outstanding
financing has declined, the number of transactions that are
represented in our activity is very, very significant. Eighty-
eight percent of our transaction volume in 2012 represented
small businesses. And that is kind of the classic 80-20 rule,
that it is labor intensive, it takes a lot to reach small
businesses, and that it is part of why we are conducting so
many Global Access Forums around the country in order to reach
out and find them and make sure that they know about the
opportunity to work with Eximbank in order to finance their
exports.
But beyond the outreach and the promotion, we have created,
I think, a number of strategies and adopted some innovations in
order to leverage our resources better so that we can get more
done, and I think taken some other very important initiatives.
So when you look at the relative decline as a percentage of
our financing of the dollars that have gone to support small
business, it is really a function of the denominator. What we
are finding is that, you know, there are a number of very large
transactions that are coming to the Bank, some of them having
to do with large infrastructure projects. I will give you an
example. We financed a large petrochemical facility in Saudi
Arabia. It was $5 billion of financing, and I think it created
something like 11,000 jobs or supported 11,000 jobs in the
United States. That is very powerful.
But in order to get the opportunity to support so many jobs
with one transaction that is $5 billion, we would have to go
out and find $1 billion of small business opportunities to
support, and that can be difficult. So that is one of the
things that you are seeing when you see the relative decline in
terms of small business support compared to what we have done
overall.
I would say that--and I will finish this up--in addition to
creating new programs to create more efficiency with respect to
how we process small business activity, we have been very
successful in negotiating opportunities for U.S. procurement,
particularly from small businesses, with respect to some of the
large projects that we finance. So, for example, Pemex is the
large--the national oil company for Mexico. We financed them
for a long time so that they could purchase from the United
States. And a couple of years ago, our project finance team
negotiated a set-aside for small business of $200 million,
asked Pemex to identify 500 small companies that they do
business with. We scrubbed that list to make sure that they, in
fact, were small businesses, that they existed, and that they
complied with the SBA's definition of small business.
So we take the mandate very seriously. We are working
closely with the SBA as part of the Commerce Department, SBA
collaboration on global business solutions, and doing
everything we can in order to promote more financing for small
businesses.
Senator Warren. Well, then let me just wrap this up by
saying I very much appreciate the attention you are giving to
this. I very much appreciate the outreach and the multiple ways
in which you may assist small businesses, sometimes through
large business lending. But I hope that the trend line we are
seeing--and that is dropping from, just in a very short period
of time, 22 percent of the dollars that go out the door are
going to small businesses down to 17 percent of the dollars
going out the door are going to small businesses. I hope that
is a trend line we are going to be able to stop and to reverse,
that it is still the mandate for Eximbank to be able to make
sure that we are getting these dollars directly to our small
businesses.
Ms. Felton. Yes, Senator. I can assure you that the
Chairman is very committed to that, and if confirmed, I would
be very committed as well.
Senator Warren. Good. Thank you very much.
I will hold off on Ms. O'Regan. Thank you. Thank you, Mr.
Chairman.
Chairman Johnson. Ms. Felton, authorizations for women-
owned and minority-owned small businesses reached a record $838
million last year, up almost 17 percent from 2011. What can the
Bank do moving forward to support even more minority-owned and
women-owned businesses?
Ms. Felton. Thank you, Mr. Chairman, for that question. We
have a number of outreach efforts underway in order to reach
more minority-owned businesses. For example, we signed an MOU
with the minority development--supplier development agency at
the Commerce Department so that we can collaborate in working
with them and identifying opportunities to work with minority-
owned firms. Some of the data that they have developed shows
that very often small business exporters export to their
country of home origin, and they have familiarity and
relationships and understand the markets.
And so one of our directors, Director Pat Loui, who is
sitting here behind me, has led the outreach to the Asian
American Pacific Islanders demographic in order to increase our
penetration and make them more aware of opportunities to do
business with Eximbank. I have worked with African American
groups; specifically, I see an opportunity to work with the
African diaspora community, many of whom came here to go to
school, went to college and obtained graduate degrees, and are
a real asset to the United States and Africa. They are not as
risk averse as other companies in terms of going out and
seeking the opportunities. And some of them have engineering
companies that got started with Government contracts and have
demonstrated over, you know, one or two decades the ability to
do whatever it is, in terms of construction and building and
engineering work, and make--I think that there may be an
opportunity to help companies like that that have demonstrable
experience in construction develop opportunities to build small
power plants, do water projects, whatever, in Africa. And we
have done some of that already.
Chairman Johnson. Ms. Felton, what is your experience
dealing with the Native American community?
Ms. Felton. Sir, I personally do not have a lot of
experience dealing with the Native American community. However,
I did have the opportunity to work a little bit with the
Commerce Department. A former official there, Reta Jo Lewis,
was very involved in the Sister Cities and also the Native
American outreach effort through the Commerce Department. So it
is something that we can, I think, put higher up on our list of
priorities.
Chairman Johnson. Yes. Dr. O'Regan, what would your
priorities be as Assistant Secretary for PD&R at HUD?
Ms. O'Regan. Thank you, Mr. Chairman. My first priority, if
I were to be confirmed, is to do an assessment of the current
capacities at PD&R. In 2008, as you probably know, the National
Academy of Sciences did an assessment of PD&R, and one of their
key findings was that over the past several decades, its
capacity had deteriorated. Since then, in the past 5 years,
major strides have been made in increasing its capacity--the
analytical capacity and the data needed for the type of
independent research that we all need for our housing policies.
And so I think the time has come to do an assessment. That
would be the first step, if confirmed, to see what is needed
now to secure the gains that have been made and any additional
steps to be sure that we have the data that we need for
monitoring well-functioning housing markets.
Chairman Johnson. Senator Crapo.
Senator Crapo. Thank you, Mr. Chairman.
Dr. O'Regan, I want to get into some issues that are
specifically going on at HUD right now. I realize that you are
appointed to go there, but I am hopeful that you can comment on
some of these.
Currently at HUD there is a proposed rule on the
Affirmatively Furthering Fair Housing. This rule will provide
data to grantees participating in certain housing programs and
is aimed at fulfilling HUD's responsibility to assure that we
combat discrimination in these programs. Are you familiar with
this proposed rule?
Ms. O'Regan. Yes, I am.
Senator Crapo. Good. Could you tell me specifically what
types of data will HUD be providing under the rule?
Ms. O'Regan. Thank you, Senator, for that question. The
proposed rule has been made, and we are still in the public
comment period, so I have not read through most of the public
comments, and then HUD would probably be responding to those
comments. But I do not know the specifics. On that front,
though, PD&R, for whatever data will be created and put
forward, PD&R would have a very big role. That is where it
should sit. And the goal, as I would see it, if I was
confirmed, is to make sure that we have the burden of the
creation of the data and the transmission of the data on HUD,
not the participants and the local communities, and this
actually might help level the playing field on communities of
different sizes that do not have the scale to be able to get
the data needed themselves; and then to make sure that the data
are going to be able to answer the kind of questions that are
embedded in the proposed rule.
Senator Crapo. Well, thank you. In fact, you answered what
was going to be one of my follow-up questions about where this
burden would fall.
Do you have any privacy concerns? And how will this data
collection interplay with HUD's existing data collection
efforts?
Ms. O'Regan. Thank you, Senator. That would probably be a
little bit speculative from the outside, having read the
proposed rule. There are many publicly available data that are
aggregated at levels that always protect privacy and that are
still at a low enough level of geography that we can do the
kinds of work and assessing what is looking at--how
neighborhoods look relative to other parts of the metropolitan
area. So I would see no need for going below that level for
this type of analysis.
Senator Crapo. All right. That would be important, in my
opinion, to protect the privacy. Can you discuss this rule, the
assessment of the rule the grantees will be required to
complete under the proposed rule? And how does that compare to
the existing analysis of impediments to fair housing choice?
Ms. O'Regan. Senator, the final rule has not been written,
but comparing just the process component of this rule, it moves
the analysis earlier in the process. And so to the extent that
planners are going to take important information into account
in making choices, it moves the data and the information before
the choices are made. And so to me that seems a great
contribution. Adding data into the analysis after a decision is
made is not very useful.
Senator Crapo. We can agree on that. Well, I thank you for
your efforts here, and I will look forward to having a further
discussion with you after we get further into this process and
you are heavily involved in its implementation.
Thank you.
Chairman Johnson. Senator Warren.
Senator Warren. Thank you.
Dr. O'Regan, as you know, the financial crash of 2008 was
quick, sudden, and it caught our Nation unawares and seemed to
catch most of our regulators unawares as well. But the crisis
was years in the making, and there really were a lot of
signposts that we were headed for trouble.
I think specifically about consumer financial products. A
generation ago it was clear, you could see the price of a
credit card, of a mortgage, checking accounts. Both the
borrowers and the lenders knew the terms of what they were
getting into. By the time of the crash, lenders had moved to a
very different business model where they advertised one up-
front price, but then back in the fine print there were lots of
charges and changes in the interest rates and so on that
ultimately changed how much the consumer was paying and
obscured how much the consumer was paying. Buyers were less and
less able to make comparisons among products and less and less
able to tell what kind of obligation they were taking on.
Now, the 2008 crash started one lousy mortgage at a time,
and yet our regulators seemed remarkably caught off guard
during this. As you know, the Office of Policy Development and
Research at HUD is responsible for monitoring the housing
market conditions and analyzing and gathering data. So my
question is: What do you think needs to change at HUD in the
way data are collected and analyzed to make sure we are never
caught by surprise again?
Ms. O'Regan. Senator, thank you for that question. I am
going to build off my earlier response on thinking about that
report from the National Academy of Sciences, which is that the
internal capacity inside PD&R on data and analytics had
declined dramatically, and one part of that was in the
economics and housing market piece. And that has been one of
the areas that has been built up most since 2008, and I think
that is critical. You need ongoing research and data, and you
need the staff capacity to be paying attention. And so the
number of staff that have been lost during that time with
expertise was quite large.
A second piece of this, though, I think, as you know, you
are going to be watching the indicators. You have the data, and
you have got the right staff for doing it. You need to be
forward-looking, and the ability of PD&R to be looking forward
through demonstrations and research had also been limited.
One of the areas in which I know HUD is doing research now
has to do on financial literacy and different types of
counseling programs to both see which ones work and which ones
are more cost effective. That is something we should know as we
are looking to design the solutions to avoiding the next
housing crisis.
So I think you need capacity both for what is going on in
the moment and looking forward.
Senator Warren. And you feel like you have the commitment
that you are going to be able to have the resources you need to
collect the data you need and have the people you need to
analyze them?
Ms. O'Regan. If I am confirmed, that is my highest
priority, and it is why I am taking this job.
Senator Warren. Good. I am delighted to hear it.
Now, I have another question for you along another part of
this line, and that is, as you know, the housing market has not
entirely recovered from the 2008 crisis. According to a recent
study by CoreLogic, one in five families with a mortgage is
still below water. So the question I have for you is: What is
it that your division can do to help inform HUD and to make
certain that HUD is responding to the housing crisis in the
fullest and most effective way?
Ms. O'Regan. Thank you, Senator. I think this is on the
research side. One of the most difficult things is to look out
at a complicated problem like what is going on in housing
markets and see possible solutions, and the benefit of having
ongoing research--and, for example, the decisions that
households make when they are underwater, there has been a
considerable amount of research during this crisis that has
surprised some analysts on who walks away or who does not walk
away and what does it take to be able to--what type of
modifications does it take in order to have sustainable
homeownership, and those insights came from research. And so I
think this is the purview of what PD&R should be strong at, and
these types of lessons from the last several years should shape
the agenda of what research we are doing going forward.
Senator Warren. So I am hearing you say in part that what
you want to do is you want to expand the reach of the research
and take it in some new directions. Is that correct?
Ms. O'Regan. One of the things that PD&R did in the last
year was expand the way it devised its forward-looking research
agenda. One of the criticisms in the National Academy of
Sciences report was that it was insular, looked inside PD&R and
HUD for making these decisions. They took that to heart. They
opened up the process last year, had hearings, conferences, and
input from others to shape the forward-looking agenda in a way
that it should meet the needs of a much broader set of people
who are looking at housing markets.
So I think that process is exactly a much better one than
was used in the past, and I would be recommending using
something like that going forward for setting the research
agenda.
Senator Warren. Good. Well, I just want to say I am very
encouraged by the direction that HUD has already started, but
by the way you talk about the importance of research and as you
rightly say, Ranking Member, the importance of doing the
research that helps us inform decisions before we make them,
that we have a real opportunity here to make better decisions
going forward. So thank you very much. Thank you both. Thank
you for your willingness to serve.
Thank you.
Chairman Johnson. Thank you, Ms. Felton and Dr. O'Regan,
for your testimony and for your willingness to serve our
Nation.
I ask all Members to submit questions for the record by COB
this Friday, September 13. I would also ask the nominees to
please submit your answers to the written questions as soon as
possible so that we can move your nominations in a timely
manner.
This hearing is adjourned.
[Whereupon, at 10:55 a.m., the hearing was adjourned.]
[Prepared statements, biographical sketches of nominees,
and responses to written questions supplied for the record
follow:]
PREPARED STATEMENT OF WANDA FELTON
To Be First Vice President, Export-Import Bank of the United States
September 10, 2013
Thank you Mr. Chairman. Chairman Johnson, Ranking Member Crapo, and
the Members of this Committee, thank you for inviting me to testify
today. I am extremely gratified that President Obama has nominated me
to serve a second term as First Vice President and Vice Chair of the
Export-Import Bank of the United States. If confirmed, I look forward
to working with you to continue growing exports and supporting U.S.
jobs.
I also want to acknowledge the presence and support of my mother
Maro Lester, my husband Michael Owens, and other family members who are
here today.
Ex-Im Bank is the official export credit agency of the United
States. The Bank's mission is straightforward--to promote U.S. job
growth and job retention through exports. The Bank provides financing
to help U.S. companies expand into overseas markets when financing is
not available in the private sector. Ex-Im Bank also steps in when
there is a need to level the playing field because U.S. exporters are
facing foreign competitors with financing from their Governments. The
goal is to take financing off the table as a competitive factor so that
American companies can compete for export sales fair and square.
Importantly, Ex-Im Bank operates at no cost to taxpayers. The Bank
generated $1.1 billion for the U.S. taxpayers in FY2012 alone.
Ex-Im Bank is central to the National Export Initiative to double
exports by 2015. President Obama's goal in announcing this initiative
was to stimulate job growth and position our economy for sustained
competitiveness and prosperity. I am passionate about this mission, and
there is good reason for my enthusiasm.
``Made in the USA'' remains the world's strongest brand. However,
the global economy has never been more competitive. I believe that we
have a responsibility to do what we can to help American companies win
the battle for international market share. In fiscal 2012, Ex-Im Bank
supported an estimated 255,000 American jobs at 3,600 companies.
During my first term, I traveled to 20 cities and towns across the
United States to engage small businesses and other business leaders in
an effort to promote the President's National Export Initiative. If
confirmed, I will continue this outreach because small businesses are
the bedrock of our economy and their prosperity is essential to job
creation.
In fiscal 2012, Ex-Im Bank authorized $6.1 billion of direct
support for small business exporters. This represented 88 percent of
2012 transaction volume. When indirect exports are taken into account,
Ex-Im Bank provided a total of $7.5 billion of support for small
businesses.
It is a fact that large exporters win sales that feed a huge but
hidden chain of small- and middle-market suppliers. Ex-Im Bank
recognizes the potential of this economic leverage and has sought to
amplify it through new programs.
In addition to small business outreach, I led Ex-Im Bank's effort
to increase commercial engagement between the United States and sub-
Saharan Africa. Ex-Im Bank has a congressional mandate to promote trade
with Africa, and the President has made this a centerpiece of his trade
policy.
I have worked to advance our congressional mandate and promote the
President's agenda. I worked closely with Ex-Im Bank's Sub-Saharan
Africa Advisory Committee to develop a strategic plan to help the Bank
achieve more robust results in Africa--without taking undue risk.
I look at every transaction through the lens of financial merit. Is
the transaction creditworthy? Is there a reasonable assurance of
repayment? That is always my starting point.
For 15 years I worked in private equity. Many of my clients
invested in small- and middle-market growth companies so I helped steer
capital to small businesses, including companies owned by women and
minority entrepreneurs. During those years, I also did business in
Latin America, India, Africa, and parts of Asia. These are some of Ex-
Im Bank's most important markets.
Let me close by noting that I began my career at Ex-Im Bank. I
learned credit analysis at the Bank and have worked in finance ever
since. I have approximately 25 years of experience in credit and
financial analysis which brings a perspective that is valued by board
members and career staff.
Finally, it is impossible for me to convey how much it has meant to
me to be able to return to Ex-Im Bank. The Bank has changed
dramatically under Chairman Hochberg's leadership. In many ways, it is
unrecognizable from the place I worked in the early 1980s--the
commercial vitality and energy are palpable. Ex-Im Bank is reaching
many more small businesses and supporting far more U.S. jobs than ever
before.
However, one thing has not changed--Ex-Im Bank has world-class
employees. They take their fiduciary duty to protect the public trust
very seriously and these public servants care deeply about Ex-Im Bank's
mission. They could work anywhere making a lot more money, yet they
choose Government service. They work long hours to provide financing
that keeps American workers employed. It is personal to them.
If confirmed, it would be a privilege to continue working with such
a fine group of people.
Thank you.
PREPARED STATEMENT OF KATHERINE M. O'REGAN
To Be an Assistant Secretary, Department of Housing and Urban
Development
September 10, 2013
Chairman Johnson, Senator Crapo, and Members of the Committee, I am
honored to appear before you today as you consider my nomination as the
Assistant Secretary for the U.S. Department of Housing and Urban
Development's Office of Policy Development and Research. I would like
to start by acknowledging and thanking family members and friends here
today, both physically and virtually. In addition to those watching
from a distance, my brother Bill O'Regan and his oldest child, Bill,
are seated behind me. And watching with several sisters from her home
in Rhode Island, I want to specifically acknowledge my mother, Mary
O'Regan, whose own career so greatly shaped my path to this hearing.
Through her work in public health, and my father's work in education, I
was taught the tremendous importance of public service.
My mother is a nurse who spent most of her professional career
running a community health clinic located within a HUD-funded public
housing project in Providence. I spent formative years witnessing the
importance of place--how neighborhoods and communities matter in the
lives of families--and how very important well-designed public policies
and well-run community institutions can be.
My career has focused on such communities, institutions, and
policies. Let me briefly highlight three aspects of my background most
relevant for this position that also shed light on how I see the
office's role.
First, my training and research are well aligned with HUD broadly
and this office specifically. For more than 20 years, I have taught and
conducted research on a range of issues related to housing policy,
urban areas, and community development. This includes work focused on
how and why neighborhoods and communities change, what policies might
drive economic improvements, and research evaluating the various
effects of housing policies. As an economist who does quantitative
work, I understand the role of the economic affairs division, and use
the data it collects and maintains. As a researcher whose own work
speaks directly to policy, I appreciate the critical contribution of
this department in driving sound data-based policy decisions. Part of
the department's charge is to link to the broader research community,
of which I am a long-standing member.
Second, the office of Policy Development and Research has a much
broader and more important set of constituents, namely the wide array
of Federal, State, and local actors in the housing and community
development fields. I have been actively engaged with members of these
groups far beyond my research, from advising and collaborating with
city and State agencies, to formal and informal work with community
development and based organizations. These experiences provide me with
a much greater understanding of their needs, and how HUD may better
serve them.
Finally, I have extensive administrative and managerial experience.
Over my career, I have undertaken a range of leadership roles,
including more than a decade leading the largest Master's program at
NYU's Wagner School of Public Service. My most significant managerial
role was as Associate Dean of Faculty, during a time of momentous
change at the school and the university. This position required working
collaboratively within the school, across the university, and
externally with key stakeholders. I chose to do this work because
having well-run institutions matters, and having managed has improved
how I think about the design of effective policies.
I believe in HUD's mission of creating and supporting cohesive and
economically healthy communities. Doing so requires the data and
knowledge to make sound, evidence-based choices about using our limited
resources well, and this is the department's main role: to create such
knowledge, and to participate in policy decisions that make good use of
evidence. Secretary Donovan has emphasized this approach in his tenure,
even highlighting its importance to the continued transformation of HUD
itself. If confirmed, I look forward to working tirelessly on this
goal, with the Secretary, Administration, and Members of this
Committee.
I would be honored to serve. Thank you and I look forward to your
questions.
RESPONSES TO WRITTEN QUESTIONS OF SENATOR JOHNSON
FROM KATHERINE M. O'REGAN
Q.1. Dr. O'Regan, for the past few years, PD&R has been working
on a Congressionally mandated Indian Housing Needs Survey. This
survey is the first comprehensive study of the deep housing
needs facing Indian Country since 1996. HUD faced some
criticism from Tribes as it launched the survey, and has since
worked to be more responsive. Going forward, will you commit to
working with Tribes and us in Congress to ensure that the study
stays on track and to maintaining consultation with Tribes?
A.1. Yes. HUD recognizes and commits to a Government-to-
Government relationship with federally recognized tribes. The
study in question is a report on the incidence of housing needs
among Native Americans, Alaska Natives, and Native Hawaiians,
and was mandated by the Senate report language in an
appropriations act. For this study, it is necessary to survey
in-person residents of reservations governed by the sovereign
tribes, and the explicit consent of the tribal authorities that
were randomly selected for the survey is imperative. Further,
the Office of Policy Development and Research (PD&R) has
consulted extensively with elected tribal leaders and tribally
designated housing entities at meetings of their national and
regional organizations. At all times, PD&R has been mindful of
the need for consultation with the tribes that will be
surveyed, and we have to date obtained excellent cooperation
with most tribal governments. So far, all but one have agreed
to participate. This cooperation will continue to be of prime
importance in the completion of the survey, and we will
conscientiously consult with the relevant tribal leadership.
HUD will work with the Members of the Committee to try to
resolve any issues that might threaten the timely release of
objective findings from this very important study.
------
RESPONSES TO WRITTEN QUESTIONS OF SENATOR CRAPO
FROM KATHERINE M. O'REGAN
Q.1. Economic analyses play a very important role in the
drafting and implementation of Federal agency rulemakings. The
Regulatory Flexibility Act was passed by Congress to ensure
that any proposed regulations do not have a disproportionate
regulatory burden on small businesses and small entities. This
rule is very important to ensure that small business viewpoints
and perspectives are taken into consideration by Federal
agencies when drafting and implementing regulations and to
calculate any potential burdens.
What are your thoughts about the Regulatory Flexibility Act
and what role does the Office of Policy Development and
Research play in helping the Department to comply with the law?
A.1. I agree that the Regulatory Flexibility Act plays an
important role in the Federal rulemaking process to keep
agencies focused on the potential compliance burdens faced by
small businesses and similar entities. The Office of Policy
Development and Research (PD&R) is responsible, in cooperation
with the HUD program offices promulgating the rules, for
drafting the Initial and Final Regulatory Flexibility Analyses
required by the Regulatory Flexibility Act when HUD issues a
rule having a significant economic impact on a substantial
number of small entities.
Q.2. Executive Order 12866 requires Federal agencies to conduct
cost/benefit analyses for ``significant regulatory actions''
that may have an annual effect on the economy of $100 million
or more or adversely affect the economy in a material way.
What are your thoughts about Executive Order 12866 and what
role does the Office of Policy Development and Research play in
helping the Department to comply with the Executive order?
A.2. I believe it is very important for Federal agencies to be
cognizant of the full economic effects of regulations, both
positive and negative, and that Executive Order 12866 and its
implementing guidance provide agencies with firm and thorough
guidance on how to do so. The Office of Policy Development and
Research (PD&R) is responsible, in cooperation with the HUD
program offices that promulgate rules, for drafting the
Regulatory Impact Analyses for economically significant
regulations as required by the Executive order. As part of the
rulemaking process, PD&R staff also work with the program
offices to examine alternative approaches to help select the
approach that achieves the regulatory objective while imposing
the lowest compliance costs.
Q.3. President Obama issued Executive Order 13563 to improve
the regulatory process and regulatory review. Specifically, the
Executive order ``must identify and use the best, most
innovative, and least burdensome tools for achieving regulatory
ends'' taking into account benefits and costs, both
quantitative and qualitative.
What are your thoughts about Executive Order 13563 and what
role does the Office of Policy Development and Research play in
helping the Department to comply with the Executive order?
A.3. I believe that Federal rulemaking should always be guided
by clear analysis and consideration of effectiveness and
compliance costs. The Office of Policy Development and Research
(PD&R) is responsible, in cooperation with the HUD program
offices that promulgate the rules, for producing the analyses
required for rules to be cleared by the Office of Information
and Regulatory Affairs in the Office of Management and Budget.
These analyses include evidence that demonstrate how HUD
examined the available means for achieving the regulatory
objective in the most innovative and least burdensome way as
required by Executive Order 13563.