On his first day in office, President Joe Biden issued an executive memorandum, “Modernizing Regulatory Review,” instructing the director of the Office of Management and Budget (OMB) to “propose procedures that take into account the distributional consequences of regulations.” The memo has already been criticized by Mick Mulvaney, the first OMB director under President Donald J. Trump.
Any controversy over whether agencies should analyze distributional impacts ignores two things.