WASHINGTON — Suggestions from the credit union industry on regulations in need of review or reform did not make the cut in response to a request from the Small Business Administration's Office of Advocacy.

After reviewing some 80 nominations of regulations in need of review or reform, the Office of Advocacy has released the top 10 submissions. The office's Regulatory Review and Reform Initiative, or r3, was designed to identify and address existing federal regulations that should be revised because they are ineffective, duplicative or out of date, according to the agency.

Both CUNA and NAFCU suggested several areas in need of reform and review including Regulation D, the Bank Secrecy Act and Anti-Money Laundering Law, and the Real Estate Settlement Procedures Act, among others.

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SBA said the top ten submissions were:

Update air monitoring rules for dry cleaners to reflect current technology (Environmental Protection Agency).

Flexibility for community drinking water systems (EPA).

Simplify the rules for recycling solid wastes (EPA).

Clearly define "oil" in oil spill rules (EPA).

Update flight rules for the Washington, D.C., regional area (Federal Aviation Administration).

Eliminate duplicative fi-nancial requirements for architect engineering services firms in government contracting (Federal Acquisition Regulation Council).

Simplify the home office deduction (IRS).

Update rules on the use of explosives in mines to reflect modern industry standards (Mine Safety and Health Administration).

Review the medical-laboratory worker rule (Occupational Safety and Health Administration).

Reverse auction techniques for online procurement ( Office of Federal Procurement Policy).

The top ten rules were chosen based on several factors, including whether the rule could reasonably be tailored to accomplish its intended objectives while reducing the impact on small businesses or small communities, the SBA said. The agency also looked at whether the rule has ever been reviewed for its impact on small entities and whether the rule imposes duplicative requirements.

"These rules, nominated by small business, need to be reviewed by federal agencies to determine if they are outdated, ineffective, duplicative or overly complex," said Thomas Sullivan, chief counsel for advocacy at the SBA. "Streamlining and updating these regulations could help to ease the disproportionate federal regulatory burden placed on small business."

The rules have been transmitted to the appropriate federal agencies for their action, according to SBA's Office of Advocacy. The SBA has posted the rules to its Web site (www.sba.gov/advo/r3) and an update on the status of agency reviews will be published twice a year.

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