Reforming Foreign Defense Sales to Improve Speed and Accountability

4/9/2025

Executive Orders

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Action Summary

Purpose:
- Revitalize the American economy by eliminating federal regulations that stifle competition, entrepreneurship, and innovation.
- Aim to remove rules that predetermine economic winners and losers by excluding new market entrants.
Definitions:
- Agency: As defined in section 3502 of title 44, U.S. Code, excluding the Executive Office of the President.
- Agency head: The highest-ranking official of an agency (e.g., Secretary, Administrator, Chairman, or Director).
Rescinding Anti-Competitive Regulations:
- Review Criteria:
  - Regulations that create or facilitate de facto/de jure monopolies.
  - Barriers to entry for new market participants.
  - Restrictions that limit competition between entities.
  - Licensure or accreditation requirements that unduly limit competition.
  - Unnecessary burdens on agency procurement processes.
  - Any other restraint or distortion harming free market operations.
- Agency Process:
  - Agency heads must review all applicable regulations and submit a list—with recommendations for rescission or modification—within 70 days.
  - For each regulation, they must provide either a proposed modification or justification if the rule remains unchanged despite its anti-competitive effects.
  - Prioritization is required for regulations meeting the “significant regulatory action” criteria under Executive Order 12866.
- Public Input:
  - The Chairman of the FTC will issue a Request for Information (RFI) within 10 days to collect public input, remaining open for 40 days.
  - Feedback received will be forwarded to the relevant agency for further consideration.
- Consolidation and Integration:
  - Within 90 days of receiving agency lists, the Chairman (in consultation with other key officials) will provide a consolidated list to the Director of the Office of Management and Budget (OMB).
  - This list will include recommendations for rescission or modifications of identified anti-competitive regulations, potentially incorporating additional relevant regulations.
  - OMB, through the Administrator of the Office of Information and Regulatory Affairs, will consult with stakeholders to decide on incorporating these recommendations into the Unified Regulatory Agenda.
General Provisions:
- Ensures that the order does not impair statutory agency authority or the functions of the OMB.
- Implementation is subject to applicable law and appropriations.
- No party may enforce any right or benefit based on this order.

Risks & Considerations

The Executive Order aims to eliminate anti-competitive regulations, which could lead to significant changes in the regulatory landscape affecting various sectors, including education and research. This may impact Vanderbilt University’s operations, particularly in areas reliant on federal regulations and funding.
There is a risk that the removal of certain regulations could lead to increased competition in sectors where Vanderbilt University is active, potentially affecting its market position and strategic initiatives.
The focus on reducing barriers to entry and competition may necessitate adjustments in Vanderbilt’s compliance and regulatory strategies, especially if current practices are influenced by existing federal regulations.
Vanderbilt University may need to engage in advocacy or public comment processes to ensure that its interests and those of its stakeholders are considered in the review and modification of regulations.

Impacted Programs

Vanderbilt’s Research Programs could be affected by changes in regulations that currently govern research funding and collaboration. The university may need to adapt to new competitive dynamics in securing federal grants and partnerships.
The Office of Government and Community Relations may play a crucial role in monitoring regulatory changes and advocating for policies that support Vanderbilt’s mission and strategic goals.
Vanderbilt’s Legal and Compliance Teams will need to closely follow the developments of this Executive Order to ensure that the university remains compliant with any new regulatory requirements or changes.

Financial Impact

The potential rescission or modification of regulations could alter the funding landscape for higher education and research institutions, impacting Vanderbilt’s financial planning and resource allocation.
Vanderbilt University might experience shifts in its funding opportunities, particularly if deregulation leads to changes in federal grant priorities or eligibility criteria.
There may be increased opportunities for Vanderbilt to engage in public-private partnerships or collaborations with industry, as deregulation could foster a more competitive and dynamic market environment.

Relevance Score: 4 (The order presents a need for potential major changes or transformations of programs.)

Key Actions

Vanderbilt’s Office of Federal Relations should monitor the review process of federal regulations to identify any changes that may impact the university’s operations, particularly those related to research funding and procurement processes. Engaging with federal agencies to provide input during the public comment period could help shape outcomes favorable to the university.
The Vanderbilt Center for Entrepreneurship should assess the potential impacts of deregulation on innovation and market entry opportunities. By understanding these changes, the center can better support faculty and student entrepreneurs in navigating new market conditions and capitalizing on emerging opportunities.
Vanderbilt’s Legal Affairs Office should evaluate the implications of potential changes to licensure and accreditation requirements. This will ensure that the university remains compliant with federal regulations while maintaining its competitive edge in offering accredited programs.
The Office of Research should prepare for potential shifts in federal funding priorities resulting from deregulation. By aligning research initiatives with new federal priorities, Vanderbilt can enhance its competitiveness in securing grants and contracts.

Opportunities

The executive order presents an opportunity for Vanderbilt’s Innovation Center to expand its role in fostering entrepreneurship and innovation. By leveraging deregulation, the center can support new ventures and collaborations that drive economic growth and technological advancement.
Vanderbilt can capitalize on the focus on reducing anti-competitive barriers by developing partnerships with industry leaders and startups. These collaborations can enhance the university’s research capabilities and provide students with real-world experience in dynamic market environments.
The emphasis on eliminating unnecessary barriers to entry aligns with Vanderbilt’s commitment to diversity and inclusion. The university can develop initiatives that support underrepresented groups in accessing entrepreneurial opportunities and resources.

Relevance Score: 4 (The order presents the potential for major process changes required for Vanderbilt’s programs due to impacts on research funding and market opportunities.)

Average Relevance Score: 4.6

Timeline for Implementation

Within 10 days of April 9, 2025: The Chairman is required to issue a Request for Information (RFI), which will remain open for 40 days.
Within 70 days of April 9, 2025: Agency heads must submit a list of anti-competitive regulations along with recommendations for rescission or modification.
Within 90 days of receiving the agency lists: The Chairman, in consultation with relevant officials, must provide a consolidated list to the Director of the Office of Management and Budget.

Relevance Score: 5

Impacted Government Organizations

Federal Agencies with Rulemaking Authority: This order directs every agency head (excluding components of the Executive Office of the President) to review and address regulations, meaning all such agencies must participate in identifying and modifying anti-competitive regulations.
Federal Trade Commission (FTC): The FTC, through its Chairman, is responsible for issuing the request for information (RFI) and collaborating in the review process under this order.
Department of Justice (DOJ): The Attorney General is involved in the consultation and decision-making process regarding the elimination or modification of anti-competitive regulations.
Office of Management and Budget (OMB): The OMB Director is tasked with receiving and consolidating the list of regulations recommended for rescission or modification and integrating these into the Unified Regulatory Agenda.
Office of Information and Regulatory Affairs (OIRA): Operating under the OMB Director, OIRA is involved in the consultation process to determine the final modifications or rescissions for the regulations in question.
Assistant to the President for Economic Policy: This official participates in the consultation process, providing input on the economic implications of the regulatory changes, reflecting the White House’s strategic economic priorities.

Relevance Score: 5 (This directive applies broadly across all federal agencies with rulemaking authority, impacting a wide spectrum of government organizations.)

Responsible Officials

Agency Heads – Each agency head (e.g., Secretary, Administrator, Chairman, or Director) is responsible for reviewing and reporting on anti-competitive regulations within their rulemaking authority.
Chairman of the Federal Trade Commission (FTC) – Tasked with issuing the request for information (RFI) and consolidating public input regarding the identified regulations.
Attorney General – Required to consult with the FTC Chairman, the Assistant to the President for Economic Policy, and relevant agency heads, and to be involved in the review and consolidation of regulation modifications or rescissions.
Assistant to the President for Economic Policy – Involved in the consultation process with the FTC Chairman, Attorney General, and agency heads to prepare recommendations for the consolidated regulatory review.
Director of the Office of Management and Budget (OMB), through the Administrator of the Office of Information and Regulatory Affairs – Responsible for consulting with other officials to decide whether to incorporate proposed regulatory rescissions or modifications into the Unified Regulatory Agenda.

Relevance Score: 5 (Directives affect high-level officials including Cabinet members and top agency heads, which directly influence national regulatory policy).