In mid-February 2025, President Trump issued three executive actions (the orders) intended to improve the administration of the executive branch and enhance the accountability of Federal agencies. Among other things, the orders require that: (1) heads of Federal agencies prepare to initiate “large-scale” reductions in force (RIFs) and submit agency reorganization plans to the Director of the Office of Management and Budget (OMB); (2) Federal agencies, including independent agencies like the SEC, submit all proposed and final significant regulatory actions to the Office of Information and Regulatory Affairs (OIRA) within the Executive Office of the President for review prior to their publication in the Federal Register; (3) heads of independent agencies establish a White House Liaison position within their respective agencies; (4) agency heads review all regulations subject to their respective agencies’ jurisdiction for consistency with law and Trump administration policy and identify regulations for potential modification or rescission; and (5) agency heads review their respective agencies’ enforcement activity and de-prioritize or terminate enforcement actions based on their consistency with law and Trump administration policy.  The three orders are summarized below.

Implementing the President’s “Department of Government Efficiency” Workforce Optimization Initiative

Issued on February 11, 2025, this order seeks to reform the Federal workforce to maximize its efficiency and productivity through a series of mandates.  Among other things, the order (referring to an earlier executive action mandating a freeze on the hiring of Federal civilian employees and requiring the OMB Director to submit a plan to reduce the size of the Federal government’s workforce) mandates that the OMB Director's workforce reduction plan shall require each agency to hire no more than one employee for every four employees that depart.  In addition, each agency head shall develop a hiring plan to ensure new hires are in the “highest-need areas;” prepare to initiate RIFs, prioritizing the elimination of, among other areas, offices that perform functions not mandated by statute or other law; and submit a report to the OMB Director that identifies any statute that establishes the agency and its subcomponents and discusses whether the agency or its subcomponents should be eliminated or consolidated.

The order is available here and a related fact sheet is available here.  A memorandum issued by the OMB Director on February 26, 2025, which provides further guidance on the agency RIFs and reorganization plans contemplated in the order, is available here.

Ensuring Accountability for All Agencies

Issued on February 18, 2025, this order seeks to improve the accountability of independent Federal agencies through enhanced Presidential oversight. Among other things, the order requires that all Federal agencies, including independent agencies, submit all proposed and final significant regulatory actions to OIRA for review prior to their publication in the Federal Register.  The order also requires the OMB Director to implement various oversight measures with respect to independent agencies and requires independent agency heads to establish a White House Liaison position.  The order also requires that the OMB Director establish “performance standards and management objectives” for independent agency heads and report to the President on their performance.

The order is available here and a related fact sheet is available here.

Ensuring Lawful Governance and Implementing the President’s “Department of Government Efficiency” Deregulatory Initiative

Issued on February 19, 2025, this order seeks to implement a deregulatory initiative within the executive branch and focus resources on “regulations squarely authorized by constitutional Federal statutes.”  Among other things, the order requires that agency heads review all regulations subject to their respective agencies’ jurisdiction for consistency with law and Trump administration policy and identify regulations that fit within one of various enumerated classifications (e.g., regulations that exceed the Federal government’s constitutional authority and regulations that are based on unlawful delegations of legislative power, among others).  The order requires that OIRA consult with agency heads to develop a Unified Regulatory Agenda that seeks to rescind or modify these regulations, as appropriate. The order also requires that agency heads review their respective agencies’ enforcement activity and de-prioritize or terminate enforcement actions based on their consistency with law and Trump administration policy.

The order is available here and a related fact sheet is available here.