What Is the Congressional Review Act for a DOL 401(k) Rule?

The Congressional Review Act (CRA) gives Congress a post-promulgation review mechanism. It is not a second notice-and-comment period, and "major rule" does not mean "the only kind of rule Congress can disapprove."

That distinction matters because three separate ideas are often collapsed:

• CRA coverage
• major-rule classification
• congressional disapproval.

A covered non-major action still has to be submitted.^[6][7]

Major status adds extra procedural requirements.^[6]

Congressional disapproval is a legislative act requiring both chambers and presidential approval—or a successful veto override.^[1][2]

Those are different stages.

What Does DOL Have to Submit?

Before a covered rule can take effect, the agency must submit a report to:

• House of Representatives
• Senate
• Comptroller General.^[1][6]

The report includes:

• copy of the rule
• concise general statement
• whether the rule is major
• proposed effective date.^[1]

DOL also provides GAO with rulemaking materials involving matters such as:

• cost-benefit analysis
• Regulatory Flexibility Act
• Unfunded Mandates Reform Act
• Paperwork Reduction Act
• Administrative Procedure Act
• relevant Executive Orders.^[1][6]

That is why a Government Accountability Office report often looks like a compact audit of the preamble analyses covered in INV-199 through INV-203.

Both Major and Non-Major Rules Are Submitted

This is the first misconception to eliminate.

The submission obligation is not limited to major rules.^[6]

GAO says agencies must submit:

• major rules
• non-major rules
• interim final rules.^[7]

Major status changes what happens next.

It does not determine whether the submission requirement exists.

A database field that says:

CRA = no because non-major

is wrong.

The better structure is:

CRA covered?

then:

major or non-major?

Proposed Rules Are Different

GAO expressly tells agencies:

do not submit proposed rules.^[7]

That fits the statutory design.

CRA review concerns rules the agency has promulgated.

An NPRM is still asking for public comment and can change materially before final action.

So the sequence for an ordinary EBSA rule can look like:

NPRM → comments → final rule → CRA submission.

The proposal belongs to the APA rulemaking process.

The final action triggers congressional review.

What Is a "Major Rule"?

The definition appears in:

5 U.S.C. 804(2).^[3]

OIRA's Administrator determines whether a rule is major under any of three criteria.^[3][6]

A rule can qualify if it is likely to produce:

1. annual economic effect of $100 million or more
2. major increase in costs or prices
3. significant adverse effects on competition, employment, investment, productivity, innovation or U.S. competitive ability.^[3]

That is broader than a single dollar test.

The $100 million criterion is simply the easiest to recognize.

CRA's $100 Million Is Not UMRA's $100 Million

INV-202 matters here.

UMRA uses:

$100 million in 1995 dollars, adjusted annually.

CRA says:

$100,000,000 or more

for the annual-effect criterion.^[3]

It does not add the 1995-dollar inflation-adjustment language.

That means a 2026 analyst should not import the approximately $193 million UMRA threshold into CRA.

The statutes use similar-looking numbers for different purposes.

That is exactly the kind of cross-statute error that creates bad regulatory summaries.

Major Status and Economically Significant Are Separate Labels

Executive Order 12866 has its own significance framework.

CRA has a statutory major-rule definition.

OIRA participates in both systems.

That can make the terms look interchangeable.

They are not legally identical.

The correct statement is:

OIRA determined the rule was major under CRA.

Not:

"The rule was major because every economically significant action is automatically the same category."

Check the actual CRA submission or federal rule record.

What Does GAO Do After a Major Classification?

GAO prepares a report to Congress.^[6]

The report assesses whether the agency's submission shows compliance with specified procedural requirements.

GAO says plainly that it does not:

• analyze
• comment on

the substance or quality of the rulemaking when preparing the CRA major-rule report.^[6]

That distinction matters.

A oversight report is not:

"GAO approves this regulation."

It is closer to:

"Here is what the agency did under the required regulatory procedures."

How Fast Does GAO Report?

For a rule classified as major, GAO's report is due no later than:

15 calendar days

after the later relevant submission/publication date described in CRA.^[6]

That makes GAO's major-rule page a useful compact source for:

• received date
• Federal Register date
• effective date
• RIN
• cost-benefit analysis
• RFA
• UMRA
• PRA
• Executive Order treatment.

It is a high-value cross-check.

It should not replace the actual rule.

Major Status Generally Brings a 60-Day Delay

A rule classified as major generally cannot take effect until at least:

60 days

after the later of:

• Federal Register publication
• congressional receipt.^[1][8]

That second date causes real problems.

A rule can be published on Monday.

Congress may not record receipt until days later.

The clock follows the later event.

A compliance calendar that counts only from Federal Register publication can therefore be wrong.

Congressional Receipt Is Not a Technicality

GAO's April 2026 government-wide review makes this unusually concrete.^[8]

GAO reviewed:

462 major rules

issued from January 21, 2021 through January 20, 2025.^[8]

It found:

119

had stated effective dates inconsistent with the CRA's 60-day waiting period and did not claim one of the statutory exceptions.^[8]

That is roughly:

26 percent.

This is not a rare theoretical timing problem.

Why Were So Many Dates Off?

GAO found that congressional receipt was a major source of the mismatch.^[8]

The House and Senate still require paper copies for CRA submissions, while GAO accepts submissions electronically.^[8]

Agencies can know:

• publication date

before they know exactly when:

• House received it
• Senate received it.

GAO recommended greater clarity around what counts as congressional receipt.^[8]

For that category, the safest timeline records all three dates:

• publication
• House receipt
• Senate receipt.

Then use the latest relevant date.

There Are Exceptions to the Major-Rule Delay

The 60-day rule is not absolute.

CRA allows an agency to set a different effective date when it properly finds good cause that notice and public procedure are:

• impracticable
• unnecessary
• contrary to public interest

and states the finding and reasons in the rule.^[5][8]

CRA also has a specialized exception for certain hunting, fishing and camping regulatory programs.^[5]

The second category will rarely matter to a 401(k) article.

The good-cause provision can.

Do not assume:

major status = always exactly 60 days.

Check for the statutory exception.

The 2007 QDIA Rule Shows the Timing Problem Inside 401(k) Law

DOL's final rule on qualified default investment alternatives was a:

major-rule classification.^[9]

It created the regulatory framework under which qualifying default investments can provide ERISA fiduciary liability relief when conditions are satisfied.^[9]

The Comptroller General received the rule October 29, 2007.

It had been published October 24.^[9]

GAO concluded that the rule did not provide the required 60-day period before its announced effective date.^[9]

That is a direct 401(k) example.

The CRA issue did not concern whether QDIAs were good policy.

It concerned timing.

The QDIA Example Also Shows GAO's Role

the oversight report still reviewed:

• cost-benefit analysis
• paperwork burden
• statutory authority
• Executive Order treatment.^[9]

It did not rewrite the QDIA rule.

It did not decide whether a plan fiduciary could rely on the safe harbor.

The report identified a procedural compliance issue.

For current plan compliance, the operative QDIA regulation still has to be read separately.

Electronic Disclosure Also Received Major Status

DOL's 2020 electronic-disclosure safe harbor received major-rule status.^[10]

It allowed qualifying pension plan administrators to furnish specified disclosures electronically under a new safe harbor.^[10]

GAO report recorded:

• publication May 27, 2020
• effective date July 27, 2020.^[10]

That is another reminder that retirement administration rules can qualify as major even when they are not primarily about investment selection.

"Major" is an economic and market-effect classification.

Not a subject-matter label.

The 2024 Retirement Security Rule Also Received Major Status

DOL's 2024 Retirement Security Rule was submitted to GAO with major-rule status.^[12]

The Comptroller General received it:

April 25, 2024.^[12]

It was published the same day.

Its stated effective date was:

September 23, 2024.^[12]

The generous gap made the CRA delay straightforward.

Later courts stayed and vacated the rule for other reasons.

That history separates two questions:

Was congressional-review procedure followed?

from:

Was the rule otherwise lawful?

CRA status is not legal immunity.

What Can Congress Do After Submission?

Members can introduce a joint resolution of disapproval during the statutory window.^[2][6]

The resolution uses a prescribed form.

If enacted, it makes the rule:

of no force or effect.^[1][2]

The Senate receives expedited procedures during the applicable CRA review period.^[2]

This can make CRA materially different from ordinary legislation.

But "expedited" does not mean:

automatic.

The resolution still has to become law.

A Joint Resolution Needs More Than One Chamber

A House vote alone does not invalidate a DOL rule.

A Senate vote alone does not invalidate it either.

For a CRA resolution of disapproval to become law, the resolution must:

• pass House
• pass Senate
• be signed by President

or survive a presidential veto through the constitutional override process.

That last step is not a footnote.

The 2022 DOL investment rule proves it.

The 2022 Prudence and Loyalty Rule Became a CRA Test Case

DOL finalized:

Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights

in December 2022.^[11]

GAO recorded it as a rule with:

major status.^[11]

The rule addressed ERISA fiduciary investment duties, including:

• investment selection
• QDIAs
• shareholder rights
• proxy voting.^[11]

Congress later targeted the rule through:

H.J.Res.30.^[13]

That resolution passed both chambers.

Did H.J.Res.30 Repeal the DOL Rule?

No.

The President vetoed the resolution.^[14]

The House later failed to achieve the two-thirds vote needed to override the veto.

Because the disapproval resolution did not become law, the CRA process did not nullify the DOL rule.

That distinction is important in historical articles.

Wrong:

"Congress overturned the 2022 rule."

Correct:

"Congress passed a CRA disapproval resolution, but the presidential veto prevented it from becoming law."

Why Is the Veto Example So Useful?

Because it shows CRA is legislative review, not a one-house veto.

Congress can act quickly under CRA.

But Article I's ordinary lawmaking structure still matters.

A resolution sent to the President can be:

• signed
• vetoed.

A veto can be:

• overridden
• sustained.

The rule's legal status depends on where that process ends.

DOL Has Had Retirement Rules Actually Disapproved

In 2017, Congress used the CRA to disapprove DOL retirement-savings rules involving State programs for private-sector workers.^[15][16]

One rule addressed savings arrangements established by:

States for non-governmental employees.^[15]

Another addressed arrangements established by qualifying:

State political subdivisions.^[16]

The joint resolutions became:

• Public Law 115-35
• Public Law 115-24.^[15][16]

Those rules did not merely face resolutions.

The disapprovals were enacted.

What Happens When Disapproval Becomes Law?

Section 801 provides that the disapproved rule shall not take effect or continue in effect.^[1]

If it already took effect and is later disapproved, CRA treats it as though it had never taken effect.^[1][17]

That is a much stronger consequence than:

• agency delay
• litigation stay
• non-enforcement policy.

An enacted CRA disapproval changes the rule's legal status by statute.

A compliance system should treat:

resolution enacted

as a fundamentally different event from:

resolution introduced.

The "Substantially the Same" Restriction Reaches Forward

The Act also restricts what the agency can do after disapproval.^[1][6]

DOL may not simply reissue the disapproved rule in:

substantially the same form

or issue a new rule that is substantially the same unless later legislation specifically authorizes it.^[1]

That gives CRA disapproval a longer tail than ordinary rescission.

It can constrain the next rulemaking.

But the phrase creates uncertainty.

What Does "Substantially the Same" Mean?

CRA does not define it.^[17]

CRS has identified several plausible comparison methods, including:

• text
• scope
• standards
• policy substance
• cost-benefit structure.^[17]

There is no universal formula.

That means an article should not say:

"DOL can never regulate this subject again."

The safer statement is:

DOL cannot reissue the disapproved rule or a substantially-the-same rule without later statutory authorization; the boundary of substantial sameness is not defined by the Act.

CRA Coverage Is Broader Than Documents Called "Final Rule"

CRA adopts the APA's broad definition of:

rule

with exclusions.^[3][6]

That means some:

• guidance
• memoranda
• policy statements

can require CRA review.

The label on the PDF is not dispositive.

The first question is whether the agency action fits the statutory rule definition.

Then check the statutory exclusions.

What Are the Main CRA Exclusions?

The Act excludes three important categories.^[3][6]

Particular applicability

Actions focused on specifically named or identified persons or entities can fall outside the Act's rule definition.

Agency management or personnel

Internal management and personnel rules are excluded.

Internal organization, procedure or practice

These can be excluded when they do not substantially affect rights or obligations of non-agency parties.^[3][6]

The exclusions matter because:

APA rule

does not always equal:

CRA-covered rule.

A DOL Memorandum Shows How the Classification Works

In 2023, GAO considered a joint OMB-DOL memorandum on federal contract labor practices.^[19]

GAO concluded that the memorandum met the APA definition of a rule because it:

• had general applicability
• operated prospectively
• prescribed policy and procedure.^[19]

But GAO also concluded that it fell within CRA's exclusion for:

agency management or personnel.^[19]

So it did not have to be submitted.

The analysis was two-step:

1. APA rule?
2. Does a CRA exclusion apply?

That is more reliable than judging by document title.

What Is the CRA Lookback?

A late-session rule can receive renewed congressional-review periods in the next session.^[18]

The mechanism applies when a rule is submitted too close to sine die adjournment for Congress to receive the full review period contemplated by CRA.

For lookback rules, CRA treats the rule as constructively received/published on the:

15th legislative or session day

of the succeeding session for calculating specified review periods.^[18]

That can make a prior Administration's late rules vulnerable after:

• new Congress
• new President.

The calendar can therefore matter as much as the rule's content.

Why the Lookback Is Especially Important During Presidential Transitions

An Administration cannot reliably avoid CRA review by sending rules to Congress in the final weeks of its term.

The lookback mechanism can reopen the expedited review periods for qualifying late rules.^[18]

This explains why CRA use often spikes after a presidential transition.

But exact lookback calculations depend on:

• House legislative days
• Senate session days
• sine die adjournment.

CRS estimates are useful.

The House and Senate Parliamentarians are the authoritative procedural arbiters.^[18]

CRA Review vs. OIRA Review

INV-197 covers OIRA.

OIRA review:

Executive Branch review before publication of significant drafts.

CRA review:

Congressional review after promulgation of covered rules.

OIRA also determines major-rule status for CRA purposes.^[3][6]

That does not merge the two processes.

A draft can clear OIRA.

Then DOL publishes the final rule.

Then CRA submission and congressional review begin.

CRA vs. UMRA

INV-202 covers UMRA.

The distinction is particularly important because both contain:

$100 million

language.

CRA

Fixed $100 million annual-effect criterion for major-rule classification.^[3]

UMRA

$100 million in 1995 dollars, adjusted annually, for specified mandate analysis.

Same-looking base number.

Different statute.

Different calculation.

Different consequence.

Do not copy one threshold into the other.

CRA vs. the Federal Register Effective Date

The Federal Register tells the public the agency's stated effective date.

CRA can constrain when a major-status rule is legally permitted to take effect.^[1][8]

That is why a regulatory tracker needs:

• published effective date
• CRA major/non-major classification
• House receipt
• Senate receipt
• exception claimed.

One date field is not enough once major status applies.

Does GAO Fix the Effective Date?

No.

GAO reports the procedural issue.

The 2007 QDIA report said DOL did not provide the required delay.^[9]

GAO did not itself rewrite:

• Federal Register text
• CFR
• effective-date clause.

That illustrates the limited role.

The compliance consequence of a CRA timing defect can involve difficult statutory questions, particularly because 5 U.S.C. 805 contains a broad judicial-review bar.^[4]

Do not treat a GAO observation as an amended regulation.

What Does Section 805 Say About Judicial Review?

The statutory text says no:

• determination
• finding
• action
• omission

under the CRA is subject to judicial review.^[4]

Courts have litigated the scope of that language in different contexts.

For a practical 401(k) article, the safe point is narrower:

The CRA is not designed as an ordinary private lawsuit mechanism for plan sponsors to challenge a rule.

Current rule status should be confirmed through:

• statute
• Federal Register
• CFR
• congressional action
• controlling court decisions.

Worked Example: UMRA Threshold Is Used for CRA

Analyst reads INV-202 and remembers:

approximately $193 million in 2026.

A DOL rule has annual economic effects of:

$150 million.

Memo says:

"Not a CRA major rule because it is under $193 million."

Wrong statute.

The CRA's first major-rule criterion remains:

$100 million annual effect.^[3]

The UMRA inflation adjustment does not transfer.

Worked Example: Non-Major Means No Congressional Submission

Service provider sees:

Type: Non-Major

in the federal rules database.

Internal note says:

"Congress was not notified."

Wrong.

Non-major covered rules still go to:

• House
• Senate
• GAO.^[6]

The difference is that GAO does not have to prepare the same major-rule procedural report.^[6]

Submission and major-rule reporting are separate requirements.

Worked Example: 60 Days Is Counted From Publication Only

A rule with major status is published:

May 1.

House receives it:

May 5.

Senate receives it:

May 8.

Analyst counts 60 days from May 1.

That can produce an early date.

The CRA uses the later congressional-receipt/publication framework.^[1][8]

The receipt record matters.

This is exactly the timing problem GAO revisited in 2026.^[8]

Worked Example: H.J.Res.30 Is Described as a Repeal

Article says:

"Congress repealed DOL's 2022 Prudence and Loyalty rule in March 2023."

The resolution passed both chambers.

But it was vetoed.^[13][14]

The override failed.

So the disapproval resolution never became law.

That single omitted fact reverses the legal conclusion.

Worked Example: GAO Report Becomes an Approval Stamp

Committee memo says:

"GAO reviewed and approved the Retirement Security Rule."

No.

The GAO report documented the major-rule classification and assessed listed procedural steps.^[12]

GAO's CRA FAQ says its report does not analyze or comment on the substance or quality of rulemaking.^[6]

A procedural report cannot be cited as:

substantive endorsement.

Worked Example: End-of-Year Rule Is Assumed Safe

DOL issues and submits a rule late in a congressional session.

Researcher says:

"The 60-day CRA window expired when Congress adjourned."

Potentially wrong.

The lookback provision can restart the relevant review periods in the next session.^[18]

Late timing can increase political exposure rather than eliminate it.

Check the actual legislative/session-day calculation.

CRA Validation Checklist

Before citing CRA status for a DOL retirement rule, verify:

Covered rule

Does the action fit the CRA rule definition?

Exclusion

Does one of the Section 804 exclusions apply?

Stage

Is this a promulgated rule rather than an NPRM?

Submission

Was it sent to:

• House
• Senate
• Comptroller General?

Major status

What did OIRA determine?

Threshold

Do not confuse CRA with UMRA.

Dates

Record:

• publication
• House receipt
• Senate receipt
• stated effective date.

Exception

Did DOL invoke good cause or another CRA exception?

GAO

Is there a major-rule report?

Congress

Was a disapproval resolution:

• introduced
• passed one chamber
• passed both
• signed
• vetoed
• overridden?

That sequence keeps congressional review status tied to actual legal events.

A Practical Source Matrix

CRA research is a timeline problem.

Missing one status event can reverse the answer.

Fast Answers

What is the Congressional Review Act?

A federal statute requiring covered agency rules to be submitted to Congress and GAO and giving Congress expedited procedures to disapprove them.

Do only major rules get submitted?

No.

Do proposed rules get submitted?

GAO says agencies should not submit proposed rules.^[7]

Who decides whether a rule is major?

The OIRA Administrator under the statutory criteria.^[3][6]

What is the CRA dollar threshold?

One major-rule criterion is an annual economic effect of $100 million or more.^[3]

Is that adjusted for inflation?

Not under the text of CRA's $100 million criterion.

Is it the same as UMRA's threshold?

No.

What extra requirements apply to a major rule?

Most notably, GAO reporting and generally a 60-day delayed effective date.^[1][6]

When does the 60-day clock run from?

The later relevant date involving Federal Register publication and congressional receipt.^[1][8]

Did GAO recently find timing problems?

Yes. In 2026 oversight reported 119 of 462 major rules in its 2021-2025 review period had stated effective dates inconsistent with the required delay without a claimed statutory exception.^[8]

Was the 2007 QDIA rule major?

Yes.^[9]

Did GAO identify a CRA delay problem with it?

Yes.^[9]

Was the 2022 Prudence and Loyalty rule major?

Yes.^[11]

Did Congress successfully disapprove it?

No. H.J.Res.30 passed both chambers but was vetoed, and the veto was not overridden.^[13][14]

Has Congress ever successfully disapproved a DOL retirement-related rule?

Yes. Two DOL rules concerning State and political-subdivision savings arrangements were disapproved in 2017.^[15][16]

What happens after successful disapproval?

The rule has no force or effect, and CRA restricts reissuance of the same or a substantially-the-same rule absent later statutory authorization.^[1]

Does CRA define substantially the same?

No.^[17]

What is the safest one-sentence rule?

Use CRA records to determine whether Congress received, reviewed or disapproved a DOL rule; use the current CFR and operative legal authorities to determine what a 401(k) plan must do today.

Sources & References

1. U.S. House of Representatives — Office of the Law Revision Counsel: 5 U.S.C. §801 — Congressional Review — https://uscode.house.gov/view.xhtml?req=(title:5%20section:801%20edition:prelim)
2. U.S. House of Representatives — Office of the Law Revision Counsel: 5 U.S.C. §802 — Congressional Disapproval Procedure — https://uscode.house.gov/view.xhtml?req=(title:5%20section:802%20edition:prelim)
3. U.S. House of Representatives — Office of the Law Revision Counsel: 5 U.S.C. §804 — Definitions — https://uscode.house.gov/view.xhtml?req=(title:5%20section:804%20edition:prelim)
4. U.S. House of Representatives — Office of the Law Revision Counsel: 5 U.S.C. §805 — Judicial Review — https://uscode.house.gov/view.xhtml?req=(title:5%20section:805%20edition:prelim)
5. U.S. House of Representatives — Office of the Law Revision Counsel: 5 U.S.C. §808 — Effective Date of Certain Rules — https://uscode.house.gov/view.xhtml?req=(title:5%20section:808%20edition:prelim)
6. U.S. Government Accountability Office: FAQs on the Congressional Review Act — https://www.gao.gov/legal/congressional-review-act/faqs-on-the-congressional-review-act
7. U.S. Government Accountability Office: Submitting a Rule to GAO — https://www.gao.gov/legal/congressional-review-act/submitting-a-rule-to-gao
8. U.S. Government Accountability Office: Congressional Review Act — Agencies and Congress Could Improve Implementation of 60-Day Delay for Major Rules, GAO-26-107825, April 16, 2026 — https://www.gao.gov/products/gao-26-107825
9. U.S. Government Accountability Office: Default Investment Alternatives Under Participant Directed Individual Account Plans — Major Rule Report, GAO-08-256R — https://www.gao.gov/products/gao-08-256r
10. U.S. Government Accountability Office: Default Electronic Disclosure by Employee Pension Benefit Plans Under ERISA — Major Rule Report, B-332232 — https://www.gao.gov/products/b-332232
11. U.S. Government Accountability Office: Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights — Major Rule Report, B-334848 — https://www.gao.gov/products/b-334848
12. U.S. Government Accountability Office: Retirement Security Rule — Definition of an Investment Advice Fiduciary — Major Rule Report, B-336282 — https://www.gao.gov/products/b-336282
13. U.S. Government Publishing Office: H.J.Res.30 — Enrolled Joint Resolution Concerning Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights — https://www.govinfo.gov/app/details/BILLS-118hjres30enr
14. U.S. Government Publishing Office: House Document 118-18 — Veto Message on H.J.Res.30 — https://www.govinfo.gov/app/details/CDOC-118hdoc18
15. U.S. Government Publishing Office: Public Law 115-35 — Disapproval of DOL Savings Arrangements Established by States for Non-Governmental Employees — https://www.govinfo.gov/content/pkg/STATUTE-131/pdf/STATUTE-131-Pg848.pdf
16. U.S. Government Publishing Office: Public Law 115-24 — Disapproval of DOL Savings Arrangements Established by Qualified State Political Subdivisions for Non-Governmental Employees — https://www.govinfo.gov/content/pkg/PLAW-115publ24/pdf/PLAW-115publ24.pdf
17. Congressional Research Service: The Congressional Review Act — Frequently Asked Questions — https://www.congress.gov/crs_external_products/R/PDF/R43992/R43992.9.pdf
18. Congressional Research Service: The Congressional Review Act — The Lookback Mechanism and Presidential Transitions — https://www.congress.gov/crs_external_products/IF/PDF/IF12708/IF12708.1.pdf
19. U.S. Government Accountability Office: OMB and U.S. Department of Labor — Applicability of CRA to Joint Memorandum Titled Strengthening Support for Federal Contract Labor Practices, B-335142 — https://www.gao.gov/products/b-335142

Educational Disclaimer

ROIStreet publishes educational content about 401(k) plans, ERISA, Department of Labor rulemaking, the Congressional Review Act, GAO major-rule reports, OIRA review and congressional procedure. This article is not legal, fiduciary, tax, investment, legislative, parliamentary, regulatory or plan-administration advice. CRA coverage, submission, major-rule status, effective-date timing, lookback periods and congressional disapproval depend on the exact agency action and procedural record. A GAO report does not itself amend a rule, and introduction or passage of a disapproval resolution does not nullify a rule unless the resolution becomes law. Current plan obligations should be verified against operative statutes, current CFR text, published agency actions, enacted legislation and controlling judicial decisions.

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