On November 19, 2025, Chief Counsel for Advocacy Casey Mulligan testified before the Senate Small Business Committee in a hearing titled, “Trump’s Regulatory Rollback: Saving Americans $907 Billion and Counting.” Below is Chief Counsel Mulligan’s opening statement:
Chair Ernst, Ranking Member Markey, and Members of the Committee: I am honored to discuss with you the small business effects of President Trump’s regulatory agenda. My testimony does not necessarily reflect the views of the Administration or the SBA.
Before beginning, I would like to thank the Committee for supporting my nomination to be Chief Counsel, and I look forward to working with you to support America’s small businesses.
The Biden Administration finalized 12,000 rules that would cost almost $6 trillion. Against that backdrop, President Trump was elected to stop the “ever-expanding morass of complicated Federal regulation….” He directed agencies to identify “regulations that impose undue burdens on small businesses.”
Advocacy is well positioned to help agencies follow that direction. During my nomination hearing, I committed to prioritize meeting small businesses where they are. I have done so in person, together with our Regional Advocates who every day gather small business perspectives nationwide and bring them into policy discussions in Washington, D.C.
For years, small businesses burdened by regulations remained silent, fearing retaliation. Now they tell Advocacy that this administration is the first to listen and understand. One even said Advocacy “quite literally saved Christmas.”
As agencies have been seeking comments on candidates for deregulation, my office has flagged roughly 300 issues for federal agencies, particularly those giving large organizations an artificial advantage over small ones. One example is the Outpatient Prospective Payment System, which pays hospitals more for identical services than it pays independent physicians.
The Trump Administration has already delivered substantial regulatory relief for small businesses. For example, the One Big Beautiful Bill zeroed out the penalty on auto manufacturers that fail to achieve Biden’s impossible fuel-economy standards. With approximately 14 million Schedule C businesses owning vehicles, that change alone positions small entities to save tens of billions of dollars.
Additionally, President Trump and Congress removed 16 regulations in 2025 by way of the Congressional Review Act. More rule changes are on the way.
Among roughly 60 economically significant rules proposed so far, the largest small-business savings likely come from EPA’s plan to halt greenhouse-gas regulation of vehicles. Without that action, vehicle quality would have fallen, and prices risen, costing small businesses about half a trillion dollars.
Another rule flagged by small businesses is the proposed OSHA Heat rule. It would impose sweeping, one-size-fits-all, and often absurd requirements on workplaces where heat is above certain temperature thresholds. During a meeting with Advocacy, an Arizona watermelon farmer explained that the rule would require shade structures even though harvesting occurs at night, when there is no sun to shade.
In contrast, well-designed deregulation increases competition and productivity. President Trump’s first term was a case in point. Prescription drug prices fell for the first time in decades. Deregulation sharply reduced internet access prices. The competition channel cited in the RFA is a reason for both changes.
While regulators are quick to sanction businesses that violate their requirements, they often fail to follow the rules Congress set.
A particularly frequent practice has been to unlawfully certify important rules as not having a significant economic impact on a substantial number of small entities. Such certifications are a pathway to capricious enforcement actions against small entities.
In Orwellian fashion, sixty-five percent of the major rules from the Biden Administration were nonetheless said to lack significant effects on small entities or otherwise not require consideration of effects on them. Small businesses were saddled with at least $100 billion in costs without acknowledgment of their magnitude.
President Trump’s “Restoring Gold Standard Science” EO initiates additional reforms that small entities have long sought decisions that rest on transparent data and reproducible methods.
For example, independent fishermen find the modeling of fisheries by the Biden Administration to be outdated and contrary to the Magnuson-Stevens Act. Among other things, fishermen point to Georges Bank, where closures aimed at protecting groundfish also bar scallop harvests, leaving an estimated $52 million in scallops to die off unharvested annually.
Thank you for the opportunity to testify today. As Chief Counsel for Advocacy, I will continue to listen and to work toward better policy for all small businesses. I would be happy to answer any questions.