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Administrative Procedure Act Proposed Rules Rulemaking Process

Cooley LLP

President Trump Directs Federal Agencies on How to Repeal ‘Unconstitutional’ Rules

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On April 11, 2025, a new rule went into effect in which the United States government will start to strictly enforce the requirement that foreign nationals register their presence with U.S. Citizenship and Immigration Services...more

Holland & Knight LLP

Clean Air Act Rulemakings Don't Follow the Normal Rules – Just Ask the Supreme Court

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Every law student learns that the Administrative Procedure Act (APA) outlines the default rules for how federal agencies propose and finalize regulations and how courts review them. But for many significant actions under the...more

Cooley LLP

Acting SEC Chair Uyeda presents blueprint for SEC rulemaking processes

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Yesterday, Acting SEC Chair Mark Uyeda delivered remarks to the Investment Company Institute’s 2025 Investment Management Conference. While much of his presentation was specific to investment companies, the theme of his...more

Seward & Kissel LLP

FDIC Withdraws Pending Proposed Rule on Brokered Deposits

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On March 3, 2025, the Federal Deposit Insurance Corporation (“FDIC”) withdrew its pending proposed rule on brokered deposits (the “Proposal”), originally published in the Federal Register on August 23, 2024. The Proposal,...more

Davis Wright Tremaine LLP

New Administration Outlook: A Possible Roadmap to What's Ahead for the CFTC Under New Leadership

On January 20, 2025, the Commodity Futures Trading Commission ("CFTC") unanimously elected Commissioner Caroline D. Pham as acting chairman. The Administration has not yet identified who will be nominated for the position of...more

Morgan Lewis

Executive Order Pauses All Pending Rulemaking Activity for Federal Agencies: Impact on CFPB

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President Donald Trump’s executive order titled Regulatory Freeze Pending Review directs federal agencies to stop all rulemaking activity pending within the agency and to consider all rules already published as paused for 60...more

Bradley Arant Boult Cummings LLP

Bradley Comment Letter Highlights Questions Regarding the CFPB’s Statutory Authority to Issue Contemplated Mortgage Servicing...

On July 10, 2024, the Consumer Financial Protection Bureau (CFPB) released a proposal to amend the existing mortgage servicing rules in Regulation X. The substance of the proposal has attracted a lot of attention and...more

Davis Wright Tremaine LLP

Is the FDIC's Proposed Rulemaking on Brokered Deposit Restrictions a Solution in Search of a Problem?

One of the most fundamental activities of an insured depository institution (IDI) is taking and safekeeping customer deposits. However, a recent proposed rulemaking by the Federal Deposit Insurance Corporation (FDIC) poses...more

Holtzman Vogel Baran Torchinsky & Josefiak

In Compliance: Holtzman Vogel's July 2024 Round-Up

Holtzman Vogel attorneys wrote on the Supreme Court's landmark Loper Bright decision earlier this month. The Court overruled its 1984 decision in Chevron v. NRDC that introduced the so-called "Chevron deference" principle...more

Maynard Nexsen

FAR Council Publishes its Semiannual Regulatory Agenda

Maynard Nexsen on

On February 9, 2024, the Federal Acquisition Regulatory Council ("FAR Council") – Department of Defense, General Services Administration, and National Aeronautics and Space Administration – published its Semiannual Regulatory...more

Ballard Spahr LLP

AFSA asks House Appropriations Committee to block proposed FTC Motor Vehicle Dealers Trade Regulation Rule

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On June 21, 2023, the American Financial Services Association (“AFSA”) asked the House Appropriations Committee to include language in the Financial Services and General Government appropriations bill that would prevent the...more

White & Case LLP

Interagency Statement on Role of Supervisory Guidance to Become a Rule

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In response to a call for a rulemaking by two leading bank industry trade associations, the federal banking agencies have issued a proposed rule to codify an earlier interagency statement that their supervisory...more

Polsinelli

CY 2020 OPPS Proposed Rule – HHS Seeks Comments on 340B Payment Reductions and Remedies

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This past week, CMS confirmed it will continue the 2018 and 2019 underpayment policy for certain 340B covered entities unless the D.C. Court of Appeals upholds the lower court’s ruling that it is unlawful. In that case, CMS...more

Holland & Knight LLP

STB Revisits its Ban on Ex Parte Communications in Rulemaking Proceedings

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The Surface Transportation Board has taken a significant step in modernizing its regulatory processes by proposing to eliminate its long-standing prohibition on ex parte communications in its informal rulemaking proceedings....more

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