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Administrative Procedure Act Rulemaking Process Regulatory Reform

Sheppard Mullin Richter & Hampton LLP

CFPB to Revoke Medical Debt Collection Advisory Opinion

On April 11, the CFPB filed a joint motion in the U.S. District Court for the District of Columbia indicating its intent to revoke an advisory opinion on medical debt collection. The Bureau requested a stay of litigation...more

Mintz - Health Care Viewpoints

Deregulatory Push by Trump Administration Picks Up Speed

It’s no secret that President Trump, his Cabinet, and other executive branch leaders are prioritizing deregulatory activities over more historical federal governance approaches. Indeed, one of President Trump’s earliest...more

Pillsbury - Gravel2Gavel Construction & Real...

Presidential Memo Directs Immediate Repeal of Regulations Without Public Notice and Comment

Continuing with the Trump administration’s deregulatory agenda, the White House issued a Presidential Memorandum on April 9 titled Directing the Appeal of Unlawful Regulations. It instructs executive agencies to repeal...more

Brownstein Hyatt Farber Schreck

White House Advances Deregulatory Agenda

On April 9, 2025, President Trump issued a memorandum directing federal agencies to begin repealing regulations deemed “clearly unlawful,” particularly those invalidated or undermined by recent Supreme Court rulings such as...more

Katten Muchin Rosenman LLP

The CFPB Shuts Down Controversial "Regulation Through Guidance" Practices

The acting head of the Consumer Financial Protection Bureau (CFPB) continues to winnow out regulatory tools used by agency staff under the prior administration. Just a month after revoking certain interpretative rules and...more

Cozen O'Connor

And Here We Go – Reformation of the FAR Directed by Executive Order

Cozen O'Connor on

As we have hinted at (and even mentioned) in some of our more recent client alerts, the proverbial other shoe has now dropped. In the April 15, 2025, Executive Order entitled "Restoring Common Sense to Federal Procurement"...more

Blank Rome LLP

Rescission of Regulations Without Notice and Comment? What’s Next for Regulated Industries in the Deregulation Climate

Blank Rome LLP on

We previously wrote about President Trump’s February Executive Order identifying deregulation as a top administration priority (here and here). That Executive Order, 14219 (the “Deregulation EO”), directed all executive...more

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

CFPB to Conduct Comprehensive Review of Previously Issued Guidance Documents

Holland & Knight LLP on

The CFPB will begin the process of discontinuing regulatory "guidance" and instead enforce the Administrative Procedure Act's rulemaking process. In a pair of internal memos circulated to all divisions and offices within the...more

Wiley Rein LLP

Trump Directs Agencies to Quickly Repeal Unlawful Regulations, Without Notice-and-Comment

Wiley Rein LLP on

On April 9, 2025, President Trump signed a Presidential Memorandum (Memorandum) entitled Directing the Repeal of Unlawful Regulations. The Memorandum – part of a broader “Department of Government Efficiency” Deregulatory...more

Stoel Rives - Environmental Law Blog

Fed up with Federal Rules?  OMB Implements a Federal Deregulation Idea Solicitation Process on White House Urging.

On April 9, 2025, the White House published a new Memorandumentitled “Directing The Repeal of Unlawful Regulations,” aimed at identifying and reviewing unlawful or potentially unlawful regulations for potential repeal. The...more

Cooley LLP

Commissioner Crenshaw decries SEC action pulling the plug on defense of climate disclosure rules

Cooley LLP on

As reported in this PubCo post, the SEC announced yesterday that it was ending its “defense of the rules requiring disclosure of climate-related risks and greenhouse gas emissions”—the climate disclosure rules. In response to...more

Jones Day

The CFTC is Off to a Fast Start Under Acting Chairman Pham

Jones Day on

In a break from the typical acting agency chairman, Acting Commodity Futures Trading Commission ("CFTC") Chairman Caroline Pham has taken several significant actions, signaled several more, and set the agency on a path to...more

Nelson Mullins Riley & Scarborough LLP

No Soup for You - SEC Commissioners Revoke Authority of Director of Enforcement to Launch Investigations

In a famous Seinfeld episode, a master soup maker had strict rules for ordering his delicious confections.  A violation of his rules, resulted in “No soup for you!”...more

Cooley LLP

Acting SEC Chair Uyeda presents blueprint for SEC rulemaking processes

Cooley LLP on

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

Holland & Knight LLP

EPA Announces Deregulatory Initiative to "Power the Great American Comeback"

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U.S. Environmental Protection Agency (EPA) Administrator Lee Zeldin announced on March 12, 2025, that EPA will undertake 31 distinct actions in an effort to advance President Donald Trump's Day One executive orders (EOs) to...more

Arnall Golden Gregory LLP

U.S. Department of Health and Human Services Rescinds "Richardson Waiver" Policy

On March 3, 2025, the U.S. Department of Health and Human Services (“HHS”) announced a new policy to reverse course on certain public notice and comment procedures. This marks a significant change to a process in place for...more

Proskauer - Health Care Law Brief

HHS Scraps Richardson Waiver, Clearing Way for Faster Rulemaking

On March 3, 2025, the United States Department of Health and Human Services (“HHS”) issued a policy statement rescinding the Richardson Waiver, a policy in place since 1971 that required notice-and-comment rulemaking for...more

Foley Hoag LLP

Department of Health and Human Services Seeks to Revise Rulemaking Policies

Foley Hoag LLP on

On Friday, February 28, 2025, the Department of Health and Human Services (HHS) issued a policy statement announcing changes to rulemaking processes for agencies within HHS. According to the statement, HHS is rescinding a...more

Epstein Becker & Green

HHS Reverses Its Longstanding Policy and Limits Public Participation in Rulemaking

On March 3, 2025, the Secretary of Health and Human Services published a policy statement in the Federal Register that reverses a policy adopted over 50 years ago that was intended to expand public participation in the...more

Latham & Watkins LLP

HHS Issues Policy Statement to Expand Use of Rulemaking Without Notice and Comment

Latham & Watkins LLP on

The policy statement aims to bring more rapid action on personnel and management decisions and empowers HHS and each of its offices and subagencies to promulgate or rescind certain rules without a period of notice and comment...more

Seward & Kissel LLP

FDIC Withdraws Pending Proposed Rule on Brokered Deposits

Seward & Kissel LLP on

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

Orrick, Herrington & Sutcliffe LLP

CFPB Pause: Where From Here?

Visit our resource center, CFPB Pause: Where From Here?, to stay on top of the latest and what it may mean for the federal and state regulatory and enforcement landscape. On February 8, the Consumer Financial Protection...more

Perkins Coie

CEQ Regulations Replaced by Guidance for a Year of Living in Uncertainty

Perkins Coie on

On February 19, 2025, the Council on Environmental Quality (CEQ) submitted to the Federal Register an interim final rule rescinding its National Environmental Policy Act (NEPA) regulations, which have been the foundation for...more

Snell & Wilmer

Trump Issues Executive Order for Deregulation

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President Donald J. Trump, in December 2017, discussed the number of regulations eliminated in his first Administration’s “far-reaching regulatory reform,” known as the “two-for-one rule.” Eleven months earlier, Trump had...more

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