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Government Accountability Office Congressional Review Act

ArentFox Schiff

Why the Congressional Review Act May Play a Major Role in Early Weeks of the Trump Administration

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There is significant potential that the Congressional Review Act (CRA) will play a prominent role in the early weeks of the Trump Administration. Below, we will break down what the CRA is, when it applies, and how it may be...more

Pillsbury Winthrop Shaw Pittman LLP

Trump 2.0: White House and Congressional Republicans Poised to Use the Congressional Review Act for Swift Regulatory Rollback

With unified control of Congress and the White House, Republicans are primed to use the CRA to swiftly overturn regulations promulgated in the final months of the Biden Administration. The Congressional Review Act (CRA)...more

Mintz - Health Care Viewpoints

Mintz IRA Update — Opposition to the Use of March-In Rights to Lower Drug Prices

In our previous Mintz IRA Update, we covered the Biden administration’s proposal exploring the use of “march-in rights” granted under the Bayh-Doyle Act (the “Act”) to seize pharmaceutical patents if the administration...more

Akin Gump Strauss Hauer & Feld LLP

The Regulatory Race Is On: The Biden Administration Sprints to Issue Key Health Policies

The upcoming election, and the approaching end of the President’s four-year term, introduce additional dynamics into the agencies’ rulemaking process and even the guidance process. From now through the November election, the...more

King & Spalding

A Brief Overview of the Federal Rulemaking Process in the United States

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Since the enactment of the Inflation Reduction Act of 2022 (the “IRA”) in the United States, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) have issued notices of proposed regulations...more

Venable LLP

The Fall 2023 Unified Agenda - Implications for 2024

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On December 6, the Biden administration released its Fall 2023 Unified Agenda of Regulatory and Deregulatory Actions. A unified agenda is issued in the spring and fall each year; it outlines federal agencies' areas of focus...more

Constangy, Brooks, Smith & Prophete, LLP

NLRB delays effective date of “joint employer” regs until late February

The National Labor Relations Board announced Thursday that it was delaying the effective date of its new joint employer regulations from the original December 26 (end of next month) to February 26, 2024. The Board asserts...more

Fenwick & West LLP

SEC’s Crypto Accounting Bulletin Determined Procedurally Deficient

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On October 31, 2023, the U.S. Government Accountability Office (GAO) published a formal decision concluding that the Securities and Exchange Commission (SEC) failed to follow prescribed Congressional Review Act (CRA)...more

Orrick, Herrington & Sutcliffe LLP

SEC’s SAB 121 should be subject to congressional review, says GAO

On October 31, the GAO opined that the SEC’s Staff Accounting Bulletin 121 (SAB 121) is a rule, and thus the SEC was required to submit it for congressional review. SAB 121 describes how SEC staff would expect entities to...more

Pillsbury Winthrop Shaw Pittman LLP

The Return of the Congressional Review Act

Little used before the Trump administration and with limited time to act, what regulations will the Biden administration target with the CRA? Democrats can use the Congressional Review Act to overturn regulations passed in...more

Beveridge & Diamond PC

Recent and Forthcoming Environmental Rules and Guidance Could Be Reversed Under Congressional Review Act: Three Steps for...

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If Joe Biden is elected President, and the Democrats win control of both the House and Senate, the new Administration could potentially use the Congressional Review Act (“CRA” or “Act”) to reverse recent and still-to-come...more

Ballard Spahr LLP

Five federal regulators issue statement clarifying role of supervisory guidance

Ballard Spahr LLP on

In what seems to be a response to the Government Accountability Office’s (“GAO”) determination that the Consumer Financial Protection Bureau’s indirect auto finance bulletin (the “Bulletin”) was a rule subject to the...more

Goodwin

Senate Takes Steps to Repeal CFPB Indirect Auto Lending Guidance

Goodwin on

On April 17, 2018, U.S. Senate Majority Leader Mitch McConnell (R-KY) announced that the Senate would seek to repeal the Consumer Financial Protection Bureau’s (CFPB’s) indirect auto lending guidance. The Senate passed a...more

Baker Donelson

Indirect Auto Lending: GAO Opinion Sets Wheels in Motion for Regulatory Clarity

Baker Donelson on

A recent finding by the U.S. Government Accountability Office (GAO) could have a significant impact on the indirect auto lending industry. Last month, the GAO issued an opinion declaring that a Consumer Financial Protection...more

Bradley Arant Boult Cummings LLP

Five Years Later: Five Takeaways From the Bulletin That Rocked the Auto Finance Industry

In 2013, the Consumer Financial Protection Bureau (CFPB) issued a bulletin on indirect auto lending that took the industry by storm. As we approach the five-year anniversary of the memo’s issuance, it’s valuable to reflect on...more

Bradley Arant Boult Cummings LLP

2017 in Review: Three State Enforcement Trends Impacting the Auto Finance Industry

Auto lenders, like many private citizens, began 2017 curious as to what change the impending Trump administration would bring. In the landscape of government enforcement, however, the consensus amongst industry participants...more

A&O Shearman

US Federal Banking Regulators May Re-evaluate Leveraged Lending Guidance

A&O Shearman on

The US Board of Governors of the Federal Reserve System, and the US Federal Deposit Insurance Corporation sent letters to Representative Blaine Luetkemeyer stating that they are considering seeking public input regarding...more

Ballard Spahr LLP

The preclusive effect of a Congressional override of the CFPB dealer pricing bulletin: we think Professor Levitin’s premise is...

Ballard Spahr LLP on

As we reported recently, the Government Accountability Office has determined that CFPB Bulletin 2013-02 on dealer pricing in indirect auto finance (“Dealer Pricing Bulletin” or “Bulletin”) is a “rule” subject to review under...more

Ballard Spahr LLP

CFPB indirect auto finance bulletin determined to be a “rule” subject to Congressional review

Ballard Spahr LLP on

Congress may have now have the opportunity to disapprove by a simple majority vote the CFPB’s disparate impact theory of assignee liability for so-called dealer “markup” disparities as a result of a determination by the...more

Troutman Pepper Locke

Recent Congressional Review Act Developments Could Have Far-Reaching Effects

Troutman Pepper Locke on

On December 5, the Government Accountability Office (GAO) essentially invalidated the CFPB’s auto lending guidance by finding that it constitutes a “rule” for purposes of the Congressional Review Act (CRA)....more

Hogan Lovells

Catch a fish by its tail: has Senator Pat Toomey hooked the U.S. Leveraged Loans Guidance?

Hogan Lovells on

What has the U.S. Fish and Wildlife Service got in common with the U.S. banking agencies [1]? Simple: the U.S. Government Accountability Office (the "GAO"), which investigates financial matters on behalf of Congress, has...more

Ballard Spahr LLP

GAO determination that leveraged lending guidance is subject to CRA could foreshadow similar fate for CFPB indirect auto finance...

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In May 2017, we blogged about press reports that the Government Accountability Office (GAO) had accepted a request from Senator Patrick Toomey for a determination concerning whether the CFPB Bulletin 2013-02, titled “Indirect...more

A&O Shearman

The U.S. Government Accountability Office Determines That 2013 Leveraged Lending Guidance Is a Rule

A&O Shearman on

On October 19, 2017, the United States Government Accountability Office (GAO) issued an opinion determining that the 2013 Interagency Guidance on Leveraged Lending (the “2013 Guidance”), issued jointly by the Office of the...more

Ballard Spahr LLP

GAO to opine on whether CFPB indirect auto finance guidance is a rule subject to disapproval under the Congressional Review Act

Ballard Spahr LLP on

American Banker has reported that the Government Accountability Office has accepted a request from Senator Pat Toomey on whether the CFPB’s indirect auto finance guidance issued in March 2013 is a “rule” under the...more

Foley & Lardner LLP

Chairman Goodlatte Outlines Sweeping Agenda for House Judiciary Committee

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With Washington undergoing a transformation the likes of which has not been seen in decades, House Judiciary Committee Chairman Bob Goodlatte recently outlined his committee’s priorities for the 115th Congress. Speaking at an...more

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