The Federal Maritime Commission (the “FMC” or the “Commission”) recently issued its highly anticipated decision on remand in TCW, Inc. v. Evergreen Shipping Agency (America) Corp. et al. (the “Order on Remand”),[1] a...more
Over the last three decades, federal agencies have increasingly used “interpretations” to “explain” what a formal regulation means, rather than to go through the more expensive, complicated and slow process of changing the...more