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Notice and Comment Administrative Procedure Act Chevron Deference

Holland & Knight LLP

Trump Executive Order Requires FERC, Other Agencies to Add Sunset Rule into Regulations

Holland & Knight LLP on

President Donald Trump issued an executive order (EO) titled "Zero-Based Regulatory Budgeting to Unleash American Energy" that directs the Federal Energy Regulatory Commission (FERC) and three other federal agencies to...more

Dorsey & Whitney LLP

The SEC and SARs

Dorsey & Whitney LLP on

The Commission periodically has filed enforcement actions against broker-dealers for failing to file SARs - suspicious activity reports - typically centered on a failure to file reports regarding microcap issuers. Those...more

Sheppard Mullin Richter & Hampton LLP

U.S. Supreme Court Holds Agency Interpretations Are Not Subject To Notice-and-Comment Rulemaking Requirement

In 2004, the DOL revamped its regulations regarding the Fair Labor Standards Act (FLSA) administrative exemption. In 2006, the Bush DOL issued an opinion letter finding that mortgage loan officers qualified for the...more

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