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Comment Period Arbitrary and Capricious Rulemaking Process

Holland & Knight LLP

CFPB Seeks Comments and Data on Revised Open Banking Rule

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The CFPB published an advanced notice of proposed rulemaking (ANPR) on Aug. 22, 2025, seeking comments and data to aid in the agency's reconsideration of its Section 1033 Open Banking Rule. This notice follows the CFPB's...more

Nossaman LLP

Supreme Court Clarifies Requirement for Agencies to Respond to Public Comments on Proposed Rulemakings

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The week of June 23, 2024, in Ohio v. Environmental Protection Agency, the U.S. Supreme Court clarified in a 5-4 decision that if a federal agency fails to provide a reasoned response to comments raised during the rulemaking...more

Goodwin

Financial Services Weekly Roundup: Madden Fix/Valid When Made Rule Faces New Challengers

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In the News. On the heels of a lawsuit challenging the Office of the Comptroller of the Currency’s (OCC) recently issued Madden fix/valid when made rule, eight state attorneys general filed suit challenging a similar rule...more

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