In a spate of executive orders and other actions over the last several weeks, the new administration has moved to exert unprecedented control over independent regulatory agencies, including the Federal Energy Regulatory...more
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....more
On February 19, 2025, President Donald Trump issued the executive order “Ensuring Lawful Governance and Implementing the President’s ‘Department of Government Efficiency’ Deregulatory Initiative” (the 2025 EO). The 2025 EO,...more
Amidst a blitz of executive action, on February 18, President Donald Trump signed an executive order entitled “Ensuring Accountability for all Agencies” (Executive Order) exerting more direct control over “independent...more
Last week, President Trump issued two executive orders aimed squarely at upending the long-accepted authority and independence of certain federal agencies. The first order, Ensuring Accountability for All Agencies, derides...more
Despite the tone and tint of recent headlines, President Trump's February 18, 2025, "Ensuring Accountability for All Agencies" Executive Order (the "Accountability EO") appears to be the latest in a long line of efforts to...more
The Office of Management and Budget’s (OMB) Office of Information and Regulatory Affairs (OIRA) published a blog item on August 14, 2024, announcing the availability of a report highlighting examples of agencies seeking to...more
As part of its efforts to strengthen public engagement in the federal regulatory process, the Office of Information and Regulatory Affairs (OIRA) in the Office of Management and Budget (OMB) announced on July 10, 2024, that...more
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
The Office of Information and Regulatory Affairs (OIRA) within the Office of Management and Budget (OMB) has completed its review of the new Title IX rule and has cancelled the remaining meetings that were publicly posted,...more
We have an important update to share about the status of MSHA’s Respirable Crystalline Silica rulemaking, officially proposed as Lowering Miners’ Exposure to Respirable Crystalline Silica and Improving Respiratory Protection....more
We have an important update to share about the status and now more clear outcome of OSHA’s rulemaking for a Worker Walkaround Designation Process Rule. Thursday, OMB updated the entry on its website about the Worker...more
In early 2023, OSHA revealed plans for a rulemaking for a Worker Walkaround Representative Designation Process Rule that would amend existing regulation 29 CFR § 1903.8(c), which governs participation by third parties in OSHA...more
On March 1, 2024, the Office of Information and Regulatory Affairs (“OIRA”), Office of Management and Budget (“OMB”), Executive Office of the President received the final version of FDA’s rule on regulation of laboratory...more
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
As of Monday March 4, 2024—just three months after the end of its comment period on December 4, 2023—FDA’s rule on regulation of laboratory developed tests (“LDTs”) as medical devices is under review by the Office of...more
On January 2, 2024, the Office of Information and Regulatory Affairs (OIRA) completed its review of the U.S. Department of Labor’s final rule on independent contractor classification under the Fair Labor Standards Act. The...more
]Effective and meaningful public engagement are “foundational principles of Federal regulatory development” and the Biden Administration has sought to remove barriers to public participation in the regulatory process. We...more
The Biden Administration is in the process of revising a cog fundamental to federal policymaking. The cog, a guidance document issued by the Office of Management and Budget’s (OMB) entitled Circular A-4, has the potential to...more
On April 7, 2023, the Office of Management and Budget (OMB) requested comments on proposed Circular A-4, “Regulatory Analysis.” 88 Fed. Reg. 20915. According to OMB, since 2003, OMB Circular A-4, Regulatory Analysis, has...more
The Office of Management and Budget (OMB) published a request for information (RFI) on April 27, 2023, seeking public input on existing or potential bioeconomy-related industries and products that are established, emerging,...more
On Thursday, the Office of Management and Budget released proposed revisions to “Circular A-4”. It also released a separate preamble, explaining its thinking and asking for comment on certain identified issues....more
In February 2023, the Office of Information and Regulatory Affairs (OIRA), within the Office of Management and Budget (OMB), published a summary of learnings and potential recommendations on broadening public engagement in...more
Regulations matter. Federal executive action is supposed to be rooted in statutes, established through regulatory processes generally tied to the Administrative Procedure Act (APA), and — at least conceptually — rooted in the...more
On November 20, 2022, the Office of Federal Contract Compliance Programs (OFCCP) published proposed changes to its Supply & Service scheduling letter and itemized listing. Over the next few weeks, DCI will provide a series of...more