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
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 Management and Budget (OMB) recently issued an updated memorandum to the heads of executive departments and agencies entitled, “Guidance on Compliance with the Congressional Review Act” (2019 Memo). The 2019...more
On April 8, 2019, Commissioner Hester Peirce of the Securities and Exchange Commission (“SEC”) delivered a speech entitled “SECret Garden” at the Practicing Law Institute’s 2019 SEC Speaks conference. In her speech,...more
A memorandum issued by the Office of Management and Budget entitled “Guidance on Compliance with the Congressional Review Act” imposes a new review process on final rules issued by the CFPB and other independent regulatory...more