Rulemaking

Committee:

Federal agencies sometimes grant to regulated parties temporary or permanent “waivers” or “exemptions” (also sometimes referred to as “exceptions”) from regulatory requirements.

Committee:

The  ABA’s House of Delegates recently approved Resolution 106B. The Resolution proposes various reforms to the rulemaking provisions of the APA, many of which embrace principles endorsed in past ACUS recommendations.  This project identifies points of overlap, and offers the Conference’s views on non-overlapping portions of the Resolution.