Rules on Rulemakings

This project addresses whether and when agencies should adopt rules setting forth the procedures the agencies follow when engaging in informal rulemaking. These procedures can include internal approval requirements for proposed rules, minimum comment periods, requirements for ex ante and ex post review, and protocols for submitting sensitive information, among other subjects. The project will not seek to dictate the precise types of rulemaking procedures agencies should adopt, but it will explore the potential costs and benefits of a single rule or set of rules that sets forth an agency’s informal rulemaking practices.


Committee Chair
Senior Counsel, Office of General Counsel
U.S Securities and Exchange Commission
Staff Counsel and In-House Researcher
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