News & Analysis as of

Congressional Review Act OIRA Office of Management and Budget

Akin Gump Strauss Hauer & Feld LLP

The Regulatory Race Is On: The Biden Administration Sprints to Issue Key Health Policies

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

King & Spalding

A Brief Overview of the Federal Rulemaking Process in the United States

King & Spalding on

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

Hogan Lovells

OMB Issues Memorandum Guidance on Executive Departments’ and Agencies’ Compliance with the Congressional Review Act

Hogan Lovells on

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

Mayer Brown Free Writings + Perspectives

SEC Informal Guidance Scrutinized by Commissioner and Subject to OMB Memo

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

Morgan Lewis

OMB Expands FERC Actions Subject to Prepublication Review

Morgan Lewis on

A recent policy statement from the Office of Management and Budget (OMB) instructs departments and agencies—including independent agencies like FERC—to submit “guidance documents, general statements of policy, and...more

Morgan Lewis

OMB Expands Department and Agency Actions Subject to Prepublication Review

Morgan Lewis on

The Office of Management and Budget’s (OMB’s) policy statement emphasizes the role of the Congressional Review Act in the rulemaking process and incorporates rulemaking actions that were not consistently subject to...more

Hogan Lovells

New OMB review process could impede FDA issuance of guidance documents

Hogan Lovells on

Starting on 11 May 2019 there will be an additional layer of government review that may slow down the issuance of certain U.S. Food and Drug Administration (FDA) guidance documents. ...more

Ballard Spahr LLP

OMB guidance on CRA compliance imposes new rule review process on independent agencies

Ballard Spahr LLP on

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

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