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Interagency Guidance Administrative Procedure Act

Jackson Lewis P.C.

Where Does the End of Chevron Deference Leave ERISA?

Jackson Lewis P.C. on

For the last 40 years, judges were required to defer to administrative agencies’ reasonable interpretations of ambiguous federal statutes under Chevron v. Natural Resources Defense Council. The Supreme Court upended that...more

White & Case LLP

Interagency Statement on Role of Supervisory Guidance to Become a Rule

White & Case LLP on

In response to a call for a rulemaking by two leading bank industry trade associations, the federal banking agencies have issued a proposed rule to codify an earlier interagency statement that their supervisory...more

Ballard Spahr LLP

GAO determination that leveraged lending guidance is subject to CRA could foreshadow similar fate for CFPB indirect auto finance...

Ballard Spahr LLP on

In May 2017, we blogged about press reports that the Government Accountability Office (GAO) had accepted a request from Senator Patrick Toomey for a determination concerning whether the CFPB Bulletin 2013-02, titled “Indirect...more

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