Two Recent Executive Orders Aim to Limit the Impact of Agency Guidance Documents

Crowell & Moring – Federal agencies often clarify statutory or regulatory obligations through non-binding “guidance” documents, which the Administrative Procedure Act (APA) exempts from notice-and-comment requirements. Businesses routinely ask for this guidance to help break down what are often complex and convoluted rules. But all too often, these guidance documents shed their “non-binding” character, and […]
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