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Regulatory Freeze Pending Review


A week ago -- actually, the day of President Biden's inauguration and first half-day at work (which was probably a lot of "Did you bring your state ID and your social security card?" and "You start with no PTO, but you start accruing it as of tomorrow") -- the White House, via the Assistant to the President and Chief of Staff Ronald Klain, signaled that some regulatory freezing might be in order:

With respect to rules that have been published in the Federal Register, or rules that have been issued in any manner, but have not taken effect, consider postponing the rules’ effective dates for 60 days from the date of this memorandum, consistent with applicable law and subject to the exceptions described in paragraph 1, for the purpose of reviewing any questions of fact, law, and policy the rules may raise. For rules postponed in this manner, during the 60-day period, where appropriate and consistent with applicable law, consider opening a 30-day comment period to allow interested parties to provide comments about issues of fact, law, and policy raised by those rules, and consider pending petitions for reconsideration involving such rules. As appropriate and consistent with applicable law, and where necessary to continue to review these questions of fact, law, and policy, consider further delaying, or publishing for notice and comment proposed rules further delaying, such rules beyond the 60-day period. Following the 60-day delay in effective date:

a. for those rules that raise no substantial questions of fact, law, or policy, no further action needs to be taken; and

b. for those rules that raise substantial questions of fact, law, or policy, agencies should notify the OMB Director and take further appropriate action in consultation with the OMB Director.


Okay. What does that mean for us?

Yeah. That's what I wanted to talk to you about.

Reg F falls into the "have been published in the Federal Register" and "have not taken effect" category. However, since the current (we'll come back to that) effective date is 30 November 2021, that won't be affected by the proposed 60-day delay.

So Reg F is going to go forward as planned?

That is 100 percent not clear at this moment. It is likely all regulatory changes made under the previous administration will be subject to scrutiny of some kind -- and some will get more scrutiny than others. 

Because Reg F directly affects consumers, the safe guess is that it will be reviewed. And there may be some changes, either suggested or implemented.

Then what do we do?

Whatever you're currently doing to prepare for the roll-out of Reg F, keep doing that. And if you haven't started at all because you're thinking "this'll never happen" (which is how I read most computer manuals), stop that. Reg F in some form -- and likely mostly the current form we know -- is going to happen.




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