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Analysis
Presidential Memorandum Directing the Repeal of Unlawful Regulations
April 23, 2025
On April 9, 2025, President Trump signed a Presidential Memorandum “Directing the Repeal of Unlawful Regulations” and an accompanying “Fact Sheet” (the Presidential Memorandum and the Fact Sheet...
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Regulations.gov form for submitting deregulation ideas
April 14, 2025
There is now a form on Regulations.gov for submitting deregulation ideas in response to last week's OMB RFI. A few observations: The form seems designed to support automated generation of draft...
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RFI on deregulation ideas
April 10, 2025
TLDR: "Are there any regulations you want to repeal?" I guess the White House is unhappy with the volume of regulation repeal ideas coming out of the regulatory review under EO 14219: they're about...
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EO floats bypass of notice-and-comment for deregulatory actions
April 10, 2025
Major developments re the Deregulation EO 14219, including a plan to bypass notice-and-comment on some regs. A new EO signed yesterday orders agency heads to bypass notice-and-comment if a rule they...
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OCC email system breach
April 8, 2025
“The OCC discovered that the unauthorized access to a number of its executives’ and employees’ emails included highly sensitive information relating to the financial condition of federally regulated...
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DC Circuit vacates stay of order restoring MSPB and NLRB members
April 7, 2025
The en banc DC Circuit, citing Humphrey's Executor, has vacated the panel's stay of the district court's order restoring the fired MSPB and NLRB members. Especially interesting for financial services...
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Top success factor for a novel bank charter application
March 13, 2025
In my experience, the top success factor for a novel bank charter application is already having a customer deposit business. Why? Because the biggest hurdle most applicants face is convincing the...
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DOGE and the OIG Report on BETR
March 12, 2025
DOGE’s focus on replacing humans with AI adds significance to this recent FRB OIG report on the Bank Exams Tailored to Risk (BETR) process, which tailors community bank exams to risk through...
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EO 14219 and MRAs, MRIAs & MRBAs
March 11, 2025
EO 14219 and MRAs, MRIAs & MRBAs -- an example from the FDIC Crypto Documents: EO 14219 orders agencies to de-prioritize (and terminate) enforcement inconsistent with Administration policy and legal...
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EO 14219 and the Prudential Regulators
March 6, 2025
It seems like the broad regulatory review ordered by EO 14219 was drowned out by last month’s other noise. And, at most agencies, staffing upheaval will make it hard to take rapid deregulatory...