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Update in Brief

Shining the Light on Regulatory Dark Matter: Due Process and Management for Agency Guidance Documents

While agency development and use of guidance documents can be a mind-numbing subject, it is very important. Guidance – the full spectrum of agency policy statements and interpretive rules, including agency memoranda, circulars, bulletins, frequently- asked questions and so forth – is a vast but…

Shining the Light on Regulatory Dark Matter: Due Process and Management for Agency Guidance Documents

While agency development and use of guidance documents can be a mind-numbing subject, it is very important. Guidance – the full spectrum of agency policy statements and interpretive rules, including agency memoranda, circulars, bulletins, frequently- asked questions and so forth – is a vast but…

Bringing Accountability to Regulation: Doing More Good than Harm

 If reasonable minds can agree that the goal of regulation is to enhance, not undermine, societal well-being, then the Regulatory Accountability Act (RAA), S. 951, can bring the most important statutory change to the regulatory process since the enactment of the Administrative Procedure Act…