Applicability of the Biden Administration’s Regulatory Freeze to Independent Agencies

On January 20, 2021, White House Chief of Staff Ron Klain issued a memorandum ordering a temporary freeze of new or pending rules in order “to ensure that the President’s appointees or designees have the opportunity” to review them. Despite such action being a now-routine feature of any new incoming administration, there remains much uncertainty about the scope of this regulatory moratorium, including whether the Klain Memorandum will have the effect of halting pending rules issued by...
By: WilmerHale

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