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Presidential Memorandum Directing the Repeal of Unlawful Regulations

April 23, 2025

I. Introduction 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...

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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...

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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...