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Rescission of Regulations Without Notice and Comment? What’s Next for Regulated Industries in the Deregulation Climate
Executive Order 14219 (the “Deregulation EO”) directed all executive departments and agencies to identify regulations falling within certain enumerated categories of regulations. More recently, on April 9, 2025, the President issued a memorandum providing further direction to executive departments and agencies regarding implementation of the Deregulation EO. This memorandum addresses how the President envisions that Executive Branch agencies will go about rescinding regulations. And—spoiler alert—the vision for rescinding regulations is a departure from the typical notice-and-comment process.