March 24, 2015 · 6:04 pm

If a regulatory agency is not required to use APA notice and comment procedures to issue an initial interpretive rule, then it is not required to do so upon amendment or repeal


Opinion:
THOMAS E. PEREZ, SECRETARY OF LABOR,
ET AL.
v.
MORTGAGE BANKERS ASSOCIATION ET AL.
And
JEROME NICKOLS, ET AL.
v.
MORTGAGE BANKERS ASSOCIATION

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