Federal Bank Supervisory Agencies May Change Guidance Without Notice-and-Comment Rulemaking | White & Case LLP International Law Firm, Global Law Practice

Federal Bank Supervisory Agencies May Change Guidance Without Notice-and-Comment Rulemaking

New rulemakings to implement financial reforms leave banking organizations facing a host of uncertainties. Guidance or "interpretative rules" from the financial regulators on the intended scope and application of new rules can prove helpful in addressing those uncertainties. These "interpretative rules," however, may now present a new source of uncertainty as the result of a recent decision of the United States Supreme Court.

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