D.C. Circuit Voids Agency Attempt to Stay Implementation of Final Rule Pending Reconsideration of the Rule

Given the highly regulated nature of the financial services industry, the recent decision by the U.S. Court of Appeals for the D.C. Circuit vacating the action of the Environment Protection Agency to impose a stay on the implementation of its previously issued final rule underscores that administrative law requirements must be satisfied in connection with efforts to modify or repeal rules.

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