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ABA: The American Bankers Association
Compliance News

ABA Issues Staff Analysis of Executive Orders on Guidance Documents, Administrative Enforcement

ABA has issued a members-only staff analysis of the two executive orders that President Trump issued on Oct. 9. The orders formalized the administration’s position that guidance documents issued by federal regulatory agencies are not legally binding, and that any legally binding requirements must be issued through regulation. The orders also provided limitations on agencies’ use of enforcement actions to ensure that subjects have notice of the standards by which they will be judged.

The staff analyses summarize the orders and discuss the orders’ anticipated impact, particularly on the federal banking agencies and the Bureau of Consumer Financial Protection. For more information, contact ABA’s Jonathan Thessin.