In its annual publication of Developments in Administrative Law and Regulatory Practice 2012
, the Section of Administrative Law of the American Bar Association published an article by John Cooney
, as Co-Chair of its Banking and Financial Services Committee, discussing the first opinions issued by the U.S. District Court for the District of Columbia in response to legal challenges to regulations issued to implement the Dodd-Frank statute.
The article focuses on judicial responses to the cost-benefit analyses issued by the implementing agencies (the SEC and the CFTC) and the role the impending wave of decisions interpreting Dodd-Frank may have on Congressional consideration of proposals to require independent regulatory commissions to conduct cost-benefit analyses of their rules.
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