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Venable partner John Cooney was quoted in a January 23, 2009 American Shipper article on the impact of the Obama Administration's regulatory freeze on the Importer Security Filing (ISF).

The White House recently ordered a temporary freeze, a common practice for incoming administrations, on regulations from the Bush administration that have not already taken effect. "The White House will quickly review the rules and determine which ones are worth expending senior level staff resources on to change when there are so many other priorities for standing up the administration," said Cooney, former deputy general counsel at the Office of Management and Budget.

"So in the end, the memorandum turns out to identify a very small number of rules that the administration will actually pay attention to," he said. The rules that tend to make the cut are ones that have a large economic impact, such as environmental regulations, or are politically controversial."

According to the article, the ISF (more commonly known as the 10+2 rule) requires importers to electronically file 10 sets of cargo-centric data 24-hours prior to vessel loading overseas and carriers to subsequently file information on the status of containers in their custody.

According to Cooney, the freeze will likely not impact the ISF. "As an interim final rule, '10+2' is less likely to be held up by OMB," he said.