All Articles tagged Administrative Procedure Act

• General
  May 13, 2014 EDT
  “GROUNDBREAKIN” OR BROKEN? AN ANALYSIS OF SEC CYBERSECURITY DISCLOSURE GUIDANCE, ITS EFFECTIVENESS, AND IMPLICATIONS
  Matthew F. Ferraro

  Using case studies, this article concludes that the SEC cybersecurity disclosure guidance both procedurally overreaches and substantively underachieves.

• General
  January 01, 2009 EDT
  RULEMAKING WITHOUT RULES: AN EMPIRICAL STUDY OF DIRECT FINAL RULEMAKING
  Michael Kolber

  This paper is the first case study to evaluate the implications of direct final rulemaking in practice—an evaluation of direct final rulemaking by the FDA over the past decade.