Developments in Securities Regulation, Corporate Governance, Capital Markets, M&A and Other Topics of Interest. MORE

On Inauguration Day (January 20, 2025) President Trump issued an executive order requiring an immediate regulatory freeze.  The order was among several executive orders that President Trump signed shortly after taking the inaugural oath.  According to the memo:

  • No regulation shall be proposed, issued, or sent to the Office of the Federal Register (the “OFR”), until a department or agency head, appointed or designated by the President after noon on January 20, 2025, reviews and approves the regulation.  This prohibition is subject to exemption by the Director or Acting Director of Office Management and Budget for any rule he deems necessary to address emergency or urgent circumstances.
  • Any regulations that have been sent to the OFR but not published in the Federal Register must be immediately withdrawn from OFR review and sent for OFR approval as described above.
  • For regulations that have been published in the OFR but have not taken effect, steps shall be taken, as permitted by applicable law, to temporarily postpone their effective date for 60 days.

 The order is very similar to the Regulatory Freeze memorandum (link via Politico) that President Trump’s then Chief of Staff, Reince Priebus, circulated following his inauguration in 2017.