Petitions for Rulemaking Filed By NCLA

The New Civil Liberties Alliance Is Taking Federal Departments And Agencies To Task

The New Civil Liberties Alliance has filed 15 anti-guidance petitions—and counting— consistent with the “Brand Memo” issued by the U.S. Department of Justice, asking federal agencies and departments to adopt formal rules barring them from issuing and enforcing improper guidance. NCLA is taking federal departments and agencies to task for the abusive, shortcut manner in which they issue regulatory guidance. We believe that the attempted use of agency guidance documents to create rights or obligations that are binding on regulated third parties in the private sector is wrong and unconstitutional. As such, NCLA is asking DOJ to convert the Brand Memo into a formal rule that will last and prompts dozens of other federal departments and agencies to recognize the problems with the old way of doing guidance and adopt NCLA’s proposed rule.

 

Petition for Rulemaking DHS

Petition for Rulemaking DHS

Filed Feb 21, 2019

Petition For Rulemaking DOJ

Petition For Rulemaking DOJ

Filed Jul 18, 2018

Petition for Rulemaking HUD

Petition for Rulemaking HUD

Filed Jul 30, 2018

Petition For Rulemaking SEC

Petition For Rulemaking SEC

Filed Jul 30, 2018

Petition For Rulemaking Dept. Of Education

Petition For Rulemaking Dept. Of Education

Filed Jul 31, 2018

Petition For Rulemaking FDA

Petition For Rulemaking FDA

Filed Jul 31, 2018

Petition For Rulemaking FCC

Petition For Rulemaking FCC

Filed Aug 8, 2018

Petition For Rulemaking HHS

Petition For Rulemaking HHS

Filed Sep 6, 2018

Petition For Rulemaking DOT

Petition For Rulemaking DOT

Filed Dec 20, 2018

Petition For Rulemaking Dept. Of The Treasury

Petition For Rulemaking Dept. Of The Treasury

Filed Jan 25, 2019

Petition For Rulemaking Dept. Of Interior

Petition For Rulemaking Dept. Of Interior

Filed Jan 25, 2019

Petition For Rulemaking FTC

Petition For Rulemaking FTC

Filed Jan 25, 2019

Petition For Rulemaking DOL

Petition For Rulemaking DOL

Filed Jan 25, 2019

Petition For Rulemaking Dept. Of Agriculture

Petition For Rulemaking Dept. Of Agriculture

Filed Jan 25, 2019

Petition For Rulemaking CFPB

Petition For Rulemaking CFPB

Filed Jan 25, 2019

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