The Government Accountability Office (GAO) recently found that three guidance documents issued by the Federal Reserve from as far back as 2011 – two of which pertain to large bank supervision – have the force and effect of rules, and therefore are eligible for repeal under the Congressional Review Act (CRA).
GAO’s determination comes shortly following two White House directives stating that guidance may not have the force and effect of a rule.
Get a refresher on what we’ve learned in the past about CRA repeal rules.