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U.S. Court of Appeals for the Fifth Circuit

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Fifth Circuit remands rules to SEC because the agency failed to consider and quantify their cumulative economic impact, as required by the Administrative Procedure Act (APA) and Exchange Act

August 25, 2025

Opinion

U.S. Chamber urges Fifth Circuit to hold that agencies must consider the interaction between closely related, contemporaneously proposed rules, and that the SEC’s failure to do so violates the Administrative Procedure Act

March 12, 2024

U.S. Chamber Amicus Brief

Roman Martinez, Peter E. Davis, and Peter A. Prindiville of Latham & Watkins LLP served as outside counsel.

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