Administrative Procedure -- active
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National Association of Manufacturers & National Gas Services Group, Inc. v. U.S. Securities and Exchange Commission
(5th Circuit)
Whether the SEC violated the APA in rescinding its 2020 proxy advisory firm rule
In 2022, the NAM appealled the district court’s grant of judgment to the SEC on the NAM’s claims challenging the SEC’s rescission of the 2020 proxy firm rule. We argue in this appeal that the district court failed to engage on the substance of the NAM’s claims that the SEC failed to justify its rescission and to give the public a meaningful opportunity to comment in violation of the Administrative Procedure Act.
Related Documents:
NAM Reply Brief (March 13, 2023) Amicus brife of US Chamber and BRT (January 13, 2023) Amicus Brief of Former SEC Officials (January 13, 2023) Amicus Brief of the Society for Corporate Governance (January 13, 2023) NAM brief (January 6, 2023)
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