The New Administration, Freeze Order And Impacts

With a new administration comes the regulatory freeze announcement and its potential impact on organizations and their strategic planning.  Issuing a freeze is so common that the communications almost appear boilerplate.  President Biden made interesting changes, however, in comparison to past presidents. 

First, the scope of the freeze has expanded.  It is normal for a freeze to cover "any substantive action by an agency ... that promulgates or is expected to lead to the promulgation of a final rule or regulation, including notices of inquiry, advance notices of proposed rulemaking, and notices of proposed rulemaking" and "any agency statement of general applicability and future effect that sets forth a policy on a statutory, regulatory, or technical issue or an interpretation of a statutory or regulatory issue."  The announcement from the Biden administration includes both regulations published in the Federal Register (FR) and "rules that have been issued in