SIFMA has submitted an Amicus “Friend of the Court” Brief.

Court: 

U.S. Supreme Court

Amicus Issue: 

Whether a federal agency must engage in notice-and-comment rulemaking pursuant to the Administrative Procedure Act before it can significantly alter an interpretive rule that articulates an interpretation of an agency regulation.

Counsel of Record:

Jones Day 

Jeffrey Johnson

Other Amici: 

U.S. Chamber of Commerce

American Fuel and Petrochemical Manufacturers

American Health Care Association

Business Roundtable

National Association of Manufacturers