kaal:claim:2831040-005

The most widely recognized drawbacks of traditional rulemaking under the Administrative Procedure Act are its lack of speed, its cumbersomeness, and the volume of litigation generated by its notice and comment procedures.

The most traditional and widely recognized drawbacks of the traditional rulemaking system under the Administrative Procedure Act (APA) include its lacking speed, cumbersomeness, and the quantity of litigation it generates via its notice and comment procedures

Wulf A. Kaal, Dynamic Regulation for Innovation (2016), II. Law's Diminishing Capacity to React to Innovation, p. 9
https://ssrn.com/abstract=2831040 · source PDF

Wulf A. Kaal, Dynamic Regulation for Innovation (2016). SSRN: https://ssrn.com/abstract=2831040

• United States APA notice and comment rulemaking

failuresupport: arguedfailure: APA rulemaking dragfamily: regulatory-lagdynamic-regulationlaw-and-legal-systems

• restates kaal:claim:2740477-040 The notice and comment procedures of the SEC are too slow, and the SEC's outdated micromanagement of markets i...

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