5th Circ. Ruling Will Spur Challenges To No-Action Letters

By Gordon Todd, Brian Morrissey and Manuel Valle (August 10, 2023, 1:40 PM EDT) -- With potentially far-reaching implications for the "no-action" letter practice that is common at multiple federal agencies, the U.S. Court of Appeals for the Fifth Circuit ruled on July 21 that the U.S. Commodity Futures Trading Commission's decision to withdraw a no-action letter constituted a final agency action subject to judicial review.[1]...

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