• The Downfall of the Paralyzed Veterans Doctrine Grants Federal Agencies a "Dangerous Permission Slip for the Arrogation of Power" and Exposes the Regulated Community to Potentially Fatal Doses of Regulation Run Amok
  • March 30, 2016 | Author: Lawrence P. Halprin
  • Law Firm: Keller and Heckman LLP - Washington Office
  • The Downfall of the Paralyzed Veterans Doctrine Grants Federal Agencies a “Dangerous Permission Slip for the Arrogation of Power” and  Exposes the Regulated Community to  Potentially Fatal Doses of Regulation Run Amok (a/k/a The Triple Whammy of Perez, Auer and Whitman) In the Spring of 2015, a troubling decision of the U.S. Supreme Court, Perez v. Mortgage Bankers Association,[1] stripped away the only practical protection available to the regulated community against the abusive regulatory agency practice of adopting ambiguous legislative rules and then re-interpreting them in almost whatever way the agency later deems appropriate.  Commentators hinted at the quagmire it might create for the regulated community. Fast forward three months to June 2015 and the regulated community found itself quickly settling into the quicksand.