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Perez v. Mortgage Bankers Ass'n
The U.S. Supreme Court held that federal agencies need not follow the APA's formal notice-and-comment procedures when they wish to change an interpretive rule. In Paralyzed Veterans of America v. D. C. Arena L.P., 117 F. 3d 579 (D.C. Cir. 1997), the D.C. Circuit held that an agency must use the APA'...