The freeze memo gives an incoming President space to block and reverse last-minute regulations from the previous Administration that don’t align with the policy preferences of the new Administration.īut there’s a catch. Multiple recent Presidents, both Democrats and Republicans, have issued regulatory “freeze” memos on Day One of their terms in order to pause all pending regulations issued by the previous Administration. Trump agencies were keenly focused on insulating their last-minute roll backs from being “frozen” by President Biden on his first day in office. This led the Trump Administration to resort to unprecedented and unlawful tactics to prevent the incoming Biden Administration from reversing the last-minute regulatory roll backs rushed out by President Trump. Having had only one term, President Trump had much less time than most recent Presidents to finish regulatory roll backs that the Administration was hoping to have a second term to complete. The Biden administration now has an opportunity to more easily take off the books numerous deregulatory actions that were not properly submitted to Congress in a timely manner.Īfter the 2020 election, the Trump Administration rushed to complete as much of its regulatory roll back agenda as possible by the end of his term. In its rush to roll back as many regulatory protections as possible following the 2020 election, the Trump Administration violated an obscure regulatory law called the Congressional Review Act, making the last-minute regulatory rollbacks more legally vulnerable to reversal. Unsubmitted or Late-Submitted Rule Tables.