The Administrative Procedure Act (APA) provides the procedural framework for both rulemaking and its subsequent judicial review. Stakeholders participate throughout this process as commenters, meeting participants, and, sometimes, litigants. Judicial review represents not a separate regulatory stage, but the culmination of the rulemaking process. Most empirical scholarship, however, does not connect the two stages. Our […]

Source: Harvard Law School Forum on Corporate Governance

Published: 2026-08-10T11:31:48Z