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In with the New: Trump Freezes Pending and Non-Issued Obama-Era Regulations

Client Alert | 1 min read | 01.23.17

On January 20, 2017, President Trump's Chief of Staff Reince Priebus issued a memorandum to the heads of the executive departments and agencies calling for a regulatory freeze pending review – a practice that is relatively routine for new incoming presidential administrations. Specifically, the memorandum prohibits agencies from sending any regulation to the Office of Federal Register (OFR) prior to review and approval; requires agencies to immediately withdraw unpublished regulations for review and approval; and mandates that agencies temporarily postpone the implementation of published, but not yet effective, regulations for 60 days. Regulations subject to statutory or judicial deadlines are excluded from the aforementioned actions, but agencies must timely identify them to the OMB Director. Agencies also may identify regulations they believe should not be subject to the aforementioned procedures, namely those affecting "critical health, safety, financial, or national security matters, or for some other reason."

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Client Alert | 7 min read | 05.27.26

Colorado Hits Reset on AI Regulation: SB 26-189 Repeals and Reenacts the Colorado AI Act

Colorado’s original AI Act (SB 24-205), signed in May 2024, imposed broad obligations on developers and deployers of “high-risk AI systems” — including requiring risk management programs, impact assessments, and affirmative steps to prevent algorithmic discrimination across employment, housing, lending, insurance, health care, and education decisions. The operative date for SB 24-205 was extended twice, and a court temporarily suspended enforcement in early 2026, following a lawsuit filed by xAI, which the U.S. Department of Justice (DOJ) intervened to support. Industry feedback on SB 24-205 was generally negative. In response to this environment, Colorado’s legislature undertook a rewrite, drafting and passing SB 26-189 in a matter of weeks. SB 26-189 reflects the legislature’s effort to preserve the policy goal of filling the AI oversight vacuum given the lack of a comprehensive federal law, but within a more workable compliance framework....

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