President Donald Trump signed a pair of executive orders last week that the White House said were meant to curtail what it views as “abuses” of American citizens by federal agencies.
The orders deal with what the administration said is a federal bureaucracy that is “running roughshod” over individuals’ and companies’ legal and constitutional rights: they demand that agencies increase transparency in their regulatory and enforcement processes and reduce what the White House said is an overreliance on informal rulemaking.
Both executive orders address the Administrative Procedure Act. The administration said agencies too often use informal guidance as a work-around to the notice and comment processes the APA demands. So going forward, agencies will have to treat all guidance documents they issue, or have published before, as non-legally-binding.
Until now, the White House said, agencies have sometimes used guidance as a stand-in for formal regulations.
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The directive to agency heads builds on an 
On March 27, 2017, the president signed Executive Order 13782 revoking executive orders by President Barak Obama that had regulated the conduct of federal contractors. President Trump’s EO 13782 expressly revokes Obama’s EO 13673, also known as the “Fair Pay and Safe Workplaces” order, as well as subsequent amendments, set forth in Section 3 of EOs 13683 and 13738.
The concept is easy, but the implementation can be far more complicated, particularly in the current government contracting world where waivers to those requirements have become common.
This policy comes on the heels of 
