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Association of Data Processing Service Organizations, Inc. v. Board of Governors of the Federal Reserve System

745 F. 2d 677 (1984)

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Association of Data Processing Service Organizations, Inc. v. Board of Governors of the Federal Reserve System

United States Court of Appeals for the District of Columbia Circuit
745 F. 2d 677 (1984)

EC
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Facts

Citicorp, a bank, petitioned the Board of Governors of the Federal Reserve System (Board) (defendant) for approval to establish a data-processing subsidiary. The Board conducted a formal hearing on Citicorp's petition. The administrative law judge, sometimes called an ALJ, who presided over the hearing made findings of fact. Based on these factual findings, the administrative law judge recommended that the Board approve Citicorp's petition and, as a related action, amend a Board regulation. The Board: (1) adopted the administrative law judge’s factual findings, (2) approved Citicorp's petition, which was an adjudicatory action, and (3) followed the Administrative Procedure Act’s (APA’s), 5 U.S.C. § 551 et seq., procedure to amend the Board regulation, which was a regulatory action. The Association of Data Processing Service Organizations, Inc. (ADPSO), a data-processing industry group, petitioned the Board for a review of both the adjudicatory action and the regulatory action. The ADPSO contended that the Board was statutorily required to demonstrate substantial evidence in support of both actions, and failed to do so.

Rule of Law

Issue

Holding and Reasoning (Scalia, J.)

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