The OMB Issued a Memo Freezing Federal Financial Assistance. And Then Rescinded the Memo, But Not the Freeze. Confused? Read On

On January 29, the U.S. Office of Management and Budget (OMB) rescinded M-25-13, which it had issued two days earlier, and which required federal agencies to "temporarily pause all activities related to obligation or disbursement of all Federal financial assistance."

Days after it was issued on January 27, one federal judge administratively stayed a portion of the memo before the OMB rescinded it altogether. A White House press secretary subsequently explained that the "freeze" was, in fact, still in place, and another judge indicated he intends to issue an injunction soon.

While much remains unclear, there are basic parameters and next steps every FFA recipient should consider.

Authors: Dismas Locaria and Christopher Griesedieck, Jr. (Venable LLP)