Admin law – peer’s debate evaluation.

Please read the scenario below, and the debate from my peer. I need 250 words replying the debate of my peer’s work. The analysis provided must be back-up by the USA Law. ***When you are responding to the “Debate this” prompt, I want you to explain the WHY. I want you to have material to back up your position. I want to see the support. What is your source? I want you to constructively comment and add value to someone else’s post.*** You will see the scenario, the debate phrase and my peer’s debate. The last one is the one you have to work on.  
Scenario:
 Assume that the Securities and Exchange Commission (SEC) has a rule under which it enforces statutory provisions prohibiting insider trading only when the insiders make monetary profits for themselves. Then the SEC makes a new rule, declaring that it has the statutory authority to bring enforcement actions against individuals even if they did not personally profit from the insider trading. The SEC simply announces the new rule without conducting a rulemaking proceeding. A stockbrokerage firm objects and says that the new rule was unlawfully developed without opportunity for public comment. The brokerage firm challenges the rule in an action that ultimately is reviewed by a federal appellate court. Using the information presented in the chapter, answer the following questions. 
Debate phrase: 
 Because an administrative law judge (ALJ) acts as both judge and jury, there should always be at least three ALJs in each administrative hearing. 
Peer’s debate. Please work on this debate. Agree on it, and back up your response with the USA Law. : 
 Interpretive laws are in the form of pronouncements that are issued in different formalities through bulletins and memos. However, it is not easy to discern the interpretive laws from the rest; thus, APA expressly excludes those declared by the court from abiding by the notice and comment procedure. In some cases, the involved parties are given an option to forgo a jury and judge a mandate to weigh all the facts they provide.

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