By Michael Silva ( November 20, 2017, 4:48 PM EST) -- As has been much reported on, the Government Accountability Office, acting in response to a request by Sen. Pat Toomey, R-Pa., issued a legal opinion on Oct. 19 indicating that the 2013 Interagency Guidance on Leveraged Lending (GLL) issued jointly by the Fed, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corp. (together, the "regulators") constitutes a "rule" that is subject to the Congressional Review Act. The chairman of the House Subcommittee on Financial Institutions and Consumer Credit, Rep. Blaine Luetkemeyer, R-Mo., followed up on this determination with a Nov. 2 letter to the regulators stating his view that "under the clear statutory language of the CRA" any such rule must be submitted to Congress for a 60-legislative-day review period before it can take effect, and that since the GLL had not been submitted to Congress, "it is not yet legally effective or valid" and therefore the regulators should not enforce it in any way....