Yesterday, the Obama administration sent a memo to federal agencies and departments, directing them to freeze any pending rules until they’ve had time to conduct a “legal and policy review” of each one. Apparently, this type of directive is normal for incoming presidents, but it does raise an interesting question as to whether the effective dates of the E-Verify federal contractor rule or even the new I-9 rule will be extended.

Although both rules have already been published, the memo from Chief of Staff Rahm Emanuel directs the agencies to “consider extending for 60 days the effective date of regulations that have been published in the Federal Register but have not yet taken effect…for the purpose of reviewing questions of law and policy raised by those regulations.”

Since the E-Verify rule in particular raises substantial questions of law and policy, it seems likely that it may be delayed again…note though, that most insiders still consider its implementation to be inevitable.