MEMORANDUM OPINION
ELLEN SEGAL HUVELLE, District Judge.
Plaintiffs have sued the Secretary of the Department of Housing and Urban Development ("Secretary") in his official capacity, alleging that certain regulations that implement the Home Equity Conversion Mortgage ("HECM") program violate the Administrative Procedures Act ("APA"), 5 U.S.C. § 551 et seq. Although plaintiffs originally brought four claims against the Secretary, the parties...
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