MEMORANDUM OPINION
ELLEN SEGAL HUVELLE, United States District Judge.
On March 8, 2011, plaintiffs sued the Secretary of the Department of Housing and Urban Development ("HUD") in his official capacity, alleging that certain regulations implementing the Home Equity Conversion Mortgage ("HECM") program violate the Administrative Procedure Act ("APA"), 5 U.S.C. § 551 et seq. Although plaintiffs originally brought four claims against HUD...
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