American Bankers Association v. National Credit Union Administration

Wilkins, Circuit Judge:

*656 Longstanding principles of administrative law teach us to give federal agencies breathing room when they make policy and "resolv[e] the struggle between competing views of the public interest." Chevron, U.S.A., Inc. v. Nat. Res. Def. Council, Inc. , 467 U.S. 837 , 866, 104 S.Ct. 2778 , 81 L.Ed.2d 694 (1984). And because many policy decisions merge with legal ones, Chevron requires us frequently to sustain agency interpretations of certain federal statutes. Congress often expects agencies, with their political accountability, "bod[ies] of experience[,] and informed…