As for whether any financial regulators take the White House up on its suggestion to skip notice and comment, not sure that would pass a risk/reward test for me. (Why take the chance of having courts block something you otherwise had the authority to do?)

But see above re: the lack of imagination

I probably suffer from a lack of imagination, but my first blush reaction is that I'm not sure this memo will cause any financial regulators to seek to repeal/revise anything they weren't already to planning to revise.