Obama has made prolific use of memoranda despite his own claims that he's used his executive power less than other presidents. "The truth is, even with all the actions I've taken this year, I'm issuing executive orders at the lowest rate in more than 100 years," Obama said in a speech in Austin last July. "So it's not clear how it is that Republicans didn't seem to mind when President Bush took more executive actions than I did."
http://www.usatoday.com/story/news/politics/2014/12/16/obama-presidential-memoranda-executive-orders/20191805/
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