Re: center for regulatory effectiveness responds to regs
In a nutshell, they are stating that the regs implementing the UIGEA violate some federal law requiring estimates of a cost for a proposed regulation and do not meet the statutory requirements in the UIGEA itself.
Of course, completing all the steps that they propose to estimate all the costs of compliance with the regs would take years. Essentially, this shows that the UIGEA is unworkable.
IMO iMEGA should have waited until the proposed regs were published. This comment would form the basis for a good argument against the UIGEA. Namely, implementing it violates other federal laws requiring cost estimates and paperwork reduction. Maybe these problems are part of the reason for the delay in the decision in the iMEGA case.
Definitely, this whole comment helps our side.
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