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this is an attempt by the enforcement side to actually WRITE the rules. While they can issue executive orders that clarify the rules, this one looks like they are creating a whole new record keeping requirement.
They will nail a few people, someone will take them to court, and it will get struck down. The level of record keeping they are suggesting is burdensome and requires the dissemination of complete model information in violation of privacy laws.
It's not going to work... but they will try.
Alex
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