Heidi Heitkamp actually said...

And, it just keeps getting to that point where had you started with a rulemaking process, you would have a firmer foundation for this whole ...

I have long maintained that I think guidance can be extraordinarily helpful.

When we change how we interpret either rules or statutes, and the change has a dramatic impact on the livelihood of business people, we get ...

Is that really the kind of relationship we want with the public as it relates to an interpretive change?