James Lankford actually said...

"OK, so how does that happen?"

"I want to just put a check on that to say it is not really a safe harbor, because even they say they are not bound by No Action Letters."

"Because I am not asking, did they make the right decision? I am asking, did they do the process, and should there be an ability to have judicial review if they did not complete the process?"

"But that is just significant guidance you are highlighting. Is that correct?"