That's still 10 thousand words you're linking to… I had a look at section §46.104 https://www.hhs.gov/ohrp/regulations-and-policy/regulations/45-cfr-46/revise

That's still 10 thousand words you're linking to… I had a look at section §46.104 https://www.hhs.gov/ohrp/regulations-and-policy/regulations/45-cfr-46/revised-common-rule-regulatory-text/index.html#46.104 https://www.hhs.gov/ohrp/regulations-and-policy/regulations/... since it mentioned exemptions, and at (d) (3) inside that. It still doesn't apply: there's no agreement to participate, it's not benign, it's not anonymous.