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No, I think that the $100M number comes from the cost of implementing the change, not the impact to the impacted companies' bottom line.
by jakeydus 1y ago
No, I think that the $100M number comes from the cost of implementing the change, not the impact to the impacted companies' bottom line.
- cortesoft 1y agoI think the other person is right… the term is “economic impact” not “cost to implement”
- jakeydus 1y agoThat's what I thought too, but from the ruling in the article, it seemed like the justification came from calculating the cost to implement (emphasis on 'compliance costs'. > But an administrative law judge later found that the rule's impact surpassed the threshold, observing that compliance costs would exceed $100 million "unless each business used fewer than twenty-three hours of professional services at the lowest end of the spectrum of estimated hourly rates," the 8th Circuit ruling said.
- CWuestefeld 1y agoWell, the two are related. By definition, the economic impact must be at least as much as the cost to implement. So estimating the cost to implement sets a lower bound on the total economic impact.
- db48x 1y agoNo, it is only cost to implement the new rules. If this cost is estimated to be above one hundred million dollars, then extra review steps are required. These steps allow the public, and the regulated industry, to suggest alternatives. These alternatives must be evaluated to see if they would be both effective and cheaper for legitimate businesses to implement. If they are, then the FTC is supposed to drop their own proposed rules and adopt the alternative rules instead. This keeps the rules themselves from hurting legitimate businesses; the illegitimate businesses aren’t going to follow the rules anyway.