Mar. 22, 2023
March 22, 2023 The proposal would require third parties to disclose records of employee trades to the federal government, which is a record keeping requirement that needs to be analyzed under the PRA. This is going to involve substantial costs, both in terms of employee time and third party costs, and the agency has made no attempt to quantify them. It is likely that if the agency had attempted to quantify these costs, I would have further comments, but it is impossible for me or any other affected party to meaningfully comment on the PRA burden since the agency did not conduct an analysis, in violation of the statute.