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American Bar Comments on RAA of 2011.pdf


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In general, we think many of the new steps the bill would require for rulemaking are, in
numerous particular cases, valuable and appropriate. However, to impose these requirements
automatically and across the board will, we fear, further ossify the rulemaking process with little
offsetting benefits in the form of better rules.
The following comments track the organization of the bill itself. Readers interested only
in specific provisions of the bill should consult the Table of Contents, which indicates the pages
not only where particular topics, but also where specific statutory provisions, are discussed.

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