Tuesday, February 17, 2009
Are available on the Internet, and Chris Clayton reads the new handbook on Adjusted Gross Income and other payment limitation rules. I wonder a little bit--the lawyers would say the regulations in the Federal Register are legally binding, the handbooks aren't. ASCS and FSA always took the approach of making the handbooks more detailed and more explanatory than the regs. (The former FmHA, however, was operating as a financial institution, which meant their lawyers forced them to publish their "handbooks" as regulations. Such publication made it harder for the bureaucracy. The gain in public notice resulted in a loss of flexibility.) Now that the public can easily see the handbooks, indeed more easily see the handbooks than the regulations if it comes to that, I wonder what the long term consequences will be.