Michigan Department of Licensing and Regulatory Affairs
Office of Regulatory Reinvention
611 W. Ottawa Street; 2nd Floor, Ottawa Building
PO Box 30004; Lansing, MI 48909
Phone (517) 335-8658 FAX (517) 335-9512
REGULATORY IMPACT STATEMENT
and
COST-BENEFIT ANALYSIS
PART 1: INTRODUCTION
In accordance with the Administrative Procedures Act (APA) [1969 PA 306], the
department/agency responsible for promulgating the administrative rules must complete and
submit this form electronically to the Office of Regulatory Reinvention (ORR) no less than (28)
days before the public hearing [MCL 24.245(3)-(4)]. Submissions should be made by the
departmental Regulatory Affairs Officer (RAO) to orr@michigan.gov. The ORR will review the
form and send its response to the RAO (see last page).
Upon review by the ORR, the agency
shall make copies available to the public at the public hearing [MCL 24.245(4)].
Please place your cursor in each box, and answer the question completely.
ORR-assigned rule set number:
R. 500.101-R 500.111
ORR rule set title:
Captive Insurance Company Rules
Department:
Department of Insurance and Financial Services
Agency or Bureau/Division
Office of Insurance Evaluation
Name and title of person completing this form; telephone number:
Sarah Wohlford, Staff Attorney, 517-373-1624
Reviewed by Department Regulatory Affairs Officer:
Joseph A. Garcia, Deputy General Counsel, 517-373-7466
.
Regulatory Impact Statement and Cost-Benefit Analysis– Page 2
PART 2: APPLICABLE SECTIONS OF THE APA
MCL 24.207a “Small business” defined.
Sec. 7a.
“Small business” means a business concern incorporated or doing business in this state,
including the affiliates of the business concern, which is independently owned and operated and
which employs fewer than 250 full-time employees or which has gross annual sales of less than
$6,000,000.00.”
MCL 24.240 Reducing disproportionate economic impact of rule on small business;
applicability of section and MCL 24.245(3).
Sec. 40.
(1) When an agency proposes to adopt a rule that will apply to a small business and the rule will
have a disproportionate impact on small businesses because of the size of those businesses,
the agency shall consider exempting small businesses and, if not exempted, the agency
proposing to adopt the rule shall reduce the economic impact of the rule on small businesses by
doing all of the following when it is lawful and feasible in meeting the objectives of the act
authorizing the promulgation of the rule:
(a) Identify and estimate the number of small businesses affected by the proposed rule
and its probable effect on small businesses.
(b) Establish differing compliance or reporting requirements or timetables for small
businesses under the rule after projecting the required reporting, record-keeping, and
other administrative costs.
(c) Consolidate, simplify, or eliminate the compliance and reporting requirements for
small businesses under the rule and identify the skills necessary to comply with the
reporting requirements.
(d) Establish performance standards to replace design or operational standards required
in the proposed rule.
(2) The factors described in subsection (1)(a) to (d) shall be specifically addressed in the small
business impact statement required under section 45.
(3) In reducing the disproportionate economic impact on small business of a rule as provided in
subsection (1), an agency shall use the following classifications of small business:
(a) 0-9 full-time employees.
(b) 10-49 full-time employees.
(c) 50-249 full-time employees.
(4) For purposes of subsection (3), an agency may include a small business with a greater
number of full-time employees in a classification that applies to a business with fewer full-time
employees.
(5) This section and section 45(3) do not apply to a rule that is required by federal law and that
an agency promulgates without imposing standards more stringent than those required by the
federal law.
MCL 24.245 (3) “Except for a rule promulgated under sections 33, 44, and 48, the agency shall
prepare and include with the notice of transmittal a regulatory impact statement containing…”
(information requested on the following pages).
. Regulatory Impact Statement and Cost-Benefit Analysis– Page 3
[Note: Additional questions have been added to these statutorily-required questions to satisfy
the cost-benefit analysis requirements of Executive Order 2011-5.]
MCL 24.245b Information to be posted on office of regulatory reinvention website.
Sec. 45b. (1) The office of regulatory reinvention shall post the following on its website within 2
business days after transmittal pursuant to section 45:
(a) The regulatory impact statement required under section 45(3).
(b) Instructions on any existing administrative remedies or appeals available to the public.
(c) Instructions regarding the method of complying with the rules, if available.
(d) Any rules filed with the secretary of state and the effective date of those rules.
(2) The office of regulatory reinvention shall facilitate linking the information posted under
subsection (1) to the department or agency website.
. Regulatory Impact Statement and Cost-Benefit Analysis– Page 4
PART 3: DEPARTMENT/AGENCY RESPONSE
Please place your cursor in each box, and provide the required information, using complete sentences.
Please do not answer the question with “N/A” or “none.”
Comparison of Rule(s) to Federal/State/Association Standards:
(1) Compare the proposed rule(s) to parallel federal rules or standards set by a state or national licensing
agency or accreditation association, if any exist. Are these rule(s) required by state law or federal
mandate? If these rule(s) exceed a federal standard, please identify the federal standard or citation, and
describe why it is necessary that the proposed rule(s) exceed the federal standard or law, and specify
the costs and benefits arising out of the deviation.
There are no parallel federal rules, state standards, national licensing standards, or accreditation
association standards applicable to these proposed rules. These rules are not required by state law or
federal mandate; however, DIFS is authorized to promulgate these rules under Sections 210, 4651,
4747, and 4813 of the Insurance Code of 1956 (MCL 500.210, 500.4651, 500.4747, and 500.4813).
(2) Compare the proposed rule(s) to standards in similarly situated states, based on geographic location,
topography, natural resources, commonalities, or economic similarities. If the rule(s) exceed standards
in those states, please explain why, and specify the costs and benefits arising out of the deviation.
Generally speaking, the proposed rules have three components: 1) a requirement for audited financial
statements; 2) record retention guidelines; and 3) authorization of captive managers.
Currently, audited
financial statements are required of only traditional insurance companies and special purpose financial
captive insurance companies licensed under Chapter 47 in Michigan. Most, if not all, states that domicile
captives require audited financial statements of captive insurance companies. Because the insurance
industry is regulated by states, there are no federal standards that apply.
Regarding record retention,
traditional insurance companies are currently required to maintain the types of documents listed in these
proposed rules. These documents would be used when conducting financial examinations of captive
insurance companies. The National Association of Insurance Commissioners (NAIC), which accredits
state insurance departments in the United States, publishes guidance on the documents that are
needed to be reviewed when conducting a financial review of an insurance company.
Regarding the
captive manager authorization, most, if not all, states that domicile captives have a similar requirement,
because captive managers typically run the day-to-day operations of the captive insurance company.
Like the captive statute, these proposed rules are patterned after similar rules in Vermont, Arizona, and
South Carolina. Each of those states is a major domicile for captive insurance companies, and is known
for its regulatory structure that provides reasonable oversight while providing for robust competition.
(3) Identify any laws, rules, and other legal requirements that may duplicate, overlap, or conflict with the
proposed rule(s). Explain how the rule has been coordinated, to the extent practicable, with other
federal, state, and local laws applicable to the same activity or subject matter.
This section should
include a discussion of the efforts undertaken by the agency to avoid or minimize duplication.
We do not know of any duplication, overlap, or conflict of the proposed rules. However, most entities
already have an audit conducted as a matter of good business practice and most captive insurance
companies will already be retaining most, if not all, of the documents relating to record retention.
Purpose and Objectives of the Rule(s):
(4) Identify the behavior and frequency of behavior that the proposed rule(s) are designed to alter.
Estimate the change in the frequency of the targeted behavior expected from the proposed rule(s).
Describe the difference between current behavior/practice and desired behavior/practice. What is the
desired outcome?
Regarding the requirement for audited financial statements, the benefits include an independent,
objective assessment of risk, controls, and compliance.
The management, as well as regulators,
. Regulatory Impact Statement and Cost-Benefit Analysis– Page 5
shareholders, suppliers, and financers, are assured that the risks in the organization are well-studied,
and effective systems are in place to handle them. Audits can improve a company’s efficiency and
profitability by helping the management better understand their own internal processes and financial
systems. Having an audit also lessens the risk and therefore the cost of capital. Audits can also identify
areas in an organization’s financial structure that need improvement, and how to implement the proper
changes and adjustments.
An audit can uncover inaccuracies and discrepancies within an
organization’s records, which may be indications of weak financial organization or even internal fraud,
although fraud detection is not the main purpose of an audit. Audits ensure that financial statement
amounts are reliable, consistent, and in compliance with established accounting principles. Audits also
provide assurances to regulators that an independent professional has reviewed the financial
statements.
Currently, captive insurance companies voluntarily have their financial statements audited
by an independent party. The proposed rules are necessary to ensure the accessibility of the audited
financial statements. Regarding record retention, DIFS is required by law to conduct financial
examinations of captive insurance companies licensed in Michigan.
The proposed rules list the
documents required to be retained as well as the duration of the retention period, which will enable DIFS
to conduct financial examinations. Without such a list, DIFS’ ability to conduct a timely and efficient
exam is compromised. Regarding captive manager authorization, DIFS needs to ensure that the
persons who are conducting the day-to-day operations of a licensed captive are qualified to do so.
(5) Identify the harm resulting from the behavior that the proposed rule(s) are designed to alter and the
likelihood that the harm will occur in the absence of the rule.
What is the rationale for changing the
rule(s) and not leaving them as currently written?
Regarding the audited financial statement requirement: in the absence of such a requirement, DIFS has
no independent verification that the financial statements are complete, accurate, and prepared
according to applicable reporting guidelines. DIFS only conducts onsite financial exams every 5 years
or on an as-needed basis. Therefore, it is crucial that the accuracy of the financial statements it
receives on an annual basis are accurate.
Regarding record retention, if the proposed rule is not
enacted, it is possible that DIFS’ examinations of captive insurance companies will be less efficient and
thus more costly to the captive insurance company. Regarding the captive manager authorization: in
the absence of a rule, the day-to-day operation of a captive insurance company could be performed by
an individual who is not qualified to do so, or familiar with captive insurance companies.
(6) Describe how the proposed rule(s) protect the health, safety, and welfare of Michigan citizens while
promoting a regulatory environment in Michigan that is the least burdensome alternative for those
required to comply.
Regarding the audited financial statement requirement, accurate financial statements not only protect
that entity itself but also Michigan citizens. Regarding record retention, the proposed list of documents
needed for a financial examination will lead to better and more effective examinations, which are
designed to protect Michigan citizens.
Regarding captive manager authorization, the proposed rule will
ensure that those who are conducting the day-to-day operations of a captive insurance company are
qualified to do so which protects Michigan citizens.
(7) Describe any rules in the affected rule set that are obsolete, unnecessary, and can be rescinded.
There are no affected rules that are obsolete or unnecessary.
Fiscal Impact on the Agency:
Fiscal impact is an increase or decrease in expenditures from the current level of expenditures, i.e. hiring
additional staff, an increase in the cost of a contract, programming costs, changes in reimbursement
rates, etc. over and above what is currently expended for that function.
It would not include more
intangible costs or benefits, such as opportunity costs, the value of time saved or lost, etc., unless those
issues result in a measurable impact on expenditures.
. Regulatory Impact Statement and Cost-Benefit Analysis– Page 6
(8) Please provide the fiscal impact on the agency (an estimate of the cost of rule imposition or potential
savings on the agency promulgating the rule).
There is no fiscal impact on the department. Audited financial statements are received on an annual
basis and, with the rules’ record retention provisions, DIFS’ examinations will be more expedient and less
costly for DIFS and for the captive insurers, because the rules will result in the required information being
more readily available and accurate.
(9) Describe whether or not an agency appropriation has been made or a funding source provided for
any expenditures associated with the proposed rule(s).
There are no projected expenditures associated with the proposed rule.
(10) Describe how the proposed rule(s) is necessary and suitable to accomplish its purpose, in
relationship to the burden(s) it places on individuals. Burdens may include fiscal or administrative
burdens, or duplicative acts. So despite the identified burden(s), identify how the requirements in the
rule(s) are still needed and reasonable compared to the burdens.
The proposed rule was deemed necessary to remedy omissions in the initial captive legislation.
Most, if
not all, states that allow for captive insurance companies have the components of the proposed rule
within their statutes or rules. The proposed rules are necessary because other states that have captive
insurance programs have similar or identical requirements in their statutes or rules. In addition, the
proposed rules codify current business practices.
The most significant part of the proposed rule
requires audited financial statements from captives. These captives already voluntarily file such
statements, so the rules will impose no additional burden but will codify existing practice.
Impact on Other State or Local Governmental Units:
(11) Estimate any increase or decrease in revenues to other state or local governmental units (i.e. cities,
counties, school districts) as a result of the rule.
Estimate the cost increases or reductions on other state
or local governmental units (i.e. cities, counties, school districts) as a result of the rule. Please include
the cost of equipment, supplies, labor, and increased administrative costs, in both the initial imposition of
the rule and any ongoing monitoring.
There are no increases or decreases in revenues or costs to other state or other local government units
as a result of the rule.
(12) Discuss any program, service, duty or responsibility imposed upon any city, county, town, village, or
school district by the rule(s).
Describe any actions that governmental units must take to be in compliance
with the rule(s). This section should include items such as record keeping and reporting requirements or
changing operational practices.
The proposed rule will not affect any city, county, town or school district.
(13) Describe whether or not an appropriation to state or local governmental units has been made or a
funding source provided for any additional expenditures associated with the proposed rule(s).
There are no additional expenditures associated with the proposed rule for state or local government
units.
Rural Impact:
(14) In general, what impact will the rules have on rural areas? Describe the types of public or private
interests in rural areas that will be affected by the rule(s).
Rural areas will not be affected by the rule.
Environmental Impact:
(15) Do the proposed rule(s) have any impact on the environment? If yes, please explain.
. Regulatory Impact Statement and Cost-Benefit Analysis– Page 7
No, the proposed rule will not have any impact on the environment.
Small Business Impact Statement:
[Please refer to the discussion of “small business” on page 2 of this form.]
(16) Describe whether and how the agency considered exempting small businesses from the proposed
rules.
Entities that own captive insurance companies rarely, if ever, meet the definition of a” small business.”
However, under the rule, DIFS would have the ability to exempt any company from filing audited
financial statements on a case-by-case basis. The other components of the proposed rule, (captive
manager and record retention) have no material costs associated with them. Accordingly, DIFS
considered exempting small businesses from the proposed rules but determined that it was
unnecessary to do so because the exemption would rarely, if ever, apply.
(17) If small businesses are not exempt, describe (a) the manner in which the agency reduced the
economic impact of the proposed rule(s) on small businesses, including a detailed recitation of the efforts
of the agency to comply with the mandate to reduce the disproportionate impact of the rule(s) upon small
businesses as described below (in accordance with MCL 24.240(1)(A-D)), or (b) the reasons such a
reduction was not lawful or feasible.
Traditionally, captive insurance companies are not formed by small businesses. However, if a small
business that formed a captive insurance company under Chapter 46 of the Michigan Insurance Code
was able to show financial hardship by the requirement of an audit, DIFS would consider exemption
from the requirement on a case-by-case basis.
(A) Identify and estimate the number of small businesses affected by the proposed rule(s) and the
probable effect on small business.
We estimate the number of small businesses affected by the proposed rule to be zero because any
small businesses that own currently-licensed captives already voluntarily comply with the requirements
set forth in the rule.
(B) Describe how the agency established differing compliance or reporting requirements or
timetables for small businesses under the rule after projecting the required reporting, record-keeping,
and other administrative costs.
DIFS would have the ability to exempt a captive insurance company from having audited financial
statements on a case-by-case basis.
As a matter of good business practice, most captive insurance
companies, if not all, are already voluntarily having their financial statements audited by an independent
party.
(C) Describe how the agency consolidated or simplified the compliance and reporting
requirements and identify the skills necessary to comply with the reporting requirements.
As a matter of good business practice, most captive insurance companies, if not all, are already
voluntarily having their financial statements audited by an independent party. Captive insurance
companies are required to submit a financial report on a GAAP or statutory basis, which are the same
standards used in a financial statement audit.
(D) Describe how the agency established performance standards to replace design or operation
standards required by the proposed rules.
Captive insurance companies are required to submit a financial report on a GAAP or statutory basis,
which are the same standards used in a financial statement audit.
(18) Identify any disproportionate impact the proposed rule(s) may have on small businesses because of
their size or geographic location.
We estimate the proposed rule will have no disproportionate impact on small businesses because of
their size or geographic location.
. Regulatory Impact Statement and Cost-Benefit Analysis– Page 8
(19) Identify the nature of any report and the estimated cost of its preparation by small business required
to comply with the proposed rule(s).
Small businesses rarely own captive insurance companies. There are currently 14 captive insurance
companies domiciled in Michigan. The cost of audited financial statements for a captive insurance
company range from $12,000 to $24,000, based upon a poll of the three captive insurance companies
domiciled in Michigan which most recently submitted audited financial statements.
(20) Analyze the costs of compliance for all small businesses affected by the proposed rule(s), including
costs of equipment, supplies, labor, and increased administrative costs.
Small businesses rarely own captive insurance companies. The only costs with the proposed rule would
be for audited financial statements, a requirement from which DIFS would have the authority to exempt
certain companies.
See number 18.
(21) Identify the nature and estimated cost of any legal, consulting, or accounting services that small
businesses would incur in complying with the proposed rule(s).
Small businesses rarely own captive insurance companies. The only costs with the proposed rule would
be for audited financial statements. See number 18.
(22) Estimate the ability of small businesses to absorb the costs without suffering economic harm and
without adversely affecting competition in the marketplace.
Small businesses rarely own captive insurance companies.
The range of costs for audited financial
statements is $12,000 to $24,000. We believe that cost would not cause economic harm or adverse
competition, as many small businesses already engage auditors for financial statements.
(23) Estimate the cost, if any, to the agency of administering or enforcing a rule that exempts or sets
lesser standards for compliance by small businesses.
We estimate no cost to the department.
(24) Identify the impact on the public interest of exempting or setting lesser standards of compliance for
small businesses.
We estimate no impact on the public interest of exempting small business.
(25) Describe whether and how the agency has involved small businesses in the development of the
proposed rule(s). If small business was involved in the development of the rule(s), please identify the
business(es).
Small businesses rarely own captive insurance companies, and it is impossible to identify which small
businesses might form a captive insurance company in the future.
Thus, the department has not
involved small businesses in the development of the proposed rule.
Cost-Benefit Analysis of Rules (independent of statutory impact):
(26) Estimate the actual statewide compliance costs of the rule amendments on businesses or groups.
Identify the businesses or groups who will be directly affected by, bear the cost of, or directly benefit from
the proposed rule(s). What additional costs will be imposed on businesses and other groups as a result
of these proposed rules (i.e. new equipment, supplies, labor, accounting, or recordkeeping)? Please
identify the types and number of businesses and groups.
Be sure to quantify how each entity will be
affected.
The only costs associated with the proposed rule are related to audited financial statements. Most
captive insurance companies are already incurring costs for audited financial statements. Typical costs
for audited financial statements for captive insurance companies are in the range of $12,000 to $24,000.
The only entities affected by the proposed rules related to audited financial statements would be captive
insurance companies licensed under Chapter 46 of the Michigan Insurance Code.
As of this date there
. Regulatory Impact Statement and Cost-Benefit Analysis– Page 9
are 14 captive insurance companies who have been granted a limited certificate of authority in Michigan.
It is anticipated we will receive audited financial statements from all 13 captive insurance companies
licensed under Chapter 46 of the Michigan Insurance Code. The one captive insurance company
licensed under Chapter 47, which requires audited financial statements, has an exemption from filing
since it is inactive.
(27) Estimate the actual statewide compliance costs of the proposed rule(s) on individuals (regulated
individuals or the public). Please include the costs of education, training, application fees, examination
fees, license fees, new equipment, supplies, labor, accounting, or recordkeeping). How many and what
category of individuals will be affected by the rules? What qualitative and quantitative impact does the
proposed change in rule(s) have on these individuals?
The only costs associated with the proposed rule are related to audited financial statements.
As a
matter of good business practice, captive insurance companies in Michigan currently undergo a financial
statement audit and it is anticipated that all captive insurance companies licensed under Chapter 46 of
the Michigan Insurance Code will voluntarily submit audited financial statements, if they do not do so
already. As such, there is no additional cost.
(28) Quantify any cost reductions to businesses, individuals, groups of individuals, or governmental units
as a result of the proposed rule(s).
We estimate no cost reductions to businesses as a result of the proposed rule.
(29) Estimate the primary and direct benefits and any secondary or indirect benefits of the proposed
rule(s). Please provide both quantitative and qualitative information, as well as your assumptions.
The benefits of an audit include an independent, objective assessment of risk, controls, and compliance.
The management, as well as regulators, shareholders, suppliers and financers, are assured that the
risks in the organization are well-studied, and effective systems are in place to handle them.
Audits can
improve a company’s efficiency and profitability by helping the management better understand their own
internal processes and financial systems. An independent audit also lessens the risk and therefore the
cost of capital. Audits can also identify areas in an organization’s financial structure that need
improvement, and how to implement the proper changes and adjustments.
An audit can uncover
inaccuracies and discrepancies within an organization’s records, which may be indications of weak
financial organization or even internal fraud, although fraud detection is not the main purpose of an
audit. Due to audits, financial statement amounts are more reliable, consistent, and based upon
established accounting principles. As a regulatory body we can gain comfort that another independent
professional has reviewed the financial statements.
Currently, captive insurance companies voluntarily
have their financial statements audited by an independent party. The benefits of requiring the captive
manager authorization include ensuring managers meet minimum qualifications and the day-to-day
operations of captive insurance companies are managed by individuals with the appropriate knowledge,
background, and experience. Regarding record retention, DIFS is required by law to conduct financial
examinations of captive insurance companies licensed in Michigan.
The proposed rules list those
documents and the duration of time those documents must be kept, which will enable DIFS to conduct
financial examinations. Without such a list, DIFS’ ability to conduct a timely and efficient exam will be
compromised.
(30) Explain how the proposed rule(s) will impact business growth and job creation (or elimination) in
Michigan.
The proposed rule will have little to no impact on job creation or job elimination in Michigan. The
proposed rule has marginal potential to have a positive impact on business growth in Michigan by
demonstrating that Michigan is committed to its captive insurance program.
(31) Identify any individuals or businesses who will be disproportionately affected by the rules as a result
of their industrial sector, segment of the public, business size, or geographic location.
The proposed rules will only affect captive insurance companies.
.
Regulatory Impact Statement and Cost-Benefit Analysis– Page 10
(32) Identify the sources the agency relied upon in compiling the regulatory impact statement, including
the methodology utilized in determining the existence and extent of the impact of a proposed rule(s) and
a cost-benefit analysis of the proposed rule(s).
How were estimates made, and what were your
assumptions? Include internal and external sources, published reports, information provided by
associations or organizations, etc., which demonstrate a need for the proposed rule(s).
The only cost associated with the proposed rule relate to the audited financial statements. DIFS polled
three captive insurance companies that voluntarily submitted audited financial statements and
determined a range between $12,000 and $24,000.
Alternatives to Regulation:
(33) Identify any reasonable alternatives to the proposed rule(s) that would achieve the same or similar
goals. In enumerating your alternatives, please include any statutory amendments that may be
necessary to achieve such alternatives.
We know of no reasonable alternatives to the proposed rule that would achieve the same or similar
goals. The only way to examine the financial condition of a captive insurance company is to have an
independent professional perform a comprehensive review of the financial statements.
The best way to
gain reasonable assurance regarding the financial health of a captive insurance company is to have a
qualified independent certified public accountant conduct an audit. Audits conducted by an independent
third party on a compulsory basis will provide measurable, consistent, reliable, and reasonable results in
relation to financial standing.
(34) Discuss the feasibility of establishing a regulatory program similar to that proposed in the rule(s)
that would operate through private market-based mechanisms. Please include a discussion of private
market-based systems utilized by other states.
The only cost associated with the proposed rules are related to the audited financial statements.
Audited financial statements are executed by independent certified public accountants who are in the
private marketplace and qualified by the AICPA, the national rule-making and standard-setting
organization for certified public accountants.
To our knowledge, there are no private market-based
systems utilized by other states.
(35) Discuss all significant alternatives the agency considered during rule development and why they
were not incorporated into the rule(s). This section should include ideas considered both during internal
discussions and discussions with stakeholders, affected parties, or advisory groups.
The proposed rule was deemed necessary to remedy omissions in the initial captive legislation. Most, if
not all, states that allow for captive insurance companies have the components of the proposed rule
within their statutes or rules.
The rule will help ensure that Michigan’s captive program remains
competitive with other states’ captive programs.
Additional Information
(36) As required by MCL 24.245b(1)(c), please describe any instructions regarding the method of
complying with the rules, if applicable.
Not applicable.
PART 4: REVIEW BY THE ORR
Date Regulatory Impact Statement (RIS) received:
11-7-2014
Date RIS approved:
ORR assigned rule set
11-13-2014
2014-152 IF
. Regulatory Impact Statement and Cost-Benefit Analysis– Page 11
number:
Date of disapproval:
Explain:
More information
needed:
Explain:
(ORR-RIS March 2014)
.