What is the statement of facts and circumstances justifying a rule, and how does it differ from the statement of purpose and effect?
The statement of facts and circumstances justifying a rule is a detailed statement explaining why the rule is being adopted or amended; i.e., what circumstances changed, such as a change in the industry, to justify the amendment or what new facts, such as an amendment to the law implemented, exist to justify the new or amended rule. The statement of purpose and effect is a brief explanation of the reason for the proposed action and outcome sought to be achieved.
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