Subject: S7–04–23
From: Anonymous
Affiliation:

Oct. 23, 2023

When regulations are overly complex or ambiguous, it becomes very difficult for agencies to apply penalties and enforce rules consistently across all regulated entities. Some key problems that arise:
Vague language and multiple interpretations lead to inconsistent punishment for similar violations. Undermines fairness. Resource constraints prevent universal enforcement, so selective enforcement seems arbitrary. Complex interlocking rules make it hard to definitively prove violations in some cases. Easy for companies to find loopholes in dense regulations to avoid penalties. Inconsistent penalty precedent as new scenarios continuously emerge from unclear rules. Regulators gravitate toward areas of clarity, allowing unaddressed violations of ambiguous aspects. Disparities as large companies can afford top legal talent to negotiate down fines. Simplifying regulations and providing more concrete guidelines for compliance can help ensure fair and predictable enforcement actions. But addressing complexity requires upfront work. After the fact, inconsistent penalties erode trust in regulatory agencies and undermine deterrence goals. Clear, straightforward rules are the first step.






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