Comment by db48x

“The commissioner sees it as important that his government department actually follows the rules as written down by Congress” seems like a fairer interpretation.

Congress literally wrote “You must do X when Y”, and the FTC said “Well, probably Y isn’t true anyway, so we can skip doing X”. It’s true that Y involves an estimate, since there’s no way to calculate the exact number, but their estimate was clearly cooked with the specific purpose of letting them rush.

The new rules seem like good rules, too, so it’s really a shame that they decided that it was more important to rush than to do it right. That makes the old commissioner a bungler at best.