So, just to give you a sense of how things work on the enforcement side. As with the rulemaking side, it’s the staff that does the bulk of the work. They consider a rule and will propose it for us and we’ll consider it. Often the vote happens at a public, open meeting. With enforcement actions, we also get recommendations. Typically, the staff will recommend authorizing an enforcement action and settling it at the same time. So we often don’t see the case until the end, and are not involved in the guts of the matter. So we’re either going to authorize the division to sue or authorize you to sue and settle with them on the same day. Most of our cases settle like that right away. The voting happens in a process called seriatim, where we’re just voting on the papers, or we vote at a meeting where we have a discussion, but those meetings are, as you might guess, not open to the public.
Apr 10, 2024
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