Readers - no legal advice is given on this forum. Dye Chemist do not give legal advice here. If you are an attorney you would know better if you are not then don't give legal advice. It is only fair to the readers that you disclose your financial interest , if any , in this discussion.
Readers never ever count on getting legal advice you can count on from a regulator because its your rear end that is at risk. I have had federal and state regulators assure me that something was ok only to have them take the opposite position later. Good thing for my clients that I knew better and confirmed the statements in writing. They were dead wrong when they gave the advice and also wrong in thinking the judge would agree with them. Problem is it is very expensive to fight a government