RIS-Page 8
Licensees under the DMA are already required to comply with the DMA; therefore, there will be no, or very little,
additional costs imposed as a result of these proposed rules, which clarify existing rules. The Department
acknowledges the possibility that a minority of licensees may understand the need to adjust their recordkeeping
practices as a result of these rules, and that group of licensees may bear additional costs that, independent of statutory
impact, would consist of minimal costs relating to additional paperwork. Such licensees would have to bear the
additional costs, however, even in the absence of the proposed rule amendments. The Department is not currently
aware of any set of individuals who are not complying with the Department’s understanding of the preexisting rules
and, therefore, would sustain minimal costs in connection with reaching compliance after the promulgation of these
clarifying rules.
A. How many and what category of individuals will be affected by the rules?
The Department is not currently aware of any set of individuals who are not complying with the Department’s
understanding of the preexisting rules and, therefore, would sustain minimal costs in connection with reaching
compliance after the promulgation of these clarifying rules.
B. What qualitative and quantitative impact do the proposed changes in rules have on these individuals?
The proposed changes in rules will have no, or very little, impact on individuals because licensees must already
comply with the existing rules, which these rules merely clarify. The Department acknowledges the possibility that a
minority of licensees may understand the need to adjust their recordkeeping practices as a result of these rules, and
that group of licensees may bear additional costs that, independent of statutory impact, would consist of minimal
costs relating to additional paperwork. Such licensees would have to bear the additional costs, however, even in the
absence of the proposed rule amendments.
30. Quantify any cost reductions to businesses, individuals, groups of individuals, or governmental units as a result
of the proposed rules.
Little or no cost reductions are anticipated for businesses, individuals, groups of individuals, or governmental unit
due to the proposed rules.
31. Estimate the primary and direct benefits and any secondary or indirect benefits of the proposed rules. Please
provide both quantitative and qualitative information, as well as your assumptions.
The primary and direct benefits of the proposed rules would be clarity for all licensees as to their preexisting
obligations regarding the required frequency of updates and posts to books and records, the maintenance of written
policies and procedures for compliance with the DMA, and the preparation of budget analyses that contain adequate
general descriptions. The secondary benefit of the proposed rules would be a reduced likelihood of enforcement
actions that might be required to correct licensees’ future misunderstandings regarding their obligations concerning
the required frequency of updates and posts to books and records, the maintenance of written policies and procedures
for compliance with the DMA, and the preparation of budget analyses that contain adequate general descriptions.
32. Explain how the proposed rules will impact business growth and job creation (or elimination) in Michigan.
DIFS does not anticipate any impact on business growth or job creation/elimination in Michigan as a result of the
rules.
33. Identify any individuals or businesses who will be disproportionately affected by the rules as a result of their
industrial sector, segment of the public, business size, or geographic location.
The proposed rules will apply equally to all individuals and businesses regardless of their industrial sector, segment
of the public, business size, or geographic location.
34. Identify the sources the agency relied upon in compiling the regulatory impact statement, including the
methodology utilized in determining the existence and extent of the impact of the proposed rules and a cost-
benefit analysis of the proposed rules.
In compiling the regulatory impact statement, DIFS relied upon other similarly situated states’ statutes and
regulations (via Westlaw) to confirm that they are similar in scope and extent of regulation. DIFS also consulted legal
authorities relating to federal law (via Westlaw). The agency compared the projected or estimated costs with the
benefits or opportunities associated with the proposed rules by noting the low costs of implementing clarifying
changes to existing rules compared to the benefit of avoiding the possibility of future misunderstandings of the
preexisting rules by regulated persons. No other sources were relied upon.
A. How were estimates made, and what were your assumptions? Include internal and external sources, published
reports, information provided by associations or organizations, etc., that demonstrate a need for the proposed
rules.
MCL 24.245(3)