9. Please describe the extent to which the rules conflict with or duplicate similar rules,
compliance requirements, or other standards adopted at the state, regional, or federal level.
Parts of R 388.2 duplicate MCL 388.1925. R 388.3 duplicates some of MCL 388.1927. R 388.6
contradicts sections of the School Bond Qualification, Approval and Loan Act (Act) MCL
388.1921 to 388.1939. R 388.10 duplicates sections of the Act. R 388.11 duplicates sections of
the Act. R 388.12 duplicates sections of the Act. R 388.12 duplicates sections of the Act. R
388.13 duplicates some of MCL 388.1935. R 388.20 duplicates some of MCL 388.1938.
10. Is the subject matter of the rules currently contained in any guideline, handbook, manual,
instructional bulletin, form with instructions, or operational memoranda?
Yes, the subject matter for some of these rules is contained in guidelines, applications forms and
11. Are the rules listed on the department’s annual regulatory plan as rules to be processed
for the current year?
12. Will the proposed rules be promulgated under Section 44 of the Administrative Procedures
Act, 1969 PA 306, MCL 24.244, or under the full rulemaking process?
13. Please describe the extent to which the rules exceed similar regulations, compliance
requirements, or other standards adopted at the state, regional, or federal level.
The statute gives exclusive authority to the Bureau of State and Authority Finance to administer
and enforce the School Bond Loan Program. So, no other Michigan or federal regulations apply.
14. Do the rules incorporate the recommendations received from the public regarding any
complaints or comments regarding the rules? If yes, please explain.
No, the Bureau of State and Authority Finance has not received any complaints or comments from
the public regarding the rules.
15. If amending an existing rule set, please provide the date of the last evaluation of the rules
and the degree, if any, to which technology, economic conditions, or other factors have changed
the regulatory activity covered by the rules since the last evaluation.
The last evaluation of the rules was October 1, 2014. Since that time no factors such as
technology, or economic conditions have changed the regulatory activity covered by the rules.
16. Are there any changes or developments since implementation that demonstrate there is no
continued need for the rules, or any portion of the rules?
No, the rules continue to be needed for the implementation, administration, and enforcement of the
17. Is there an applicable decision record (as defined in MCL 24.203(6) and required by MCL
24.239(2))? If so, please attach the decision record.