If a certified complaint is filed and an investigation of discrimination begins, a small business may decide to
represent themselves, be represented by Human Resources, or hire a lawyer. As such the estimated additional cost
may range from $0 or higher depending on the option chosen.
24. Estimate the ability of small businesses to absorb the costs without suffering economic harm and without
adversely affecting competition in the marketplace.
Compliance with the Michigan Constitution and the Elliot-Larsen Civil Rights Act (ELCRA) is appropriate and
necessary to conduct business in Michigan.
25. Estimate the cost, if any, to the agency of administering or enforcing a rule that exempts or sets lesser
standards for compliance by small businesses.
The Michigan Constitution, Article V, Section 29, ELCRA, and the Persons with Disabilities Civil Rights Act
precludes exemptions or lesser standards for small businesses. It is a violation of law.
26. Identify the impact on the public interest of exempting or setting lesser standards of compliance for small
Violation of Michigan Constitution, Article V, Section 29 would be unconstitutional. It also would violate state and
federal civil rights laws.
27. Describe whether and how the agency has involved small businesses in the development of the proposed rules.
The current version of the rules had business input during public hearings. Businesses will have the same opportunity
to participate in public hearings regarding these proposed rules.
A. If small businesses were involved in the development of the rules, please identify the business(es).
At the 5-24-2024 Michigan Civil Rights Commission Meeting, presentations on Economic Equity for Minority &
Women Owned Businesses were made by Michigan Minority Supplier and Development Council (MMSDC), West
Michigan Hispanic Chamber of Commerce, National Business League, Inc., Walker-Miller Energy Services. The
focus was economic equity for minority and women-owed businesses. Every business positively benefits from an
environment free from discriminatory practices, policies, and customs. It is a shared benefit for employees,
customers, visitors, etc.
Cost-Benefit Analysis of Rules (independent of statutory impact)
28. Estimate the actual statewide compliance costs of the rule amendments on businesses or groups.
The estimated statewide compliance costs on businesses and groups are $0.
A. Identify the businesses or groups who will be directly affected by, bear the cost of, or directly benefit from the
There are no businesses or groups financially affected by the proposed rules.
B. What additional costs will be imposed on businesses and other groups as a result of these proposed rules (i.e.
new equipment, supplies, labor, accounting, or recordkeeping)? Please identify the types and number of businesses
and groups. Be sure to quantify how each entity will be affected.
There are no estimated additional costs on businesses or groups as a result of the proposed rules.
29. Estimate the actual statewide compliance costs of the proposed rules on individuals (regulated individuals or
the public). Include the costs of education, training, application fees, examination fees, license fees, new
equipment, supplies, labor, accounting, or recordkeeping.
There are no estimated additional costs on regulated individuals or the public as a result of the proposed rules.
A. How many and what category of individuals will be affected by the rules?
The public is affected by the rules. Since January 01, 2018, 10,525 case investigations have been filed with MDCR.
B. What qualitative and quantitative impact do the proposed changes in rules have on these individuals?
Proposed changes in rules will expedite processing complaints; reduce claimant costs to file.
30. Quantify any cost reductions to businesses, individuals, groups of individuals, or governmental units as a result
of the proposed rules.
The cost of notarizing complaints will be eliminated. On average Claimants pay $10 for a notarial act. Based on three
-year total this could average $35,083 per year.
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.