FA230 clarifies an essential operational distinction: law, regulation, and guidance are not the same. The law establishes the framework; regulation implements it through Negotiated Rulemaking; and "Dear Colleague Letters" provide guidance, but offer no protection if their application results in non-compliance.
The most valuable takeaway is the emphasis on going to the source—not relying on institutional memory or third-party advice, but rather developing the skill to read and interpret regulatory text directly, including the precise weight of terms such as "may," "must," and "shall."
I will apply this by verifying compliance decisions against current regulations, rather than solely against established practice.
