Opaque Regulatory Decision-Making Threatens Business Planning

The Division can publish its own internal rules and render binding decisions on sanctions and remedies without establishing transparency requirements or clear procedural standards. This creates regulatory unpredictability for businesses subject to the bill's extensive compliance obligations—businesses cannot effectively assess compliance costs or plan operations when enforcement standards can change through unpublished internal rules and binding decisions lack procedural constraints. The combination of self-directed rule-making authority with binding adjudicatory power over business operations undermines the regulatory certainty necessary for commercial planning and investment decisions.