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> It can be implemented badly if neither party truly understand the requirements, which looks to be the case here.

On that I totally agree with you. But my main point is that the law is so poorly written, almost no one, including most auditors, don't understand it, and you end up with a lot of "better safe than sorry".

If you're someone who truly understands the law then I applaud you and I wish you were my auditor, but is seems that almost no one is as well informed as you, which is the crux of the problem.



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