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fails to address a critical question that Congress determined should be addressed by fair and neutral rule-making, not by administrative fiat. 1601 Flab Anne, Room 700, Seattle, Waslalostoa 00101 - Menotti (206) S53-1100 Fax (206) 513-0120 56 of 61 EFTA00100226 Thomas R. Kane November 16, 2011 Page 3
rk, NY 1007 Tel (212) 417-8738 report (DOJ Report) confirms the need to assess PATTERN for accuracy and bias. For example, reported data indicates PATTTERN will have a racially disparate impact, particularly on black males. As illustrated in the charts below, based on the DOJ Report, white males are far
fails to address a critical question that Congress determined should be addressed by fair and neutral rule-making, not by administrative fiat. 1601 Flab Anne, Room 700, Seattle, Waslalostoa 00101 - Menotti (206) S53-1100 Fax (206) 513-0120 56 of 61 EFTA00064963 Thomas R. Kane November 16, 2011 Page 3
rk, NY 1007 Tel (212) 417-8738 report (DOJ Report) confirms the need to assess PATTERN for accuracy and bias. For example, reported data indicates PATTTERN will have a racially disparate impact, particularly on black males. As illustrated in the charts below, based on the DOJ Report, white males are far
fails to address a critical question that Congress determined should be addressed by fair and neutral rule-making, not by administrative fiat. 1601 Flab Anne, Room 700, Seattle, Waslalostoa 00101 - Menotti (206) S53-1100 Fax (206) 513-0120 56 of 61 EFTA00094081 Thomas R. Kane November 16, 2011 Page 3
rk, NY 1007 Tel (212) 417-8738 report (DOJ Report) confirms the need to assess PATTERN for accuracy and bias. For example, reported data indicates PATTTERN will have a racially disparate impact, particularly on black males. As illustrated in the charts below, based on the DOJ Report, white males are far
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