The Food Marketing Institute (FMI) is pleased to respond to the Office of Management and Budget’s (OMB’s) request for comments on the draft report to Congress on the costs and benefits of federal regulations. 67 Fed. Reg. 15014 (March 28, 2002). Specifically, this letter addresses OMB’s request for comments on reforms to specific regulations that extend or expand existing regulatory programs. In this regard, we would like to draw your attention to the regulation adopted in June 2000 by the Department of Labor that allows states to pay unemployment compensation to parents who choose to leave work on a temporary or permanent basis after the birth or adoption of a child. 20 CFR Part 604; 65 Fed. Reg. 37210 (June 13, 2000). The birth/adoption unemployment compensation regulation is an extreme extension of the agency’s authority in this area.

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