Jim Hamilton has a summary, Bainbridge commentary.  It's a good rule for accountants; companies are required to get "an independent third-party audit of due diligence at identified points in the supply chain."  It's also true that Commissioner Troy Paredes has invited judicial review of the rule, by, in his dissent, including some of the buzzwords of the Business Roundtable decision, as Bainbridge notes.  I only wonder if, given how poorly written that decision was, it will amount to much as precedent.  It would be kind of embarrassing to cite it if you are relying on it, instead of distinguishing it. 

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