I keep a messy note on my desk that just says “rules are not a statute.” It sounds obvious until you watch a market try to price a future that can be rewritten by the next chair. That is the unease sitting under the latest push from House Financial Services Committee Chair French Hill. On October 7, 2026, the Arkansas Republican said progress at the Securities and Exchange Commission and the Commodity Futures Trading Commission still falls short of the permanent change only Congress can lock in. He wants the Digital Asset Market Clarity Act finished in the lame duck, and the clock he cited is brutal: the Senate has 22 scheduled session days between the November elections and the arrival of the next Congress in January.
Twenty-two days. Not twenty-two weeks. If you have ever tried to get five people to agree on a dinner reservation, you already know how thin that runway is for a bill this contested.
Why Agency Crypto Rules Still Cannot Replace A Statute
Hill’s line, carried in an October 7 interview, was plain. The agencies have moved. Their work still does not give the country the lasting framework a statute would. His preferred sentence is worth sitting with, because it is less about a single bill title and more about competitive position.
We need that permanent law change to make sure America is number one in digital assets and blockchain technology.
French Hill, House Financial Services Committee chair
I have found that markets hear “permanent” differently from lawyers. Traders hear it as “I can hire, sign a lease, and build a compliance stack without guessing who sits in the chair in 2028.” Lawyers hear it as jurisdiction, definitions, and private rights of action. Both readings matter. Agency guidance can calm a Tuesday. It rarely settles a decade.
Perhaps the most interesting aspect of this moment is how much has already been done without a new market-structure law. Chairs have speeches. Staff have interpretations. Comment files are open. And yet the political sponsor of the House bill is still saying the work falls short. That is not a small complaint. It is a structural one.
What “Falls Short” Actually Means In Practice
A rule written under existing authority can be narrowed, stayed, or replaced. A statute, once signed, has to be amended by another statute. That difference shows up in three places ordinary investors actually feel.
- Which agency supervises the venue where a token trades, not just the derivative written on it.
- Whether a platform’s registration survives a change in administration.
- Whether classification fights keep landing in court because nobody wrote the categories into law.
Hill is not claiming the agencies have done nothing. He is claiming they cannot finish the job Congress left open. In my experience, that distinction gets lost in headline shorthand. “Regulators are acting” and “the law is settled” are not the same sentence.
The Lame Duck He Is Betting On
His window is the session after the midterms and before the next group of lawmakers is sworn in. Members walk back into the chamber already knowing whether they are returning or leaving in January. Sometimes that knowledge loosens a vote. Sometimes it freezes one. Hill still hopes the Clarity bill can move in that stretch. Hope is not a whip count.
Twenty-two Senate session days sounds like a planning fact. It is also a negotiating fact. Every day spent on ethics language is a day not spent on jurisdiction. Every absence matters more when the calendar is this short.
The September Vote Was About Debate, Not Final Passage
It helps to be precise about what failed. Senate records from September coverage show the setback was a motion to open debate, not a final up-or-down vote on the text. On September 15 the motion drew 49 votes in favor and 50 against, with one senator absent. Supporters landed 11 votes short of the 60 needed to move forward.
That is a cloture problem, not a proof that half the chamber hates digital assets. It is still a real problem. You do not get to the amendments, the manager’s package, or a conference with the House if you cannot even start the debate.
Coverage on September 23 noted a procedural crack. Republican Senator Thom Tillis switched his vote to no and filed a motion to revisit the result. A revisit is not a promise. It is a door that has not been locked. Anyone who has watched the Senate for more than one cycle knows those doors can stay ajar for months and then slam on a Thursday afternoon.
The House Already Did Its Part, With Democratic Votes
The House passed its version of H.R. 3633 in July 2025 by 294 to 134. Seventy-eight Democrats were in that yes column. I keep coming back to that number because it undercuts the lazy story that this is a one-party hobby. A Senate text with material changes would still need the two chambers to agree before anything reaches the president. Passage in one house is a start. It is not a law.
If a Senate draft drifts far enough, the House vote becomes a historical footnote rather than a template. That is the quiet risk in every “we are close” briefing.
Ethics Language Is The Fight Nobody Can Skip
After the September vote, Democratic negotiators said ethics safeguards were still unresolved. Senator Angela Alsobrooks said she wanted restrictions covering the current president, future presidents, and members of Congress, while keeping her support for digital-asset legislation. That combination is easy to mock and hard to dismiss. Support for a market bill and distrust of self-dealing can live in the same person.
Republican sponsors told a different story of the same week. Their September 14 draft, they said, folded in 126 substantive changes sought by Democrats. The list they cited included ethics provisions, state attorney general enforcement, and Treasury authority tied to stablecoin-related deposit flight. One hundred twenty-six is not a rounding error. It is a rewrite wearing a familiar name.
Who is right about the negotiations? Both accounts can be partly true. A draft can absorb a long list of edits and still leave the one clause a key senator needs. I have watched smaller bills die on a single definition. This one has several.
| Open issue | What sponsors say moved | What critics still want |
| Ethics limits | Provisions added in the September 14 draft | Coverage of presidents and members of Congress |
| Enforcement | State attorney general role discussed | Clear consumer path, not only federal discretion |
| Stablecoins | Treasury tools on deposit flight | Rewards and payment treatment still disputed |
| Jurisdiction | Commodity path for qualifying assets | Bright line that does not collapse in court |
Read that table as a map of delay, not as a scoreboard. Every row can eat a session day.
What The Agencies Can Do Without A New Law
Hill’s October remarks followed announcements by SEC Chair Paul Atkins and CFTC Chair Michael Selig that their agencies would keep going on crypto regulation at the president’s direction. The CFTC track started earlier. In an August 20 account of its market-rule plans, Selig was quoted saying the agency would pursue market structure whether or not the bill passed.
That sentence is both reassuring and revealing. Reassuring, because a failed cloture vote did not freeze the building. Revealing, because it admits the agency intends to stretch current powers rather than wait for new ones.
Here is the boundary that matters if you trade, list, or custody. The CFTC already supervises derivatives, including crypto futures, options, and swaps. It can also go after fraud and manipulation in spot commodity transactions. What it does not have, under existing authority, is the same routine supervision of spot crypto exchanges that it has over registered derivatives platforms. Fraud policing is not the same job as day-to-day market oversight. Anyone who has dealt with a brokerage exam knows the difference in their bones.
How The Clarity Framework Would Split The Map
Under the proposed framework described in reporting on the bill, qualifying digital commodities would generally sit with the CFTC. Securities-related activity would stay with the SEC. The bill would also set registration requirements for certain digital commodity exchanges and other participants. That is the boring heart of the project, and the part companies actually budget for.
For American investors, the practical distinction is platform supervision. The regulator responsible for a venue depends on the products and the activity. Proposed legislation would hand the CFTC added authority over qualifying spot digital commodity markets. Without that handoff, a spot venue can sit in a gray zone: watched for fraud, not examined like a registered market.
Is that gray zone survivable? Yes. Plenty of volume already lives there. Is it a place you want to build a decade-long business? I would not bet the lease on it.
A Trail Of Agency Steps That Still Are Not A Statute
A September 24 look at the limits of agency crypto rulemaking logged several separate moves. None of them, on their own, creates the spot-market statute Clarity is written to supply.
- A March 17 SEC interpretation described five asset categories.
- An August proposal sketched crypto offering exemptions of $5 million and $75 million, still subject to public comment.
- On September 17 the SEC issued a conditional exemption for tokenized-stock trading.
- The same day, a CFTC crypto markets measure entered White House review at the preliminary rulemaking stage.
Stack those items and you get motion. You do not get a code section that tells a spot exchange, in durable language, who its primary supervisor is. Comment periods can be reopened. Exemptions can be conditioned, narrowed, or withdrawn. Preliminary review is exactly what it sounds like: early.
The five-category interpretation is a useful staff map. Courts are not required to treat a map as a property line. That is the gap Hill keeps pointing at, even if he would phrase it in committee English rather than trader English.
What a desk can rely on today: Derivatives registration: relatively clear Spot-fraud authority: real, uneven Routine spot-exchange exams: not the same regime Offering exemptions: proposed, not settled Tokenized-stock relief: conditional Statutory spot framework: still a bill
A Former Lawmaker’s Read Of The Same Window
Former Democratic congressman Tim Ryan offered a similar read of the remaining calendar in comments published September 24. Lawmakers could still reach a lame-duck deal, he said, if both sides returned to the table and actually conceded something. Ryan, a Shyft Policy Board member, named the unresolved pile: ethics, consumer protection, illicit finance, and stablecoin rewards.
He also said support for federal crypto rules stayed bipartisan even while the terms stayed disputed. That matches the House vote better than it matches the September cloture tally. Bipartisan interest is not bipartisan text.
Ryan’s sharper point, for anyone writing checks, was durability. Companies committing capital and hiring people need decisions that outlast a change in administration. Agency action can help while Congress argues. Firms making long-horizon bets need a framework that does not swing with the next appointment calendar. He also argued for consistent treatment of digital assets so businesses and customers are not forced to settle classification in one lawsuit at a time.
Agency action can steady a market for a season. A statute is what you underwrite when the season changes.
That is my gloss, not his wording. The underlying claim is his: regulatory decisions have to last. I think he is right, and I also think “last” is the word negotiators keep trading away for a headline.
Seven Empty Seats And A Thinner Commission Table
The same October 7 account described thinner leadership at both agencies. Seven commissioner seats were vacant across the SEC and the CFTC. Hester Peirce had announced her resignation from the SEC the previous week, leaving Atkins and Commissioner Mark Uyeda as the remaining members. At the CFTC, Selig was described as both chair and sole commissioner.
A sole commissioner can still sign. A two-member SEC can still move some items. Neither picture looks like a fully staffed commission doing contested policy with a deep bench of votes. Vacancies do not freeze markets. They do change how bold a rule can be, how fast an appeal lands, and how exposed a decision looks if a court asks who, exactly, constituted the agency.
Peirce’s departure matters for another reason. She had been one of the more consistent internal voices on digital-asset questions for years. Losing that voice in the same month Hill is begging for a statute is not a coincidence the industry should shrug off. Personnel is not policy by itself. It is the pipe policy has to travel through.
What The 22 Days Will Actually Be Spent On
Hill’s timetable puts the hard bargaining after an election that decides who comes back. Members enter the session knowing their own political half-life. That can produce strange coalitions. It can also produce absenteeism dressed up as principle.
If I were sketching the days, not as a whip but as a reader of past lame ducks, I would expect the hours to cluster around four arguments.
- Who is covered by ethics limits, and whether the text names offices or only future conduct.
- How stablecoin rewards are treated, and whether that fight hijacks the market-structure title.
- How much illicit-finance language banks and state enforcers will accept without turning the bill into a surveillance statute.
- Whether consumer-protection tools sit with the market regulator, a separate agency, or private plaintiffs.
None of those are technical trivia. Each one can flip a senator who already voted yes on the idea and no on the motion. The September math was 49. You need 60 to talk. The distance is not philosophical. It is eleven people, plus whoever was absent, plus whoever switches when the text actually moves.
Investors Are Pricing A Process, Not A Slogan
For a holder of bitcoin, ether, or a smaller token, the bill can feel remote until a listing disappears or a product launch slips a quarter. The remote part is the mistake. Venue supervision decides which disclosures you see, which surveillance shares data with whom, and which bankruptcy remote is actually remote. Classification decides whether a yield product is a security offering or a commodity service. Those are not Washington hobbies. They are the terms on the screen.
Consider the tokenized-stock exemption issued on September 17. Conditional relief can let a pilot breathe. It does not tell a broker-dealer, five years out, that the pilot has become a lane. The August offering exemptions, at $5 million and $75 million, are the kind of thresholds founders circle in pitch decks. Thresholds in a proposal are not thresholds in the Code of Federal Regulations, and thresholds in the Register are still not thresholds in statute. I keep repeating versions of that sentence because the industry keeps treating them as synonyms.
They are not synonyms.
Stablecoin Rewards And Deposit Flight Are Not Side Plots
Ryan put stablecoin rewards on the unresolved list. Sponsors pointed to Treasury authority on deposit flight as one of the Democratic changes already drafted. Those two phrases are aimed at the same fear from opposite doors. Banks worry that a reward-bearing stablecoin pulls deposits on a bad afternoon. Crypto firms worry that a ban on rewards kneecaps a product consumers already use as a payment rail. Congress has to pick a theory of harm before it can pick a rule.
Deposit flight is not an abstract macro slide. It is a community bank watching balances move to a token that settles in seconds and pays something the savings account does not. Whether that “something” is interest, a reward, or a marketing rebate is exactly the definitional fight. If the lame duck spends its best week on that definition, market structure waits in the hallway. If it ignores the definition, the banking votes may not be there at all.
I do not think there is a clever shortcut here. The side plot is the plot.
Illicit Finance Will Be Used As Both Shield And Sword
Every market-structure negotiation in this space eventually meets the illicit-finance paragraph. Supporters call it the price of legitimacy. Opponents call it a pretext for treating software like a bank branch. Ryan listing it among the open items is a reminder that the paragraph is not finished. A bill that cannot say, in operable language, what a platform must monitor and what a developer must not be forced to monitor will lose votes on both flanks.
State attorney general enforcement, one of the changes sponsors say they already accepted, cuts across this. State AGs move faster than federal agencies and answer to different voters. Giving them a lane can soothe senators who do not trust Washington. It can also create fifty interpretations of the same token. Clarity, as a brand, does not survive that outcome. The name of the bill is doing a lot of work it may not earn.
A Conference, If It Ever Happens, Is Another Bill
Even a successful Senate motion would not end the story. A Senate version with material changes still has to be reconciled with the House text that passed 294 to 134. Conference is where popular House provisions go to be traded. Ethics language that satisfied Alsobrooks could look different after House negotiators touch it. Registration thresholds that exchanges thought they understood could move by a comma.
Hill’s hope assumes not only 60 votes to debate, but enough agreement afterward to avoid a second war. Twenty-two session days is a tight box for one war. It is a cruel box for two.
What Companies Should Do While The Calendar Argues
Ryan’s advice to treat agency action as helpful but incomplete is the grown-up posture. A firm can map products against the five categories in the March interpretation, comment on the exemption proposal, and watch the conditional tokenized-stock relief for clues about how staff think about wrappers. It should not book those clues as settled law.
A practical split I use when talking to operators looks like this.
- Build compliance around powers the agencies already have: fraud, manipulation, derivatives registration, disclosure where a product is plainly a security.
- Treat proposed exemptions as scenarios, and model both the $5 million and $75 million paths plus a world where neither is finalized.
- Do not assume spot-exchange supervision will look like futures-exchange supervision until a statute or a final rule says so.
- Keep a version of the product that still works if ethics or rewards language kills a related provision.
That is not thrilling counsel. It is the counsel that survives a failed cloture vote. The firms that get hurt in these windows are the ones that staffed a launch date to a congressional rumor.
The Competitive Claim Is Doing Political Work
Hill’s “number one” line is a competitiveness argument wearing a legal brief. Other jurisdictions have spent the last few years writing crypto statutes, some clumsy, some narrow, some frankly promotional. The American answer has been a mix of enforcement, exemptions, and unfinished bills. You can believe the enforcement era corrected real fraud and still think the unfinished bill is a tax on serious builders. Both things have been true in the same quarter.
Does a statute automatically make the United States first in blockchain technology? No. Talent, capital markets, and energy costs do more of that work than a title page. A statute does something more modest and more useful. It tells a company where the referee stands. Without that, “number one” is a slogan you cannot underwrite.
Reading The Vacancies Against The Rulemaking Calendar
Seven open seats is not a footnote to the legislative story. It is a parallel story. Atkins and Uyeda can carry SEC items that do not need a fuller bench, and some items may not. Selig as sole CFTC commissioner can advance a markets measure into White House review, as the September 17 preliminary step showed. A preliminary step is not a final rule, and a final rule is not a statute. The stack is real. The stack is also short one kind of authority.
If nominations fill those seats before the lame duck, the agencies may look sturdier just as Congress is asked to act. If the seats stay empty, Hill’s argument gets an extra exhibit: even the administrative path is thinly staffed. Either way, the political incentive to “let the agencies handle it” looks weaker in October 2026 than it did when both commissions had fuller tables.
What A Reasonable Reader Should Watch Next
I would ignore victory laps and watch four mundane signals.
- Whether Tillis’s motion to revisit is actually scheduled, or remains a filed piece of paper.
- Whether ethics text names current officeholders or only prospective rules, because that single choice moves Democratic votes.
- Whether the CFTC markets item leaves preliminary review with spot-venue language that still admits its statutory limit.
- Whether the SEC exemption proposal draws comments that force the thresholds to change, which would reset the clock staff were hoping to run.
A fifth signal sits outside the bill. If commissioner nominations move, the “agencies will just do it” camp gains a face. If they do not, Hill’s permanent-law argument gets louder without him raising his voice.
A Note On What This Is Not
This is not a claim that every token deserves a federal license, or that every enforcement action of the last few years was theatre. Fraud cases do not become legitimate because a market-structure bill is late. The September procedural loss does not mean the House vote was fake. The 126 drafted changes do not mean Democrats were fully satisfied. Holding two incomplete stories at once is the only honest way to read this file.
It is also not a prediction that the lame duck will deliver. Twenty-two days is a fact Hill put on the table. Facts about calendars have killed more bills than hostile speeches ever did.
The Gap Between A Busy Agency And A Settled Market
Go back to the note on the desk. Rules are not a statute. The SEC can sort assets into five categories and still leave a judge free to sort them again. The CFTC can police spot fraud and still lack the exam manual it uses on a derivatives platform. A conditional exemption can open a door for tokenized stocks and leave the hinge attached to staff discretion. An offering proposal can float $5 million and $75 million and never become the on-ramp a founder needs.
Hill’s October argument is that this pile, however active, falls short of the permanent change he thinks the country needs if it wants the lead in digital assets and blockchain technology. You can disagree with the competitiveness boast and still grant the legal point. Permanence is the product Congress sells and agencies cannot fully counterfeit.
The Senate’s September math remains the obstacle in the way of that product: 49 for opening debate, 50 against, one absent, 60 required. Tillis left a procedural thread. The House left a 294 to 134 text, with 78 Democrats on the yes side. Negotiators left a dispute over ethics that reaches presidents and members, and a sponsor claim of 126 changes that did not close the gap. Ryan left a list, ethics and consumer protection and illicit finance and stablecoin rewards, that still reads like a agenda rather than a deal sheet.
Meanwhile the commissions are short seven seats, the SEC is down to Atkins and Uyeda after Peirce’s resignation, and the CFTC is down to its chair. That is a lot of absence for a season when everyone is promising presence.
How I Would Explain It To Someone Who Does Not Live In This Market
Imagine two referees who can throw flags for cheating, write memos about what the game should look like, and even run a trial league on a side field. They cannot, by memo, change the rulebook the league will still be using after they retire. That change needs the owners. In this analogy the owners are Congress, the trial league is the exemption file, and the side field is spot crypto. The flags are real. The rulebook is late.
People who trade every day already feel the side field. Spreads, listing rules, and which stablecoin a venue will touch all carry the uncertainty. People who only hear the speeches miss it, because speeches sound like decisions. A comment file is not a decision. A 49-vote motion is not a decision. A chair’s interview is not a decision. The decision is a bill that both chambers accept and a president signs, or it is another year of memos.
I would rather have the memos than silence. I would rather have the statute than the memos. Those preferences can sit together without turning into a press release.
The Election Does Not Pause The File
Hill was explicit that members will enter the post-election session knowing whether they are coming back. That knowledge cuts both ways. A departing senator can cast a vote they would not cast with a primary ahead. A returning senator can decide the issue is safer in the next Congress, with a different majority or a fuller commission. Nobody outside the cloakroom can price that cleanly. What can be priced is the scarcity of days.
Twenty-two session days also compete with everything else a lame duck carries: spending, nominations, the ordinary backlog. Crypto market structure is not the only folder on the desk. It may not be the loudest. Loud and scheduled are different traits. A bill can trend all week and never see the floor.
Where The House Text And The Senate Mood Diverge
The House vote showed that a sizable Democratic bloc will support a market-structure bill under the right drafting. The Senate mood, at least on September 15, showed that opening debate is a higher bar than a simple majority. Those facts do not contradict. They describe different institutions. Anyone blending them into “Congress is ready” is selling a cleaner story than the record supports.
Alsobrooks’s position is a useful specimen. She has backed digital-asset legislation and still wants ethics limits that cover the current president, future presidents, and members. A whip who treats that as a niche demand will miscount. A whip who treats it as a veto on the entire project may also miscount. The September 14 draft’s 126 changes suggest sponsors tried to meet the demand partway. The failed motion suggests partway was not enough for the 60.
There is a human tempo to this that spreadsheets miss. Negotiators get tired. Staff memos get longer. A single absent senator swings a tally that was already short. Tillis switching to no and filing to revisit is the kind of move that keeps group chats alive and leaves the official calendar blank. Alive is not the same as advancing.
Registration Is The Quiet Provision That Changes Business Models
Headlines linger on ethics and on which agency “wins.” Operators linger on registration. If qualifying digital commodity exchanges must register, the cost of being a venue changes. Surveillance obligations, custody standards, and who may intermediate a trade stop being competitive choices and become conditions of doing business. That is why some firms want the bill and some firms only want the speech about the bill.
The current split encourages a familiar arbitrage. List the derivative where the rulebook is mature. Leave the spot market in a looser perimeter, policed after the fact. Clarity, if it passed in something like the form described, would shrink that arbitrage for qualifying assets. Shrink is not the same as delete. Securities activity would remain with the SEC, and plenty of tokens will keep arguing they are neither, or both, until a definition catches them.
Court-by-court classification, the outcome Ryan warned against, is the expensive version of that argument. It rewards the party that can fund the longer brief. A statute does not end litigation. It gives the litigation a shared text. Shared text is an underrated public good.
Why The October Timing Matters More Than The Quote
Hill could have made this argument in July, after the House vote, or in September, after the motion failed. Making it on October 7, with the election weeks away and the session-day count already public, is a choice. It tells agencies their momentum is welcome and insufficient. It tells senators the sponsor has not folded. It tells companies the political risk did not expire when the procedural vote failed.
Whether that message moves a single vote is unknowable from outside. Messages rarely do. Texts do, occasionally, when they solve a senator’s specific problem. The specific problems on the table have names: ethics coverage, rewards, illicit finance, consumer tools, and the fear of deposit flight. A quote about being number one does not solve them. A paragraph that solves them might.
A Durable Framework Is A Hiring Decision
Ryan tied the legislative fight to payroll. I think that is the right scale. A compliance hire made against a proposed exemption is a bet that the proposal survives comment, review, and the next chair. A compliance hire made against a statute is a bet that repeal is harder than revision. Those are different bets, with different severance risk. Founders feel that in recruiting conversations even when they never say the bill number out loud.
Blockchain teams do not only compete with each other. They compete with sectors that already have boring, durable rulebooks. Boring is a feature. The sector asking engineers to move cities should be able to say, without a caveat the length of a law-review note, who regulates the cash market. It cannot say that yet. Hill is, in his way, admitting the same thing.
Durability test: if the chair changes, does the permission still exist? If the answer is "maybe," you do not have a statute yet.What Would Count As Enough, If The Lame Duck Surprises
Enough would be a text both chambers can accept that does at least four plain things. It would sort qualifying digital commodities toward CFTC oversight and leave securities activity with the SEC. It would require registration for the venues that intermediate those commodities. It would state ethics limits with enough specificity that the September objectors can vote yes without pretending. It would address rewards and deposit flight in language a bank regulator and a payments firm can both implement.
Enough would not require perfection. Perfection is how these bills die with everyone still claiming to support the goal. A flawed statute that can be amended is, for hiring and for custody design, often better than an elegant proposal that never leaves committee. I know that sounds like a low bar. The September tally suggests the bar is not low. It is simply located in a different room from the press conference.
If the lame duck produces only another agency announcement, the file returns to the place it already occupies: active, incomplete, and exposed to the next appointment. That outcome is available. It may even be the likely one. Likely is not the same as settled, which is the whole argument Hill is making while the days run down.
Holding The Thread Through January
Between now and the swearing-in, the useful posture is skeptical patience. Watch the revisit motion. Watch whether ethics text moves from talking point to operative clause. Watch whether spot-market language in any CFTC item admits what current law cannot do. Watch the vacancies, because a commission of two and a commission of one are not the institutions people picture when they say “the regulators have it covered.”
And keep the House number nearby, not as nostalgia but as evidence. Two hundred ninety-four to one hundred thirty-four, with seventy-eight Democrats, means a version of this idea has already cleared one chamber. The Senate’s 49 means a version of the debate has not. The distance between those numbers is the distance between a news cycle and a law.
French Hill is betting that distance can be crossed in a short, strange session, after voters have spoken and before the next Congress arrives. The agencies, by his own telling, cannot cross it for him. That may be the cleanest summary available on October 7. Rules are moving. The statute is not. Twenty-two days is not very many days to pretend otherwise.
