I was going to start off by saying I'm not a lawyer, but of course I am.
As I understand it, the full panoply of the commission's enforcement powers is available to enforce breaches of the regulations. The status of a circular as a policy document has not, as I understand it, been tested.
Now, there's conflicting legal advice on this, but I'm aware that there's a view out there that the legal obligation, the absolute obligation, is annual payment, and the monthly obligation is something else. I would just say that all of the BDUs have paid monthly for a decade or more—12 years—and have remained current and have been good and faithful partners to us, and nobody has raised this issue before.