Supplemental Comments on Part 1110 (Joint Trade Association)
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The Retail Industry Leaders Association (RILA) and the National Retail Federation (NRF) respectfully submit the following supplemental comments regarding the proposed amendment to the regulations governing certificates of compliance (CoCs) at 16 CFR Part 1110. 78 Fed. Reg. 28080 (May 13, 2013) and 79 Fed Reg. 15241 (July 3, 2014). These comments incorporate by reference the prior comments previously submitted by our respective trade associations1 and the joint RILA-NRF oral testimony and follow-up written statement made in connection with the CPSC’s September 18th Public Workshop.