I feel that the proposed increase in user fees for renewal of enrollment is
excessive (the increase for original enrollment seems reasonable). The Service
does a minimal amount of work in renewing enrollment: mailing out cards,
entering the returned cards' info into a computer system, and mailing out
renewal letters. It would appear appropriate, in any event, that the fee for
original enrollment (which includes many one time costs, such as a completed
questionnaire and some sort of a background check) would exceed the renewal fee.
Also, the Service should consider the impact of the increase fee on its
clientele: a 1000% increase over three years is a bit much. I feel a $100
renewal fee would be more in line with a) actual effort expended; b)
expectations of the public; and c) other similar licensing fees.
Comment on FR Doc # 07-05428
This is comment on Proposed Rule
User Fees Relating to Enrollment to Perform Actuarial Services
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