Tuesday, August 30, 2011

More on the Detrimental Impact of Too Many Rules

Disclaimer: I have written about this topic within the past three (or five) years.

I received an email today titled, "Requirement." The sender of the email is a man in whom I place a great deal of trust. I admire him because he is a thinking man who considers issues with efficiency and caution. He, however, is a player in an industry that is gasping its last feeble breaths, thanks in large part to silly, knee-jerk regulations that are applied across an entire industry, regardless of whether or not they mean anything or add to the work product.

It seems that a small cadre of consultants has been in serious breach of a specific regulation. The rule, handed down from the towers of wisdom, requires all consultants to clearly state in every report whether or not the consultant has ever worked on a specific project in any capacity in the past three years. (There is some debate about the three year rule - should you report for a five year period, lifetime, etc. One particularly inept consultant, the one who gets really excited about the rules and making sure they are obeyed and implemented, even suggested that if you mowed the lawn for someone involved in a specific project in 1987 then you are required disclose that in the report.) To be clear: I have written about this topic within the past three (or five) years.

I always include this statement in my letter of transmittal, right up front, so that my clients are clear about any past activities with respect to any given assignment. Turns out, that's wrong. The statement MUST be included in a certification (one portion of the report that bears signatures), not in the letter (which happens to be another portion of the report that bears signatures, but who's counting?). If a consultant does these things he or she is in complete compliance with regulations, unless a client requests that it be included in the letter.

Oh, and just to be sure, probably better make mention of your past experience with a particular assignment in the history section as well, as required by many clients and as interpreted by some of those who reside in the aforementioned tower of wisdom (And that particularly inept consultant, the one who gets really excited about the rules and making sure they are obeyed and implemented.). Also, best make sure that you describe any changes in your analysis and why you made said changes.

So, we now have the exact same sentence included in a single report in three separate places. Inclusion of this sentence in no way increases the reliability of a given report. It does not add to credibility to the analysis. It does not, in any way, have any impact on the conclusions derived for a given assignment. But it's in there, as required.

Certification: I, Thomas H. Humphreys, do hereby certify that I have written about this topic within the past three (or five) years. The specific date upon which I penned my last post pertaining to this peturbance was March 3, 2011. In my last discourse describing the disturbing detriments of too many directives I discussed the broad over-arching framework of too many rules. I still hold that opinion. This post, the one written today, is not a departure from my previous analysis, rather a more specific example of the broader problem, an elucidation of the sheer idiocy and voluminousness of regulations mandated by the committees that oversee a certain industry.




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