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Daryl, I understand your point, but I have some sympathy with Rich as well. FED wanted to move to something closer to the NCAA rule, but they couldn't just adopt that rule as it is (tried and true). So they came up with something that's difficult to interpret and apply.
One way out of the difficulty is simply to apply the NCAA rule that is the model for the new FED rule. I believe that's Rich's approach. I also believe that this is the direction that FED will ultimately take in sorting out the problems with their current rule.
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Cheers,
mb
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