HUD staff advised that, after submission to OMB, HUD made technical, editorial, and clarifying changes to the rule, which OMB also approved.
HUD made technical, editorial, and clarifying changes to the rule, which OMB approved, thanks to the HUD staff that advised that.
So punishing past corporate sins is not like fining everyone who was present when an accident occurred, but when it was reported, which seems both unfair and pointless.