The DOL believes that the final rule’s withdrawal would not be costly or disruptive, but that perspective is inaccurate because it is measured from the wrong baseline. Any valid analysis of the final rule’s withdrawal must be measured in reference to the anticipated cost and benefits of the previous rule. As things currently stand, the final rule becomes effective on May 7, 2021, and will provide annual costs and benefits of the sort estimated in an impact analysis. The DOL’s proposal to withdraw the final rule would shift the country to a new state where those annual costs and benefits won’t exist. By way of example, if an economic stimulus package were to be passed and later Congress were to debate retracting the stimulus package before the checks get sent, any analysis for doing so would include a discussion of “lost benefits” to citizens who would have received those payments.