Our comment focuses on evaluating the DOL’s adopted economic impact analysis, but of equal importance is addressing the DOL’s justification that it must comply with legal precedent and previous subregulatory guidance when force-of-law rulemaking overrules both. Courts have a responsibility, established by the Chevron doctrine, to defer to the DOL’s force-of-law rulemaking. This deference includes incorporating regulatory changes into future case law, rather than simply relying on precedent developed under prior rules.