32 U.S.C 100 establishes the paralegal oversight agency (POA) for the purpose of regulating the paralegal profession. Section 100 states in pertinent part, that the POA may act only after a hearing on the record. The POA would like to implement a rule that requires paralegals to attend a minimum number of seminars each year to ensure that their training remains up to date. The hearing notice indicatd the date of the hearing and also stated as follow: "interested parties may submit proposed findings and conclusions. However, no proposed rule exceptions will be accepted since the POA has already made a determination in this regard that will be included within the final rule." State the applicable rulemaking procedure and explain why the notice of hearing is or is not deficient.