Question 32 U.S.C. $3100 establishes the Paralegal Oversight Agency (FDA) for the purpose of regulating the paralegal profession. Section 100 states, in pertinent part. that the FDA may act only after a hearing on the record. The FDA would like to implement a rule that requires paralegals to attend a minimum number of seminars each yearto ensure that their training remains up-to-date. The Hearing Notice indicated the date ofthe hearing and also stated as follows: \"interested parties may submit proposed ndings 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 nal rule.\" State the applicable rulemeking procedure and explain why the notice of hearing is or is not decient