Brandon Van Grack, a former FARA chief now at the law firm Morrison & Foerster, predicted his former colleagues will be “very pleased” with the volume of responses and their level of detail - even if they might not agree with many of the comments criticizing the statute and its enforcement.

Laufman, who oversaw the FARA Unit at one time, said he was “heartened” by the responses, calling it “more than enough ammunition” for DOJ to work with as it works on new regulations. “I think the number of those submissions, and the nature and quality of the types of reforms people are recommending manifests a great yearning within the regulated community for greater clarity with respect to how the department administers and enforces FARA,” said David Laufman, a partner at Wiggin and Dana who submitted 12 pages’ worth of recommendations with his fellow co-chair of the ABA FARA Task Force. The details of the comments submitted offer varied perspectives on the statute and offer an array of recommendations, but pretty much every commenter appeared to agree on at least one thing: FARA is in serious need of fixes. The notice drew input from numerous corners - from the obvious sources, such as the co-chairs of the American Bar Association’s FARA Task Force and law and lobbying firms specializing in FARA or registered under the statute, to media organizations like OpenSecrets, think tanks such as the Quincy Institute, civil liberties advocacy groups, groups representing the nonprofit world and groups representing academic institutions.

TO THE FARA UNIT, WITH LOVE: Last Friday’s deadline for submitting recommendations to the Justice Department for its impending rulemaking on FARA regulations - the first substantial revisions to the Nazi-era statute in decades - has come and gone, and while it looked for a bit as though the comment period had inspired a lackluster interest in weighing in, the advance notice of proposed rulemaking drew a flurry of comments at the last minute, the nearly three dozen of which were finally posted to the federal register on Tuesday afternoon.

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