Even with a cursory reading, National Chartering is the successor to the Lenders Choice proposal the FCA announced on November 10, 1998. Issued as a proposed regulation, Lender's Choice would have allowed FCS associations to lend anywhere within the US. Rather than proceeding under well-established administrative law, which prescribes the process by which federal agencies establish regulations, the FCA is side-stepping the law by issuing a booklet that is tantamount to a regulation. By not issuing a new proposed regulation, the FCA avoids giving the public, specifically bankers and FCS associations, an opportunity to comment on its National Charter initiative.