Thursday, February 29, 2024 8:54:54 PM
It really can’t be more clear that there are two phases of assessment; the first phase is 80 days, and the second phase is (implied) 70 days. And, if required, (because the application is missing information or needs clarification) a RFI is sent requesting the necessary information, while the 150-day clock is turned off.
I believe some people may be reading that as though the “if required” part applies to the second phase, but it doesn’t. It applies the the RFI, rather than the second phase. (so the RFI may not be required, but the second phase is required) Again, it’s not called an 80-day assessment, because the second phase is not optional.
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