And that can change in two seconds because of the latitude the DPA gives the POTUS. We talked about this ad nauseum yesterday.
The professors answer on twitter:
You dont think this is open ended enough to provide for such powers?
The President may prescribe such regulations and issue such orders as the President may determine to be appropriate to carry out this Act.
@steve_vladeck
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No. Because the regulations still have to be a reasonable construction of the authorities conferred by the Act itself.