The NFATCA has posted a comment to 41p, requested a hearing and has some unusual arguments claiming must of the proposals and even some of the current procedure is not authorized by congress. IN addition, they have an interesting Legal Memorandum prepared by Stephen Halbrook that’s worth taking a look at.
His memo covers
I. NO AUTHORITY EXISTS TO REQUIRE FINGERPRINTS AND PHOTOGRAPHS OF “RESPONSIBLE PERSONS” OF TRUSTS AND OTHER ARTIFICIAL PERSONS