1208                                             LAWS OF MARYLAND                                         Ch. 284

(2) THE CONVENIENCE OF BUYERS OF STATE LOTTERY
TICKETS AND SHARES AND OF THE HOLDERS OF A WINNING TICKET OR
SHARE.

REVISOR'S NOTE: This section is new language derived
without substantive change from former Art. 88D, §
8(j) and the first clause of the second sentence of §
7(b).

In subsections (a) and (b) of this section, the word
"regulations" is substituted for the former word
"rules", to conform to the revision of § 10-101(e) of
this article.

In subsection (a) of this section, the power to "adopt'
regulations of the Agency" is substituted for the
former language "amend, repeal, or supplement the
[regulations] from time to time ... in accordance with
the Administrative Procedure Act". The former
language, which was enacted by Ch. 269, Acts of 1979,
reflected the intent of that Act to shift, from the
Commission to the Director, authority as to the
adoption of regulations for the State lottery. In
doing so, Ch. 269 struck then Art. 88D, § 7(c) and in
its stead, enacted § 8(j) and also struck references
to the "[regulations] of the Commission" and
substituted "[regulations] of the Agency, as approved
by the Commission". The language in subsection (a) of
this section reflects that, as of this time, the
regulations of the Agency are the cumulative result of
the regulations that the Commission adopted initially
under former Art. 88D, § 7(b) and, before its repeal,
(c) and that the Director subsequently adopted under
former Art. 88D, § 8(j). This language also reflects
that, under the Administrative Procedure Act, the
repeal or amendment of a regulation is effected
through the adoption of a later regulation.

Also in subsection (a) of this section, the former
specific reference to compliance with the
Administrative Procedure Act is deleted as unnecessary
since that Act would apply in any event.

The first sentence of former Art. 88D, § 7(b), which
enabled the Commission to adopt regulations "in order
that a lottery shall be initiated at the earliest
possible time", is deleted as obsolete. The Attorney
General has opined that the power in former Art. 88D,
§ 7(b) was fully exhausted on. adoption of the initial
regulations. See 64 Op. Att'y Gen. 218, 224 and 228
(1979). However, the second sentence of former § 7(b)
specified certain limitations that the initial
regulations must include. It seemed unlikely that the
intent of the General Assembly would be satisfied if
those limitations later were removed from the initial