Originally Posted by
Gizmo-RCU
In most cases an agency will bring up a proposal to the law- making body and if they(congress in this case) thinks it a good idea they direct the agency to come up with guidelines. Does anyone actually think Congress would come up with
regulations entirely on their own, get serious!

Congress does not direct the agency to come up with guidelines, they can do that at any time because guidelines are not enforceable. Congress directs agencies to come up with regulations which are enforceable.