Abel, an advisory circular does not create law, it is only an opinion that has been circulated. If it was law, I believe it would be listed as a regulation or statue (sp?)
From Blacks Law dictionary
Advisory Opinion Law & Legal Definition
An advisory opinion is a formal opinion rendered by a judge, court, or law officer in response to a request for guidance from a legislative body, government official, or other party. It differs from a decision handed down in an adversarial proceeding in that is carries no binding effect under the law. An advisory opinion is given as a matter of courtesy, often by a state attorney general at the request of government officials. A private citizen cannot get an advisory ruling from a court and can only get rulings in an actual lawsuit. Advisory opinions may be cited as the correct interpretation of a law which is subject to ambiguous or untested application in a given situation.
I'm not trying to argue, just trying to get at the actual truth of this matter
Ronnie