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“Lots of people empowered to raise a question plus nobody empowered to give an answer plus no incentive for anyone to be the counterbalancing force in favor of hitting the organization’s goals” would be my hypothesis here.
If you have an organizational culture of risk aversion and you call your lawyer and ask “Does federal law allow us to X?” there is almost no X you can ask which will give you unambiguous forward motion.
This ends up ceding entire fields to statis not because progress is forbidden but because progress is known to be likely regulated, a status which can be true without progress actually being regulated at all.
And, popping a level up the stack, the reason why the organization has such a conflict here is because the organization does not genuinely institutionally believe that their stated primary goal overrules the goal which is theoretically secondary.
(Seriously try the home version of this game. The more details you add to X the more caveats your lawyer will add in response. "Does federal law allow you to speak?" "OF COURSE." "Does federal law allow an employee of a financial institution to speak?" "... Some caveats.")
("Does federal law allow an employee of a financial institution to speak during an election year?" "Some more caveats." "How about on a Tuesday?" "A red herring." "A Tuesday in February." "... Depends which Tuesday." "Does the hour matter?" "OF COURSE IT DOES. STOP TROLLING ME.")
