If shes deadly serious then why hasn't anyone been prosecuted yet? (same thing with her CMR940 bullshit, too, nothing really came out of that memo, either, although that is civil).
The fun thing is that is not what THE LAW says, that is only what the bullshit in her edict says. Her edict is NOT the law. I don't care if you're jesus christ or the MA AG, you can't just make up or append the law on the fly, unless the law in question enables that behavior or there is some other law which gives her authority to do this. She did this because she knew the dealers would fold in about 10 seconds and create a huge shitstorm.
-Mike