These rule changes, as they pertain to the jurisdictions in which a registrant must report school attendance fails to take into account the vagaries of online learning and, as such, creates a catch-22. In today’s learning environment it is not uncommon for individuals to attend college in an entirely online setting, never setting foot on campus or in a class room.

However colleges that offer these services do maintain physical campuses with physical addresses that fall under physical jurisdictions.

Many if not most of these jurisdictions require a registrant to appear in person to update place of education.

This creates a catch-22 nightmare in which registrant students attending online classes in a state they have never been to and do not intend to travel to must now travel to that state to register school attendance, even if they have no other reason to be in that state.

If the purpose of these guidelines are to know where a registrant will be present, then requiring a registrant to update registration in jurisdictions where he or she will not be physically present is counter productive to the purpose of the registry by crowding it with useless information.

For the sake of simplicity and to avoid the kafkaesque “gotcha” situations that these guidelines claim to want to avoid, it is in the best interest of public safety and tax dollar allocation to create an exception to jurisdiction in the case of online only education in which, if a registrant attends school ONLY via distant/online/correspondence learning, that location is not considered a jurisdiction for the purpose of these guidelines and the registrant is not required to update registration unless he or she attends classes in person.

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