mained intact. Another soft spot in the bureaucracy was in CLC in Phase II, according to the Price Commission's Office of Compliance and Enforcement. That office believed CLC's insistence on reviewing and approving PC's requests for IRS investigation was more consumptive of time than productive of substance. When the checkpoint was removed in September 1972, OC&E noted that CLC had finally conceded that the Price Commission "was capable of making appropriate judgments and decisions relative to what matters needed investigation, how these investigations on available IRS resources."63 In the view of the Price Commission, the clearance procedure had never been necessary. But regardless of whether or not these supposed zones of softness in the bureaucracy actually existed-whether or not they delayed cases and procrastinated compliance action-the perception by participants in the compliance system that they were obstacles added to the difficulties in inter-agency relationships. In the final analysis, the Price Commission believed CLC was unnecessary in Phase II, CLC believed the Price Commission was unnecessary (or troublesome), and IRS believed all the policy bodies were unnecessary, at least operationally. In a sense, everybody wanted to be sheriff in Phase II, and nobdy wanted to be the deputy. In Phase III, CLC was clearly in charge; in Phase IV, IRS was the foreman for compliance action. Certainly in terms of minimizing inter-agency conflict, Phase IV had the preferable compliance structure. No assessment of management in a Program involving as many different agencies, offices and talented professionals as the stabilization program can possibly cite every problem and illustrate every "kink in the system." The problems of caseload, communications, and inter-agency relationships no doubt encompass most of the adversities that compliance management encountered in the various phases. If a price and wage controls program is going to adopt a basic structure and general purpose like that of the Economic Stabilization Program in 1971-1974, these problems will have to be addressed. They were neither incidental nor accidental, but rather were inherent in the fundamental scheme of compliance and enforcement. Changes of style, emphasis and personality in the various organizations could have subdued some of these problems, and specific operational measures could have removed others. But once the strategy of compliance and enforcement is cast (whether implicitly or explicitly), and once the structure of the program is set, the problems that management will face are the kind suggested here. Conclusion Let gentleness my strong enforcement be, -Shakespeare (As You Like It, II, vii) "Voluntary compliance" was the catchword of compliance and enforcement during the Economic Stabilization Program. Used more promiscuously than any other phrase, it denoted at once a goal to be reached, a policy adopted to reach that goal, and an instrument of policy. Although few who used the slogan bothered to define it, using it was sure to summon agreement from those otherwise in disagreement, since it was an article of faith among those who ran compliance programs. But it had at least two certain meanings. First, it was a name for the spontaneously generated obedience to price and wage rules which was assumed to rise from the breast of the nation like the chorus of a great hymn. In this sense, it denoted the "existing base" of compliance that all law-abiding firms and citizens were expected to furnish without the impetus of an enforcement program. This meaning of "voluntary compliance" contributed much to the style of enforcement programs undertaken in Phases II through IV. Second, the term referred to the correction of a price or wage violation, discovered by IRS, that a firm was permitted to make as in: "IRS got voluntary compliance from the Acme Rubber Duck Company." Strictly speaking, the compliance obtained in this way was not really "voluntary", since the firm's immediate motive for correcting the violation was that IRS had discovered it and would presumably apply a penalty if not corrected. In this sense, "voluntary compliance" actually meant a penalty-free sanction applied to a firm-an interval of time during which a violator could wash his own hands before IRS used a more abrasive soap. The procedure was used because it was thought to expand "voluntary compliance" in the nation the great goal of the Program. In fact, it did nothing of the sort, since compliance was obtained only through the threat of a penalty, and since any exemplary incentive for voluntary compliance by a firm's peers was lost if it was permitted to correct its violation away from public notice. This is not to say that this method of enforcing regulations was not desirable or effective. It was both. The litigation docket and case backlog for administrative sanctions were crowded enough without the added load of cases which could be effectively settled by IRS short of all the enforcement fireworks. And unquestionably some firms were not willful or serious violators, and deserved a second chance and a clear record: they benefitted from a quiet "voluntary compliance" settlement, and the Program benefitted from the attendant price reductions or refunds. But what was involved was not strictly "voluntary" compliance. The distinction should be made, if only because of all the hoopla that the primary meaning of the concept aroused. Huge emphasis was placed on voluntary compliance when the Program began because everyone realized that no army of enforcers was on tap to run down all possible violations. If the Program had proceeded on the assumption that few would comply unless forced to do so, the National Guard could have been mobilized and an enforcement effort of sufficient breadth would still not have been attained. So the hope that the vast majority of firms would comply with price and wage rules was father to the assumption that they would. At first, it was a good assumption. The evidence suggests that Phase I and the first several months of Phase II were greeted warmly by private citizens, as well as business firms who disliked inflation because their costs were rising. "Voluntary" compliance was forthcoming in a big way. But the last 18 months of the Program illustrate the danger of using an article of faith for a policy assumption. Compliance managers were still talking about voluntary compliance late in Phase IV, a year after public support of the program began to ebb visibly. They had to continue to invoke the concept, because it was indeed indispensable-just as metropolitan police have to assume that most people will not riot in the streets. But when the assumption begins to tatter around the edges, when the extent of compliance seems to shrink, something has to be done. When rioters do gather in the streets, the police will go out and try to maintain order. They will not sit in the stationhouse and express confidence that most citizens will comply voluntarily with antiriot laws. The point is simply this: the problem is not with the vast bulk of citizens who will comply whatever the temptations to riot or raise prices-the problem is the marginal citizen or firm who is not by nature a willfull violator, but who when conditions are appropriate will succumb to the notion that more can be had from violating the rules than from complying. Obviously something more than the assumption of voluntary compliance is needed, namely, an enforcement program. But the availability of such a program has to be coupled with a will to use it, and to use it visibly and swiftly when warranted. Any reluctance on the part of stabilization policy-makers in Phases III and IV to take strong enforcement measures, or to emphasize compliance programs, should be seen in the context of a Program that had dwelt heavily on the value and the safe assumption of voluntary compliance since its inception. In this way, the very concept of voluntary compliance as a philosophical basis for enforcement programs undermined the willingness to take stiff enforcement action-enforcement that may have been stiffer than contemplated in the best-of-all-possible-worlds of voluntary compliance. No phase in the Economic Stabilization Program suffered from a shortage of IRS investigations of business firms, price remedial orders, compliance spot-checks and other enforcement actions. But the number of these actions was not a true measure of program effectiveness. If it were, each of the phases would have to be called a success in terms of enforcement impact-and no informed observer can reach that conclusion. Phase I as a whole was marked by resolute compliance with the freeze rules, supported by an extensive if not exactly efficient enforcement effort. Phase II saw the Price Commission take on a busy enforcement schedule that helped to earn continued public support for price compliance. Phase III witnessed what most independent observers believed to be a collapse of serious enforcement intentions, though field investigations and remedial actions continued to be initiated at an active pace. Phase IV brought a relatively well-coordinated sequence of enforcement actions by CLC and IRS, which unfortunately never achieved the public visibility that an effective program would have needed. In the words of a November 13, 1973 CLC memorandum, ". . . we have suffered a bit too much internally as well as in front of the general public by not letting everyone know that we are exercising a compliance program for Phase IV." The reluctance to intensify the public visibility of compliance and enforcement in Phase IV was presaged in Phase II by CLC's attitude toward the Price Commission's pugnacious enforcement style. A former PC top official has commented ruefully on what he has termed CLC's admonitions in Phase II to the Commission to "run silent, run deep" in enforcing price regulations-a line of advice which ran counter to the Commission's predilection for "going after" major violators. Whether or not any stabilization agency in any phase was more or less aggressive about pursuing enforcement, and regardless of the motivation for any inhibitions, it can be said with reasonable certainty that compliance and enforcement during the Economic Stabilization Program were not as combative as they had the resources and opportunities to be. A more hawkish approach to enforcement in the Program would not necessarily have guaranteed price restraint in the economy, but it could have heightened the morale of IRS investigators and other personnel who carried out compliance programs. That in turn could have helped to minimize whatever intertia and managerial inefficiency troubled the program. But the imponderables are large in any equation between enforcement and price or wage behavior. As a general statement, any program of price and wage controls should make an early decision on how militant its enforcement effort will be, and that decision should be maintained as consistently as possible through the duration of the program. Consistency is not a hobgoblin when it comes to price and wage controls. The "now you see it, now you don't" sequence of applying mandatory controls, as one business news reporter described it, fostered uncertainty and confusion in the public and business communities about the Program's gravity and the durability of its rules. Alternately strong and weak pressure in the current from the enforcement spigot had much the same effect. With a succession of different compliancestrategies, a succession of different compliance organizations, and a succession of different regulations to enforce, the compliance and enforcement system was anything bút consistent over time. To the extent that "voluntary compliance" had any meaning as a goal or concept, its realization was frustrated by the interruptions in momentum that were caused by successively different rules, strategies and procedures. Reviewing the record of Phases I through IV suggests several normative propositions about compliance and enforcement: • Discrete compliance objectives should be defined and com- A separate entity and organizational focus should be estab- Management authority for enforcement actions should be unitary and centralized at one point in the Program; if decentralized field units are delegated major responsibility or operational powers, their lines of communication to the central authority should be unimpeded. • If multiple agencies are involved in compliance and enforcement for a single program, regular and mandatory coordinat |