have a present effect: a 'general statement of policy' is one that does not impose any rights and obligations". Agencies likewise use "policy statements" to offer a unilateral quid pro quo or set a floor for agency procedure ("If you the public do X, we the agency promise favorable outcome Y. If you don't do X, you can still convince us to do Y by arguing the controlling law."). A near-certain indicator of a "statement of policy" is the word "should" rather than "must". Agency policy statements are not binding on courts, and therefore receive no Chevron deference, not even weak Skidmore deference. Guidance "Guidance" is a residual category for any rule issued by an agency but not in a formally-promulgated regulation. Most non-Chevron interpretative rules, and most general statements of policy, are issued as guidance. Only three classes of law administered by agencies are binding against members of the public: statute (as interpreted by the courts), regulations, and common law. Against members of the public, the default rule, embodied in the Administrative Procedure Act, 5 U.S.C. § 553, and elaborated in the Good Guidance Bulletin, is that subregualtory guidance documents do not have force of law, and do not bind the public. Perez v. Mortgage Bankers Association, 575 U.S. 82 (2015); e.g., 15 C.F.R. § 29.2. Nothing in agency guidance documents is binding against members of the public, except— Quotes of statutes or regulations (but they are binding because they are statutes or regulations, not because they are in the guidance document) Interpretations of genuine ambiguity in statute or regulation—until those interpretations have been confirmed by an Article III court, they are just the agency's best current interpretive guess, and are not firmly binding. In most cases, a member of the public is permitted to argue for an alternative interpretation (though of course the agency will often not entertain the suggestion; they may have to go to court to get it recognized). For this purpose, silence is not ambiguity. An agency cannot point to a silence in statute or regulation, and claim that that silence is license to gap fill the silence in any way that creates new obligations on the public or carves out from an obligation of the agency. Only statutes and regulations are binding against the public; therefore subregulatory guidance cannot have independent binding effect against any member of the public, it can only interpret ambiguity.