; or (ii) the Commissioner has failed to observe procedures required by law in connection with the closure, consolidation, or new limitation on access. (5) The requirement of this paragraph is met in connection with a closure, consolidation, or limitation on access referred to in paragraph (1) only if such closure, consolidation, or limitation on access will not result in the total number of field or hearing offices of the Administration falling below the total number of such offices that were in operation on September 30, 2018. . (2) Effective date The amendment made by paragraph (1) of this subsection shall apply with respect to closures and consolidations of field or hearing offices and impositions of new limitations on access to such offices occurring after the cessation of the moratorium under subsection (a) of this section.