Larry Roberts signed several decisions on Jan.19th well after 5pm as Principal Deputy Assistant Secretary. Under 25 CFR 151.12, the only decisions that are final are those by the Ass Sec or Sec. All others go to IBIA. Land can't go into trust until after exhaustion of administrative appeal. This is crystal clear in the regulation. The Transfers into trust are invalid based on the following: Washburn did not assign responsibility to a Deputy Assistant – Indian Affairs. Roberts assumed Washburn’s position as acting ASIA on January 1, 2016. Once Roberts’ position as Acting ASIA expired (210 days into 2016), he was back to being Principal Deputy ASIA. A Principal Deputy ASIA has NO authority to sign off on a gaming fee to trust or issue a decision on trust lands