The quoted passage says they will review complaints. The letter that set this off contained no complaints.
So they're already operating outside their own guidelines. Then there's the issue of a fine, which Commissioner Simington says the commission can't levy.
Define "can't." How many things "can't" a president do that have been done in the past six weeks anyway?
As for whether the letter contained no complaints, it's not unexpected to see our government bend or break longstanding rules to do what it wants right now, is it? It seems the rules are outweighed by "intent" at so many levels in this administration. So it's fair to ask, what is the intent of this?