It is my understanding that as part of the CFR, the ADA was initially written as an ACT or Regulation but was not officially a law even though it could be enforced through the civil courts. Is this correct?

ANSWER: This is a legal question that should be referred to an attorney for a final answer.  The following is not a legal opinion.  The ADA is a law, 42 US Code  Chapter 126 known as the Americans with Disabilities Act of 1990, that has a basic outline for non-discrimination against persons with disabilities and directed by the US Access Board and the Department of Justice to promulgate Regulations and Standards for the enforcement of the ADA.