1 00:00:00.660 --> 00:00:03.000 Sean Murray: If you are a broker, guess what your life is 2 00:00:03.000 --> 00:00:07.830 going to change is not just a box on a contract, the DFS wants 3 00:00:07.830 --> 00:00:12.030 you to do some very specific things. Here we go. A broker 4 00:00:12.060 --> 00:00:16.260 shall not provide a recipient with a specific amount, rate or 5 00:00:16.260 --> 00:00:19.920 price quote, for commercial financing based upon information 6 00:00:20.250 --> 00:00:23.970 from or about the recipient until the broker transmits the 7 00:00:23.970 --> 00:00:28.260 disclosures required by another section of this particular 8 00:00:28.860 --> 00:00:32.310 regulation. So, you are not going to be, this is my non 9 00:00:32.310 --> 00:00:35.940 lawyer opinion, you are not going to be allowed to give a 10 00:00:35.940 --> 00:00:39.780 customer a price quote, until you've gotten that price quote 11 00:00:39.900 --> 00:00:43.230 from the founder or lender, and then you've given a special 12 00:00:43.260 --> 00:00:47.580 disclosure to the merchant upfront. And then after you give 13 00:00:47.580 --> 00:00:50.850 the price quote to that customer, you then need to 14 00:00:51.750 --> 00:00:55.860 provide evidence of transmission of the disclosures to the 15 00:00:55.860 --> 00:01:00.180 financer including the time of the transmission. Anytime you 16 00:01:00.180 --> 00:01:03.900 give a quote to a merchant, it must be reported to the funder 17 00:01:03.900 --> 00:01:08.100 or lender, exactly what you said to them. And when you set it, 18 00:01:08.280 --> 00:01:11.580 and the quote has to be has to come from the funders. That's 19 00:01:11.580 --> 00:01:15.000 what it says. So I know there's a tendency to look at someone's 20 00:01:15.210 --> 00:01:18.360 statements and say, let me just give you a quote based on what I 21 00:01:18.360 --> 00:01:20.400 have. And then we'll we'll submit your application and 22 00:01:20.400 --> 00:01:24.030 we'll find out for sure, this is kind of saying that you can't do 23 00:01:24.030 --> 00:01:28.080 that anymore. This quote has to come from the funder or lender, 24 00:01:28.290 --> 00:01:30.660 you then need to give them a very specific disclosure, the 25 00:01:30.660 --> 00:01:33.720 merchant, right and then after you give them a quote from the 26 00:01:33.720 --> 00:01:36.420 funder or lender, you then need to report it back to the funder 27 00:01:36.420 --> 00:01:40.980 lender and say, at this time 6:53pm I told him this specific 28 00:01:40.980 --> 00:01:45.300 quote, just to comply and if your broker is going to change 29 00:01:45.300 --> 00:01:47.550 the dynamic of the entire conversation