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Sean Murray: So we've been
talking a lot about the New York

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Commercial Financing Disclosure
law that's going into effect

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supposed to go into effect on
January 1, when they told us

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that they were fully intending
to move forward with that date

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as written into the law itself.
They told everyone that they

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basically have the option to at
least give a comment before the

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final rule. Self is final. And
they were like standby for

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information about how to comment
and like everyone's like, okay,

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great, because a lot of people
want to comment. And we were

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keeping an eye on how to do it,
too. We wanted to make sure

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everyone had that information.
And by the time I personally

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found it, they said that the
deadline had passed, the

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opportunity to comment had
already passed. And I missed it

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by like, four or five days, by
the time I found out how, you

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were supposed to comment. The
deadline was over. And it was

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very obscure. You were supposed
to email someone who was listed

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on the on the site. I'm like,
oh, you know, and they didn't do

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an announcement. You had to you
had to find it.

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Johny Fernandez: And usually,
you know, they said, they we're

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going to provide this
information, and.

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Sean Murray: Everyone was
waiting.

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Johny Fernandez: Everyone's
gonna be able to comment but.

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Sean Murray: They didn't tell
you. They didn't do any

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secondary announcement. Like,
here's, here's how you comment,

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they had to go and find it. And
by the time I found it, it was

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too late. And I thought maybe I
was the last person to know, but

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I put it out there. I asked
them, I said, Is there any other

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way to comment? And their like,
yeah, you can also email someone

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else. But they didn't tell me
that I was wrong about the

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deadline. And so I did write a
quick blurb that I shared all

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over social media telling people
It looks like the deadline has

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already passed. And, you know,
it's unfortunate, but here, here

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were the people you were
supposed to contact. And it

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turns out a bunch of other
people were also caught off

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guard, just like me, they were
waiting to find out how to

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comment standing by just
thinking they were just going to

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get you know, it's government,
thinking they were just gonna

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get around to and had it. And
they're like, oh, no, that that

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that time came and went already.
And I feel like that might have

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played a factor into what you
said that there is now a delay,

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because I don't think anyone
knew how they were supposed to

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comment. And they didn't have
ample time to do it. So what

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happened is, the DFS extended
the comment time to December 19.

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And it involves emailing someone
at DFS, their information is on

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our site, you can search, I
think, just DFS in a search bar,

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and the article should come up.
And I think I even have the

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email address of the person that
you should be talking to where

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you can comment on the New York
Commercial Financing Disclosure

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law, that's going to change
everything, whether you do small

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business lending, or merchant
cash advance, or factoring, or

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whatever it is.

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Johny Fernandez: I think, at the
end of the day, something that

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we've been stressing about is
that this is something that's

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gonna impact everyone, across
the board.

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Sean Murray: Everyone's gonna be
affected.

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Johny Fernandez: And I think a
lot of people they are like, oh,

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like, is it gonna affect me? Do
I follow like, whatever? Do I

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fall under this umbrella? And
yeah, if you're in this space,

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it definitely does impact you.
Yeah. So certainly something to

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keep your eye on. Whether, you
know, you just want to get basic

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information, whether you want to
comment, it's definitely

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something to stress and look
into.

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Sean Murray: And, you know, as
Johny said, there is now a six

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month delay. So the way that the
state is complying with the law

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statutorily is that it
technically goes into effect on

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January 1, but you don't have to
comply until six months after it

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goes into effect. So as of
January 1, it looks like the

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rule will be final, no one will
have any more say in it. And

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that six month period is not,
it's not really even necessarily

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like oh, we're delaying the law,
they're just giving you six

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months to prepare yourself to be
fully compliant with it, because

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the gap between the comment
period being closed, and the new

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year when it's supposed to go
into effect, we're talking about

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12 days with Christmas and New
Years in between, not a whole

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lot of time, if it's supposed to
create a uniform disclosure, you

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know, and calculate all types of
formulas. And so I think that's

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was was really the cause of the
the date being six months out

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for when it goes into effect to
comply. So we're all going to

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wait now for December 19, or a
few days thereafter for when

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they will announce the final
rule. But it's going to affect

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anyone who does business in
Small Business Finance in the

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state of New York. It's
something that if you do

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business in the state, you
should probably go and look it

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up and comment if you feel
confident in it or if you feel

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like it's going to affect your
your business because it's going

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to go into effect in the middle
of 2022.

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Johny Fernandez: Yup.