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Johny Fernandez: The New York
commercial financing disclosure

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law. You know, that has been a
big topic. We spoke about it

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last year, we spoke about it at
Broker Fair. It was supposed to

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intended to go into effect at
the start of the month. But

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there's been another delay.

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Sean Murray: Yeah, well, it was
originally, that's right. The

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New York financing. The New York
commercial financing disclosure

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law, was supposed to go into
effect starting January 1.

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However, at the end of last
year, I think around, what was

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it October, November, they
reached the conclusion that they

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were going to give everyone a
six month break, because they

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know that they hadn't given
anyone enough time to start

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implementing all the different
requirements. Also, they didn't

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let anyone know what all the
requirements were correct. They

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had put out a proposal. They had
solicited feedback on the

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proposal, it seemed like they
were confident that what they

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had proposed was just going to
be the law. That's what it

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seemed like, yeah. And there was
all these there was all these

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mix ups about they closed off
feedback, remember? Yeah, they

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were people.

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Johny Fernandez: People did not
know when, when to comment. They

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didn't know where to comment.
You know, some people that were,

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you know, in government were
just confused in general, people

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didn't know what's going on. So
it was a big, massive confusion.

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But we do know that yeah,
comments will be on the proposed

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regulation will be accepted
through December 20. Oh, yeah.

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December 20. So they were
accepted. Yeah. So they were be

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accepted until December 20. They
were last year last year.

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Correct. We're still we're in
2022. Last year, and now

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there's, you know, it's delayed
again. Yeah. So you're not a

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lawyer? I'm not a lawyer. We are
not lawyers, again, to to

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emphasize on that. But what does
this mean? It was delayed again.

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Sean Murray: So what's unique
about this particular delay is

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that they did not give a date
for when the law itself will be

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implemented. This, this change
was put out on December 31. I

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don't even know if it's up on
the New York State website yet.

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Basically, the I think it was
the Deputy Superintendent sent

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out a letter to a lot of lawyers
and CEOs within the the non bank

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finance industry, basically
saying, hey, we've read all your

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feedback. Yeah, we've got to,
you know, we've got a lot more

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to work out than we thought we
did. And so what they said they

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would do is that they were going
to issue a revised proposal

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sometime early in the new year.
That could be January, February,

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March. I don't know when they
didn't say when, and that

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everyone will have the
opportunity to comment yet

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again, just like they did last
year.

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Johny Fernandez: But but
hopefully, we're hoping that

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this time, there will be clear
instructions on the comments.

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Oh, yeah,

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Sean Murray: well, exactly.
Yeah. Last time, part of the

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problem was they didn't even
tell people how to comment,

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where to comment, who to comment
to? It turns out, we were the

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people that told everyone yeah,
who do you even talk to? And

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that's the original deadline had
passed. I didn't even know that

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by the time you and I found out
the deadline was over. Yeah. And

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then I reached out to him, and
they said, you could still you

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could still, you know, offers
some feed some feedback. Yeah.

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But I have a feeling that they
started getting a lot of

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responses after we published
that. And that's when they

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probably got so much information
that they were like, okay, wait,

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we really got to fix this up.
Because according to DFS, they

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said they actually reached out
to California's state

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regulators, because California
had a similar law that they had

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to implement. They're like,
Well, how did you guys do it?

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Yeah. And California had to tell
them, we couldn't do it. It's

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been four years in California
since they passed a similar law.

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Yeah. And California to this day
has not been able to implement

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it. Because it's too
complicated. Yeah. So I think

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that probably, and I'm just
speculating, I think that

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probably worried New York
State's regulators a bit that

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they're getting into something
that's a little bit more

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complicated than they first
thought. Yeah. And they said,

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Okay, let's, let's just make
sure we get it right. And, like,

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like I said, there is going to
be an opportunity to comment on

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a revised proposal, and then
there will be a new date given

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for when it will be implemented.
I don't know if that's going to

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be later this year. Next year
that we don't know there's been

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no dates given.

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Johny Fernandez: Yeah. So