1 00:00:00.200 --> 00:00:03.300 well you and I have been talking quite a bit about what's been 2 00:00:03.300 --> 00:00:07.500 happening, California, right California has 3 00:00:06.500 --> 00:00:09.500 you know recently, oh, we've 4 00:00:09.500 --> 00:00:10.800 recently put out a story talking about 5 00:00:11.600 --> 00:00:14.500 Just how difficult compliance with the California law 6 00:00:14.500 --> 00:00:18.000 might be so here. We were just directing everyone's 7 00:00:17.100 --> 00:00:20.700 attention to California mirror weeks ago. And so 8 00:00:20.700 --> 00:00:23.500 now you're bringing up New York. It's like oh yeah. Hey 9 00:00:23.500 --> 00:00:26.900 New York passed a law. Yeah, too. In fact, 10 00:00:26.900 --> 00:00:29.500 they they're disclosure law passed over a 11 00:00:29.500 --> 00:00:32.400 year ago. And it was technically supposed to 12 00:00:32.400 --> 00:00:35.500 already be an in fact. They wanted it the legislature 13 00:00:35.500 --> 00:00:39.900 wanted it to go into effect on January 1st 2022, 14 00:00:38.900 --> 00:00:41.500 but at the 15 00:00:41.500 --> 00:00:44.200 end of last year the state the 16 00:00:44.200 --> 00:00:47.400 regulator that was in charge of rolling the whole thing out with like whoa 17 00:00:47.400 --> 00:00:50.100 reading through what they're going to 18 00:00:50.100 --> 00:00:53.600 be in charge of yeah, and they're like this there's a lot there's a 19 00:00:53.600 --> 00:00:56.500 lot here that we're supposed to be in charge of we're not 20 00:00:56.500 --> 00:00:59.400 even an entirely sure we understand it. Yeah, and we're 21 00:00:59.400 --> 00:01:02.300 not sure if the covered parties the people who would 22 00:01:02.300 --> 00:01:05.400 be bound by the law can even do what 23 00:01:05.400 --> 00:01:08.500 we want them to we should probably ask them. Like, how did their 24 00:01:08.500 --> 00:01:10.800 business work first? Yeah before we start. 25 00:01:11.500 --> 00:01:14.100 Mandating collection and all that stuff and so 26 00:01:14.100 --> 00:01:17.500 there were the comment period at the end of last year. They 27 00:01:17.500 --> 00:01:20.200 asked people to give their own feedback and people were like, 28 00:01:20.200 --> 00:01:23.100 it's really kind of close to the wire you're asking for feedback and then 29 00:01:23.100 --> 00:01:26.500 we're supposed to what comply January first like, you know, this we're 30 00:01:26.500 --> 00:01:29.400 gonna have a week. Yeah, we get like a week. So I think it 31 00:01:29.400 --> 00:01:32.400 was like like the day before the day before 32 00:01:32.400 --> 00:01:35.200 New Year's I could be exaggerating the timeline around that time 33 00:01:35.200 --> 00:01:38.200 line of last week. Yeah the last week of the 34 00:01:38.200 --> 00:01:41.400 year over there like hey, you know that January 1st thing 35 00:01:41.400 --> 00:01:44.800 that we're supposed to do that's not gonna happen and for 36 00:01:44.800 --> 00:01:47.200 good reason because we were just not prepared to roll it out 37 00:01:47.200 --> 00:01:50.200 and we think that we have the illegal authority to wait 38 00:01:50.200 --> 00:01:54.000 until we know what we're doing before we're supposed to roll it 39 00:01:53.100 --> 00:01:57.000 out. So what the state said is that sometime in 40 00:01:56.300 --> 00:01:59.500 the first quarter of 2022, they're 41 00:01:59.500 --> 00:02:03.300 going to release an amended proposal for 42 00:02:02.300 --> 00:02:05.500 what the rules will be to abide 43 00:02:05.500 --> 00:02:08.200 by the New York disclosure law. So everyone said, okay. 44 00:02:09.400 --> 00:02:12.600 All right, we'll wait till sometime in 45 00:02:12.600 --> 00:02:15.200 the first quarter, which usually in government speak when 46 00:02:15.200 --> 00:02:18.100 someone says sometime in the first quarter, they usually mean the 47 00:02:18.100 --> 00:02:20.400 last day of the first quarter usually how it works in government. 48 00:02:21.200 --> 00:02:24.500 Everyone was waiting on their on their tippy toes, you 49 00:02:24.500 --> 00:02:27.400 know looking at the website hitting refresh emailing people 50 00:02:27.400 --> 00:02:30.200 in the government on March 31st billing. What's the 51 00:02:30.200 --> 00:02:32.800 deal? Yeah. What are we doing here? And the state was like 52 00:02:33.600 --> 00:02:36.200 Well, we're not really yeah, we're not really ready yet. 53 00:02:37.200 --> 00:02:38.400 You know, we'll get to it when we get to it. 54 00:02:39.200 --> 00:02:42.100 So time has just been elapsing. Some people 55 00:02:42.100 --> 00:02:45.200 have been upset that it's taken so long. We hadn't heard 56 00:02:45.200 --> 00:02:48.200 anything other people are thrilled because they're like, we don't really like the 57 00:02:48.200 --> 00:02:51.400 law to begin with right but the but I think the main problem was 58 00:02:51.400 --> 00:02:54.400 just nobody knew what was going on. Yeah, we know there's a law 59 00:02:54.400 --> 00:02:58.100 and what he's talking about it and we know how difficult California 60 00:02:57.100 --> 00:03:00.200 is going to be so like hey, what's what's going on 61 00:03:00.200 --> 00:03:03.800 with this New York? Anything was interesting because further New York period specifically 62 00:03:03.800 --> 00:03:06.100 there was this time when you said 63 00:03:06.100 --> 00:03:09.500 it's like, you know, it was supposed to go into effect, but then, you 64 00:03:09.500 --> 00:03:12.100 know, it was kind of like this pause period and kind of 65 00:03:12.100 --> 00:03:15.200 people kind of forgot about it people could you know, I didn't forget about it, but 66 00:03:15.200 --> 00:03:18.100 they put it in the back they put it in the back burner like we'll get to it when we get 67 00:03:18.100 --> 00:03:21.400 to it State hasn't even released an amended proposal yet. 68 00:03:21.400 --> 00:03:25.300 Well, I think it was August 25th. The 69 00:03:24.300 --> 00:03:28.200 state did release a the proposal 70 00:03:27.200 --> 00:03:30.400 to the Secretary of State but it 71 00:03:30.400 --> 00:03:33.500 wasn't published in the state Register or any everyone 72 00:03:33.500 --> 00:03:36.000 can easily access it until September 14th. 73 00:03:36.600 --> 00:03:39.900 So I saw it on the late evening of the 14th. How 74 00:03:39.900 --> 00:03:42.600 did I find it? I think that was one of your original question. 75 00:03:42.600 --> 00:03:44.000 How did Sean Murray find it? 76 00:03:44.800 --> 00:03:47.300 Well, I obsessively look for 77 00:03:47.300 --> 00:03:48.900 things every day. 78 00:03:49.800 --> 00:03:52.200 Since the beginning of the year, I have looked to 79 00:03:52.200 --> 00:03:55.600 see if there's been an amended proposal. They said the end of q1 that 80 00:03:55.600 --> 00:03:58.600 didn't happen. So I said maybe today maybe today maybe today maybe 81 00:03:58.600 --> 00:04:01.300 today is it there is there? Oh, yeah and 82 00:04:01.300 --> 00:04:04.500 turns out it was there one day in September. I'm like, hey, there it 83 00:04:04.500 --> 00:04:07.400 is. There's the amended proposal. So I I read 84 00:04:07.400 --> 00:04:10.800 through the commentary that the state regulator 85 00:04:10.800 --> 00:04:13.600 gave. I also briefly glanced 86 00:04:13.600 --> 00:04:16.200 through the proposal itself. I'm not 87 00:04:16.200 --> 00:04:19.900 an expert on what the language of it says. Yeah, but one 88 00:04:19.900 --> 00:04:22.600 thing to note is that the regulator kind of 89 00:04:22.600 --> 00:04:25.200 gave their own feedback and what they've been hearing and they're 90 00:04:25.200 --> 00:04:28.200 like some people are convinced that they can 91 00:04:28.200 --> 00:04:31.200 eliminate this law and make it go away 92 00:04:31.200 --> 00:04:34.300 and their feedback is basically like, hey, don't do any 93 00:04:34.300 --> 00:04:37.500 of this, right? Yeah, and that's not really helpful to them because by 94 00:04:37.500 --> 00:04:39.500 law they have to abide by it. 95 00:04:40.400 --> 00:04:43.400 So they also said that they've gotten some feedback that was 96 00:04:43.400 --> 00:04:46.700 constructive in helping them roll it out and they're 97 00:04:46.700 --> 00:04:49.300 thankful for that. But they're trying to do their the best 98 00:04:49.300 --> 00:04:52.400 they can to make sure that this is orderly they're not 99 00:04:52.400 --> 00:04:55.700 trying to ruin anything. Yeah, at least as far as what they've communicated. Yeah, 100 00:04:55.700 --> 00:04:58.400 they're trying to do this in the best way possible and they're appreciative of 101 00:04:58.400 --> 00:05:01.200 the constructive feedback that they've gotten they did 102 00:05:01.200 --> 00:05:04.400 release the new proposal as I mentioned and there's 103 00:05:04.400 --> 00:05:08.000 a new comment period meaning people have the ability 104 00:05:07.300 --> 00:05:10.400 to give additional comment, you 105 00:05:10.400 --> 00:05:13.200 know on the new proposal enter the deadline 106 00:05:13.200 --> 00:05:16.500 for that. It's October 31st Halloween. Oh, 107 00:05:16.500 --> 00:05:19.500 I didn't even yeah, it's Halloween the trick or treat trick 108 00:05:19.500 --> 00:05:22.100 or treat. That's it. So, all right, so I know when we 109 00:05:22.100 --> 00:05:25.300 spoke about California, it was definitely one of those things that you know, 110 00:05:25.300 --> 00:05:28.500 it's completely different than what we've seen in other states for 111 00:05:28.500 --> 00:05:31.200 New York. Obviously, this is the new 112 00:05:31.200 --> 00:05:34.100 proposals out and I briefly glance through it. I know 113 00:05:34.100 --> 00:05:37.500 they have like they have a breakdown of like what certain like, 114 00:05:37.500 --> 00:05:40.000 I guess they're interpretation of certain words of 115 00:05:40.500 --> 00:05:43.700 You know transactions and you have the competitors that 116 00:05:43.700 --> 00:05:46.300 some people you know, they're they're against it. 117 00:05:46.300 --> 00:05:49.800 They're opposed and obviously other people that are willing 118 00:05:49.800 --> 00:05:52.400 to help out. So overall Sean. This is 119 00:05:52.400 --> 00:05:55.100 a question that this is something that will impact 120 00:05:55.100 --> 00:05:58.200 everyone in the state of New York that works in the state of New York. A 121 00:05:58.200 --> 00:06:01.100 lot of this funds businesses here. Yeah. I don't even have to be here. 122 00:06:01.100 --> 00:06:04.300 This is this is you know, it's it's New York, so 123 00:06:05.200 --> 00:06:08.200 Should people be worried? I think that's the first question. I'll ask 124 00:06:08.200 --> 00:06:09.200 you well. 125 00:06:10.700 --> 00:06:14.100 I don't know if worried is the right term. So I common 126 00:06:13.100 --> 00:06:16.400 request that the state got 127 00:06:16.400 --> 00:06:20.200 was hey, we're already doing something really hard in 128 00:06:19.200 --> 00:06:22.300 California. Can you just make the law 129 00:06:22.300 --> 00:06:25.500 of the same so that we don't have to worry about doing 130 00:06:25.500 --> 00:06:28.700 something completely different here. Yeah, that's really hard too. 131 00:06:28.700 --> 00:06:31.400 Yeah, like where are you doing something really hard that already 132 00:06:31.400 --> 00:06:35.300 puts us up at you know to some high level standard. Can 133 00:06:34.300 --> 00:06:37.400 we just do that? And the state 134 00:06:37.400 --> 00:06:40.400 was sympathetic to that request? Okay. They 135 00:06:40.400 --> 00:06:43.600 actually the state liked what they saw in 136 00:06:43.600 --> 00:06:46.700 how California ultimately decided to move forward and 137 00:06:46.700 --> 00:06:49.500 they recognize the challenges and complying 138 00:06:49.500 --> 00:06:52.800 with that and they said hey we get it and if 139 00:06:52.800 --> 00:06:55.700 we could maybe we would roll it out the same way to 140 00:06:55.700 --> 00:06:59.000 make it easy for you. And because it is the high high, you 141 00:06:58.100 --> 00:07:02.100 know High bar to reach. However, the statute 142 00:07:01.100 --> 00:07:04.700 of our law is actually different than California 143 00:07:04.700 --> 00:07:07.300 is and we are stuck abiding by what 144 00:07:07.300 --> 00:07:10.200 the New York legislation says what, California? 145 00:07:10.600 --> 00:07:14.100 Us so because they're the difference in how the law was drafted. We 146 00:07:13.100 --> 00:07:16.500 unfortunately need to craft 147 00:07:16.500 --> 00:07:19.300 our rules in accordance with what the New York 148 00:07:19.300 --> 00:07:20.100 legislation says. 149 00:07:20.800 --> 00:07:23.400 That so, you know should people be worried. They should 150 00:07:23.400 --> 00:07:24.700 only be worried to the extent that 151 00:07:25.700 --> 00:07:28.900 if New York is all we're going to be extremely difficult for a 152 00:07:28.900 --> 00:07:29.900 California is already going to be difficult. 153 00:07:31.400 --> 00:07:34.500 If New York makes it their final rules vastly different. 154 00:07:35.500 --> 00:07:39.500 Well, then it could be a costly, you know 155 00:07:39.500 --> 00:07:42.400 process just to comply with right if you like do this 156 00:07:42.400 --> 00:07:45.400 in California do this in New York do this 157 00:07:45.400 --> 00:07:48.700 in Virginia do this in Utah and it's all different right? That 158 00:07:48.700 --> 00:07:51.400 sounds expensive. Yeah, it does. So, I mean 159 00:07:51.400 --> 00:07:54.800 obviously this there's a lot of questions and obviously 160 00:07:54.800 --> 00:07:57.300 there's that open comment period for the 161 00:07:57.300 --> 00:07:59.600 public for October 31st, so 162 00:08:01.100 --> 00:08:04.700 How does a company get ready for something like this? Should 163 00:08:04.700 --> 00:08:07.600 they I know we've talked about it for California, but should 164 00:08:07.600 --> 00:08:10.700 they sit back wait to see what happens start working 165 00:08:10.700 --> 00:08:14.300 on getting legal advice from from a legal 166 00:08:13.300 --> 00:08:16.100 expert. How do you kind of 167 00:08:16.100 --> 00:08:17.400 maneuver situation? That's 168 00:08:18.400 --> 00:08:18.900 like this 169 00:08:19.700 --> 00:08:22.100 I don't know how much how much you can 170 00:08:22.100 --> 00:08:25.700 do at this point to prepare yourself for compliance. I 171 00:08:25.700 --> 00:08:28.500 think now the one thing that you 172 00:08:28.500 --> 00:08:31.600 should be doing is it you're going to be impacted 173 00:08:31.600 --> 00:08:34.800 is to offer your feedback to the 174 00:08:34.800 --> 00:08:37.500 law to the proposal because maybe the 175 00:08:37.500 --> 00:08:40.800 state will consider it and make the change that will ultimately 176 00:08:40.800 --> 00:08:43.600 benefit your process. So I think that's 177 00:08:43.600 --> 00:08:46.300 all you really can do now until the final law is 178 00:08:46.300 --> 00:08:50.000 passed which by the way or the final rules are inactive which 179 00:08:49.300 --> 00:08:50.400 by the way 180 00:08:51.300 --> 00:08:54.300 If we're just looking at timelines now if the comment 181 00:08:54.300 --> 00:08:57.200 period for this proposal ends on October 182 00:08:57.200 --> 00:09:00.100 31st the state then needs time to 183 00:09:00.100 --> 00:09:03.500 either one issue the final rules. Yeah or 184 00:09:03.500 --> 00:09:07.500 two issue another proposal 185 00:09:06.500 --> 00:09:09.200 based upon a new round of 186 00:09:09.200 --> 00:09:09.900 feedback, right? 187 00:09:10.800 --> 00:09:13.500 Either of those things are unlikely to 188 00:09:13.500 --> 00:09:17.300 happen the day or the week after this common 189 00:09:16.300 --> 00:09:19.600 period ends so I would think 190 00:09:19.600 --> 00:09:22.300 that this law is not going 191 00:09:22.300 --> 00:09:26.000 to be in effect until at least sometime 192 00:09:25.500 --> 00:09:28.900 at least it started a middle of 2023. I 193 00:09:28.900 --> 00:09:31.500 would I would think it we're at least minimum nine 194 00:09:31.500 --> 00:09:34.400 months out from this going into effect. Okay, that's good 195 00:09:34.400 --> 00:09:37.100 to know and I think you know for those that want to take a look at the 196 00:09:37.100 --> 00:09:40.100 draft that want more information on you know, 197 00:09:40.100 --> 00:09:43.500 this the new proposal for the law. You can 198 00:09:43.500 --> 00:09:46.100 check it out online on the bank to come calm because we have the 199 00:09:46.100 --> 00:09:50.100 article there and then we have the links to all those different things online. 200 00:09:49.100 --> 00:09:52.200 So it's really quick you can like click it and 201 00:09:52.200 --> 00:09:55.200 it'll load up and these documents. You know, I one of 202 00:09:55.200 --> 00:09:58.400 them is about 10 pages. The other is about 55 80s that you can kind of 203 00:09:58.400 --> 00:10:01.200 grow through and look to see you know, how 204 00:10:01.200 --> 00:10:04.500 exactly it all breaks down and what they're what 205 00:10:04.500 --> 00:10:07.400 they're saying in the documents because I think it's also important 206 00:10:07.400 --> 00:10:10.200 for those people that are interested in looking at it and checking it 207 00:10:10.200 --> 00:10:10.300 out. 208 00:10:10.800 --> 00:10:13.400 To have an actual copy and see it. So, 209 00:10:13.400 --> 00:10:16.500 you know, if you you should you should also be worried 210 00:10:16.500 --> 00:10:19.400 if you had looked at what California is going to require and 211 00:10:19.400 --> 00:10:20.000 you had decided. 212 00:10:20.900 --> 00:10:23.400 That's not for me. I can't do all that. It's too 213 00:10:23.400 --> 00:10:26.300 much it too expensive New York will be I think 214 00:10:26.300 --> 00:10:29.000 even if it's not exactly the same in terms of 215 00:10:29.100 --> 00:10:34.200 the rollout, it will be similar in terms of the workload 216 00:10:32.200 --> 00:10:35.300 required to 217 00:10:35.300 --> 00:10:38.300 comply. So if California was is already 218 00:10:38.300 --> 00:10:41.400 too challenging for you for you. Then New York is probably 219 00:10:41.400 --> 00:10:44.700 going to be similar but at least I expect 220 00:10:44.700 --> 00:10:47.300 this is Sean Murray's prediction not any type 221 00:10:47.300 --> 00:10:50.500 of official timeline, but if the proposal common period ends 222 00:10:50.500 --> 00:10:53.400 on October 31st, I can't see this law going 223 00:10:53.400 --> 00:10:56.700 into effect until at least at the very earliest the 224 00:10:56.700 --> 00:10:59.500 middle of 2023. So there is time to worry 225 00:10:59.500 --> 00:11:02.900 about all that. I think people should be worried about California get 226 00:11:02.900 --> 00:11:05.100 your California stuff. I'll figure it 227 00:11:05.100 --> 00:11:06.800 out now. That's what you should be focused on.