1 00:00:00.100 --> 00:00:03.800 I'm not sure if anyone was ready for it to come up out 2 00:00:03.800 --> 00:00:06.700 of nowhere as it did the law obviously passed a 3 00:00:06.700 --> 00:00:09.200 while back. So we already knew that the rules were coming. 4 00:00:09.200 --> 00:00:12.500 There has been the opportunity to comment on the proposed rules 5 00:00:12.500 --> 00:00:15.400 and originally when that proposal was 6 00:00:15.400 --> 00:00:18.200 put up people the feedback that the Department of 7 00:00:18.200 --> 00:00:21.500 Financial Services got there was 8 00:00:21.500 --> 00:00:24.100 a lot and they recognized them and said, hey we got 9 00:00:24.100 --> 00:00:27.100 to go back and really redo this whole thing. And I think 10 00:00:27.100 --> 00:00:30.100 people kind of got the feeling that there was going to be a lot of 11 00:00:30.100 --> 00:00:30.800 back and forth. 12 00:00:31.500 --> 00:00:34.500 Just like what had happened in California where there 13 00:00:34.500 --> 00:00:37.100 was kind of back and forth for maybe four or five years 14 00:00:37.100 --> 00:00:41.000 over what the final rules are going to be New York 15 00:00:40.200 --> 00:00:43.300 kind of eliminated all of that and really 16 00:00:43.300 --> 00:00:46.400 just got right to the point our confident that 17 00:00:46.400 --> 00:00:49.600 they have it right now. Yeah, and they put 18 00:00:49.600 --> 00:00:52.400 the rules up on their site on or 19 00:00:52.400 --> 00:00:55.600 they published it in the state Register. I should say they published 20 00:00:55.600 --> 00:00:58.400 it the rules the final rules in the state Register on 21 00:00:58.400 --> 00:01:01.800 February 1st, but they actually filed 22 00:01:01.800 --> 00:01:04.200 them on January 12th. So the rules 23 00:01:04.200 --> 00:01:07.700 were technically finalized on January 12th, but they weren't made 24 00:01:07.700 --> 00:01:10.700 available to the public in the state Register until February 25 00:01:10.700 --> 00:01:13.900 1st. And so now we have them. Yeah, and 26 00:01:13.900 --> 00:01:15.800 it's the new reality if you're wondering 27 00:01:16.700 --> 00:01:19.100 Wait a minute. What do I need to comply with these new 28 00:01:19.100 --> 00:01:22.100 rules? Because everyone needs time to yeah to figure out 29 00:01:22.100 --> 00:01:25.300 how they're going to move forward with it get ready to adjust and 30 00:01:25.300 --> 00:01:28.500 adapt and my understanding is because because I'm 31 00:01:28.500 --> 00:01:32.000 not an attorney is that the rules go into effect six 32 00:01:31.300 --> 00:01:34.800 months from the date that they're published in 33 00:01:34.800 --> 00:01:37.200 the state Register which would put it 34 00:01:37.200 --> 00:01:41.000 as around August of 2023. Yeah, 35 00:01:40.300 --> 00:01:43.600 for one people would have to comply that's my understanding of 36 00:01:43.600 --> 00:01:46.200 it. Obviously if you're out there check with an attorney. 37 00:01:46.200 --> 00:01:49.800 Yeah. It's interesting because so far we know that it's a 53 page 38 00:01:49.800 --> 00:01:52.400 rule book. That's gonna dictate. Well covered parties will 39 00:01:52.400 --> 00:01:55.700 be required to do and overall the department said 40 00:01:55.700 --> 00:02:00.200 that it received just 21 comments on the proposed 41 00:01:58.200 --> 00:02:01.800 revised rule. 42 00:02:01.800 --> 00:02:04.400 So 21 comments. That's it. Yeah, 43 00:02:04.400 --> 00:02:07.400 I was a little surprised when we read that when I 44 00:02:07.400 --> 00:02:10.200 read that because I thought it would be more common and more people 45 00:02:10.200 --> 00:02:14.400 kind of chiming in but they just had received 21 comments 46 00:02:13.400 --> 00:02:16.200 and the department has 47 00:02:16.200 --> 00:02:16.600 cons. 48 00:02:16.600 --> 00:02:20.600 Every comment received and has made several revisions to 49 00:02:19.600 --> 00:02:22.700 the rule book. And again, 50 00:02:22.700 --> 00:02:26.300 this is the final version of that and I 51 00:02:26.300 --> 00:02:29.100 think if you are interested in reading more about it, we have 52 00:02:29.100 --> 00:02:32.400 that part of the you know, we a link 53 00:02:32.400 --> 00:02:36.000 to that actual rule book on on the article on 54 00:02:35.400 --> 00:02:38.700 our website and it's 53 55 00:02:38.700 --> 00:02:41.500 pages. I mean, there's a lot to go over. I 56 00:02:41.500 --> 00:02:44.400 mean, I think the best recommendation is to sit 57 00:02:44.400 --> 00:02:47.100 down with your attorney and kind of go over 58 00:02:47.100 --> 00:02:50.500 what exactly it's gonna be required for you if you're 59 00:02:50.500 --> 00:02:53.500 doing business in New York May I add that you 60 00:02:53.500 --> 00:02:56.300 should forgive your attorney. If you're not currently an expert 61 00:02:56.300 --> 00:02:59.600 at all 53 Pages because the rules 62 00:02:59.600 --> 00:03:02.400 were just finalized. So I imagine 63 00:03:02.400 --> 00:03:06.000 they need time to study what the final rules are you before 64 00:03:05.300 --> 00:03:08.400 they're able to you know, give you advice as 65 00:03:08.400 --> 00:03:13.800 to how to move forward. Yeah you well, 66 00:03:12.800 --> 00:03:15.400 you know, I'd haven't 67 00:03:15.400 --> 00:03:16.200 read all 53 68 00:03:16.600 --> 00:03:19.500 is on my own but I did read there's this 69 00:03:19.500 --> 00:03:22.700 a addendum attached to the rules where the 70 00:03:22.700 --> 00:03:24.100 DFS kind of 71 00:03:25.200 --> 00:03:28.200 discusses the commentary it received and how 72 00:03:28.200 --> 00:03:31.200 it decided to proceed and one of the comments they had received out 73 00:03:31.200 --> 00:03:34.300 of the only 21 was that Brokers should not 74 00:03:34.300 --> 00:03:34.800 be covered. 75 00:03:35.700 --> 00:03:38.100 By the rules and they've actually 76 00:03:38.100 --> 00:03:42.000 said too bad they are. Yeah and 77 00:03:41.300 --> 00:03:44.200 what capacity again that's for an attorney 78 00:03:44.200 --> 00:03:47.900 to figure out but this will have you know wide reaching 79 00:03:47.900 --> 00:03:50.300 effects and I imagine will be similar 80 00:03:50.300 --> 00:03:53.500 to the rules in California overall. Yeah, 81 00:03:53.500 --> 00:03:56.500 you know, that's how the law itself was written. It was kind of modeled after the 82 00:03:56.500 --> 00:03:59.200 law in California. So I anticipate that it would 83 00:03:59.200 --> 00:04:02.100 be, you know, very similar in terms of what will be 84 00:04:02.100 --> 00:04:05.300 required going forward. Yeah. I think one thing also thinking to 85 00:04:05.300 --> 00:04:08.600 consideration is if you actually go online and you read these pages 86 00:04:08.600 --> 00:04:11.800 and this is just something I'm saying 87 00:04:11.800 --> 00:04:14.800 a lot is definitely don't just read 88 00:04:14.800 --> 00:04:17.100 it and assume, you know, what what you can 89 00:04:17.100 --> 00:04:20.300 do or what to do because there's a lot of information. I have some of 90 00:04:20.300 --> 00:04:23.000 the points of what it goes through but there's just so much 91 00:04:23.500 --> 00:04:27.500 and it's so specific that I think you 92 00:04:26.500 --> 00:04:29.200 know, if you the best 93 00:04:29.200 --> 00:04:32.300 thing is to hire an attorney and sit down and go over with it 94 00:04:32.300 --> 00:04:35.300 go over it with them specifically because 95 00:04:36.200 --> 00:04:39.400 um, just you know, it's it's a lot of information. It's very 96 00:04:39.400 --> 00:04:42.200 specific and I think we've said it 97 00:04:42.200 --> 00:04:45.400 before it's like it's very specific to New York. If you're doing business in New 98 00:04:45.400 --> 00:04:48.600 York and it's gonna look very different from what California has 99 00:04:48.600 --> 00:04:52.200 and what other states have because it's 100 00:04:51.200 --> 00:04:54.500 just a different Beast Within itself. 101 00:04:54.500 --> 00:04:55.200 So 102 00:04:56.500 --> 00:04:58.800 Yeah anything that's gonna say everybody. 103 00:05:00.300 --> 00:05:04.300 Just that New York is the major Metropolitan hub 104 00:05:04.300 --> 00:05:07.300 for the small business finance industry, 105 00:05:07.300 --> 00:05:10.700 right? That's undeniable. And before when 106 00:05:10.700 --> 00:05:13.900 the California rules went into effect. There 107 00:05:13.900 --> 00:05:16.100 was a segment of people in the 108 00:05:16.100 --> 00:05:19.800 New York Market that were deciding whether or not they should proceed 109 00:05:19.800 --> 00:05:22.400 in California as if it were some foreign market 110 00:05:22.400 --> 00:05:25.600 that was optional. Yeah, everyone recognized that 111 00:05:25.600 --> 00:05:28.500 California with the biggest state in the country by 112 00:05:28.500 --> 00:05:31.500 population. And that were there was a tremendous amount 113 00:05:31.500 --> 00:05:34.200 of business to be gained by continuing to do 114 00:05:34.200 --> 00:05:37.200 business in the state. Yeah, but still is almost 115 00:05:37.200 --> 00:05:41.000 like they were there was a remoteness or Detachment to it because many 116 00:05:40.100 --> 00:05:43.200 of the company many of the companies in the industry are 117 00:05:43.200 --> 00:05:46.700 in New York or even in Florida too, right? But 118 00:05:46.700 --> 00:05:49.400 here we are now on the home turf of 119 00:05:49.400 --> 00:05:52.500 the industry and if you decide to say, 120 00:05:52.500 --> 00:05:55.800 hey, I'm gonna sit the state out. It might be a little weird to 121 00:05:56.900 --> 00:05:59.300 to not be able to help a customer 122 00:05:59.300 --> 00:06:02.300 down the street right? Because if you're based on 123 00:06:02.300 --> 00:06:05.100 Long Island, you're based in Brooklyn, you're based in the city and you have that 124 00:06:05.100 --> 00:06:08.400 local business. It says hey I hear what you do. Can you 125 00:06:08.400 --> 00:06:11.500 help me out? You know, can you help me get some funding? It would 126 00:06:11.500 --> 00:06:14.200 be really weird to be like, oh sorry can't do business. 127 00:06:14.200 --> 00:06:16.900 Yeah here right, I think. 128 00:06:17.900 --> 00:06:20.500 For anyone who had not 129 00:06:20.500 --> 00:06:23.800 moved forward in California. This will be the impetus 130 00:06:23.800 --> 00:06:26.500 for them to be compliant with disclosure laws 131 00:06:26.500 --> 00:06:29.800 because I don't think new york-based funding companies are 132 00:06:29.800 --> 00:06:32.400 going to want to miss out on funding businesses 133 00:06:32.400 --> 00:06:34.300 in New York. That's my personal opinion.