Posts tagged ‘Marijuana’

Updated Guidance Issued on Hemp Banking

Given the SC decisions and pandemic news, you may have missed that earlier this week, the National Credit Union Administration (NCUA) and FinCEN issued updated guidance on regulatory expectations for financial institutions that provide banking services to hemp-related businesses.

For those of you who have followed the issue closely – and I know many of you out there have – the updates should not contain any surprises as you develop your Bank Secrecy Act framework (BSA) in states like New York, where hemp production is legal.

In December of 2018, Congress passed legislation removing hemp from the most restricted category of the Controlled Substances Act and making hemp production and sale legal in states where hemp production is legal. This is in contrast to hemp’s cousin, marijuana, which remains illegal in a matter of federal law, even as it has been legalized in states across the country. The federal government has issued temporary regulations and is now in the process of reviewing state plans to ensure compliance with federal law.

The FInCen guidance demonstrates how much easier it is to offer hemp baking services in states where hemp is legal. Most importantly, your credit union does not have to file a Suspicious Activity Report (SAR) simply because your member is involved in a hemp business, as it is obligated to do if it is taking the risk of providing banking services to marijuana related businesses in legal pot states.

But even with its legality, servicing hemp-related businesses requires increased due diligence depending on the size and complexity of the business with which you are dealing. For example, the only difference between marijuana and hemp is its level of THC (.03 versus .04). Does your credit union have the ability to spot those businesses which aren’t making this distinction and to file the appropriate SAR? And those pesky Beneficial Owner requirements can be much more difficult to comply with if you are dealing with one of the larger, more sophisticated companies engaging in the large-scale manufacturing of hemp.

Now you can go back to thinking about how you are going to deal with employees who travel to one of those states subject to a NYS quarantine.




July 2, 2020 at 9:51 am Leave a comment

Can Your Employee Use Medical Marijuana At The Credit Union?

Since 2014 when New York legalized the use of marijuana for medical purposes, lawyers, HR professionals and employers have grappled with how best to reconcile two provisions of New York’s law which seem to be in conflict with one another. On the one hand, § 3369(2) of New York’s Public Health Law stipulates that a certified patient authorized to use marijuana shall be deemed a disability under New York’s Human Rights Law which bans discrimination against the disabled and mandates that employers provide employees reasonable accommodations to do their jobs.

Conversely, this same subdivision goes on to explain that it does “not bar the enforcement of a policy prohibiting an employee from performing his or her duties while impaired by a controlled substance” or put the employer in the position of violating Federal Law.

New Jersey also authorizes the medical use of marijuana with provisions similar to New York’s. A recent decision by its Supreme Court, while not binding in New York, could be used as persuasive authority by future employees claiming to have been discriminated against by their employers. I would certainly take a look at this case and consider whether the type of activities performed by your credit union employees justify policies that you may have regarding the use of marijuana in the workplace.

In Wild v. Carriage Funeral Holdings, Inc., a funeral director came down with cancer in 2015 and was prescribed marijuana under New Jersey’s Medical Use Law. One day he got into an accident while driving a company vehicle. He went to the emergency room and explained that he had marijuana in his system because of his cancer treatment but the doctor was unconcerned because he was clearly not impaired. Nevertheless, he was fired for violating the corporate policy against using drugs during work hours, a policy with which NCUA’s employees are all too familiar these days.

He sued claiming that he was lawfully using marijuana and he was being discriminated against because of his medical disability in violation of NJ law. The lower court disagreed because of a provision of the New Jersey Compassionate Use Act that “nothing” requires an employer to accommodate a medical user of marijuana. The case eventually found its way up to the New Jersey Supreme Court. In a brief decision, it held that it was obligated to interpret New Jersey law in a way that reconciled the two provisions. It ruled that “The Compassionate Use Act does not have an impact on the plaintiff’s existing employment rights. In a case such as this, in which plaintiff alleges that the Compassionate Use Act authorized his use of marijuana outside the workplace, the Act’s provisions may be harmonized” with New Jersey’s anti-discrimination laws.

Think about the impact that this decision has for those of you who have branches in New Jersey. Most importantly, you should make sure that your policies don’t discipline an employee simply because he or she is lawfully using marijuana. The case also raises an interesting issue that employees also need to consider. In this case, there was documented evidence that the employee was not impaired. Would the outcome have been different if the employee was impaired? And if so, how are employers going to make the distinction between an employee with marijuana in his system and an employee with marijuana in his system who is impaired? These are interesting questions that we won’t know the answer to for several years. But in the meantime, your policies have to be drafted in consideration for these questions in any state which authorizes medical marijuana use.

March 12, 2020 at 11:27 am Leave a comment

Six Take-Aways From CUNAs GAC

Back from another year at CUNAs GAC. Every year I try to highlight some themes that emerge so here is my list of the six (6) things I learned at this year’s conference:

    1. Get those DORs done. Don’t be surprised to see NCUA taking a tougher approach to your credit union when it comes to following up on Documents Of Resolution. One of the big takeaways from the report of NCUA’s Inspector General about the collapse of the NYC taxi credit unions is that NCUA should have acted more promptly to enforce long standing DORs. Anecdotally I talked to a lot of credit union people and some of them said they are already seeing this trend.
    2. Taxi medallions are an even bigger issue than I thought they were. It would have been impossible to be at the conference the last few days without hearing about taxi medallions. This has not been true over the last few years. Both Chairman Hood and Board Member McWatters defended the agency’s decision to sell the medallions to a private equity firm, just as New York State was beginning to focus on ways to stabilize the medallion market. The big questions that remain are: How much flexibility are the new medallion owners going to extend to troubled borrowers? How much is the sale going to impact the sale price of medallions? And precisely why did NCUA feel that now was the best time to sell off these assets?
    3. Alice Through the Looking Glass and the CFPB. In a presentation to the conference, CFPB director Kathy Kraninger laid out an ambitious agenda on issues ranging from qualified mortgages to payday loans even as her own bureau refuses to defend the constitutionality of its leadership structure in a case pending before the Supreme Court. I’m telling you folks, when it comes to the CFPB, be careful what you ask for. Do you really want to wake up in a world in which the legality of all those mortgage regulations you have been implementing for the last 10 years are in doubt?
    4. I know subordinated debt isn’t the most exciting issue but I continue to believe that it is one of the most important facing the industry. The Association will shortly be coming out with a survey seeking feedback on the pending NCUA proposal which would allow complex credit unions access to secondary capital for purposes of meeting their risk based capital requirements while at the same time codifying guidance making it more difficult for low income credit unions to access subordinated debt. The agency has to see if it can balance these competing concerns in a way that does not exacerbate the differences between big and small credit unions.
    5. The more things change, the more they stay the same. There are so many issues on which there should be a bipartisan consensus but Congress is still unable to get things done. I’m thinking about data security and marijuana banking, in particular. We all know that there is a huge political divide in this country; I wonder how many people realize that this perpetual ideological warfare hurts industries and consumers regardless of what party they belong to.
    6. If there is a better politician in New York than Senator Chuck Schumer, I have not met him.


February 27, 2020 at 9:33 am 1 comment

Key Federal and State Proposals Rolled Out

Well, the holiday season is officially over. Judging by the amount of information I want to give you in today’s blog, it’s clear that our policymakers are hitting the ground running. Remember, this is an election year.

Let’s start with some federal guidance.

The NCUA released its annual list of supervisory priorities. Close your eyes and guess what NCUA has listed on their agenda for this year. You got it. The BSA compliance! Listen, I understand that few statutes are as important to properly implement, but if there is a credit union out there that doesn’t understand the importance of BSA and have a grasp of how to comply with it, that credit union has issues that a regulatory guidance can’t help with. What I am surprised by is that Libor is so far down on the list. If I were making the list, my top priorities would be cybersecurity, business continuity, which should be viewed as opposite sides of the same coin, potential liquidity risks- because the ongoing need of the Fed to prop up overnight lending facilities continues to scare the bejeebies out of me, and our good friend CECL, because I don’t think credit unions should in any way be encouraged to ignore implementation issues before it’s too late.

As painful as this is for me to admit, as between my priorities and NCUA’s, it makes sense to follow NCUA’s list.

Supervisory Guidance Issued

A regulation which has flown under the radar has been one finalized by NCUA in September intended to assist credit union supervisory committee audits by providing a more concise framework and explanation for minimum audit requirements. Yesterday, the NCUA issued a guidance complimenting this regulation, which succinctly explains what these minimum obligations are. Anyone involved with the supervisory committee should take a look. I of course have some opinions about this as well, but I still have much to talk about today, and I’m in too good of a mood to get hate mail.

Governor Unveils Ambitious List of Financial Services Initiatives

I’m going to go out on a limb here and say that the Governor’s 10th list of legislative priorities for this year’s New York session includes the most comprehensive list of priorities that could impact credit union operations since he was first elected. In addition to the issues he addressed in his State of the State, which included a pointed criticism of banks for not providing services in many of the areas that need them most, his book includes several priorities which we will be scrutinizing once they take legislative form. Among the proposals that caught our eye is one dealing with reporting suspected elder abuse; further strengthening of state law banning unfair and deceptive practices; a state-level crackdown on robo-calls; and enhancing the oversight powers of the Department of Financial Services.

In addition to the issues directly dealing with financial service issues, Cuomo once again called for the legalization of the sale of marijuana for recreational use and even wants to create an institute for the study of hemp and marijuana within the SUNY system. I was chatting with a longtime colleague and lobbyist after the presentation, and he pointed out that one of the reasons you may actually see agreement on this measure is the State’s fiscal deficit. The reality is that the state can plug in estimates of projected tax revenue to help fill the gap.

Believe it or not, there’s even more, but I think you have better things to do with your time than engage in a one-sided conversation with yours truly. That being said, as many of you already know, you can always e-mail me or give me a call if you want to follow up with anything I’ve mentioned.

Have a great day.

January 9, 2020 at 9:36 am Leave a comment

Hemp Regulations Bring Banking Issues to the Forefront

On October 29th, the USDA issued interim final rules providing a framework for the legal protection and distribution of hemp in states that choose to legalize it. The long awaited regulations bring about a new stage in what promises to be a phonetic period for compliance innovation as financial institutions begin to provide banking services for products related to marijuana.

What exactly is being legalized?

Up until recently, the distinction between hemp and marijuana did not matter. Both were classified as Schedule I drugs under the Controlled Substances Act. In the 2018 Farm Bill, Congress declassified hemp and allowed it to be produced in states choosing to legalize it. The key difference between hemp and cannabis sativa is the level of THC contained in the leaves of these closely related plants. A THC level in excess of .03 is considered marijuana, while anything below that is considered hemp.

Last week’s regulations provide the framework that states like New York need to start developing the industry consistent with the federal guidelines. Many of us who have followed the issue closely have been surprised that the USDA did not move more quickly to promulgate the proposed regulations. The USDA got the message because it took the unusual step of issuing interim proposed final regulations. This means that there is now a legal framework for states to begin submitting their hemp regulation plans, even as the USDA accepts comments on these proposed regulations. Remember, we are dealing with a crop, and farmers need time to plan in advance of the growing season.

We should also expect a flood of additional guidance from banking regulators now that the USDA has taken this important step. The NCUA issued this initial guidance in August 2019, in which it promised to “issue additional guidance” once the USDA’s regulations are finalized. NCUA should start issuing that additional guidance even though it can still be modified.

On the state level, New York has advocated for financial institutions to provide financing for hemp farming since 2014. The next step is for the state to issue a proposed plan to the USDA. One issue which I am researching and will update you on in a future blog is whether the state has to pass legislation legalizing hemp production beyond the 2014 pilot program.

For those of you who might be interested in providing banking services for hemp producers and hemp related businesses, now is the time to finalize your compliance plans. These plans will be more difficult to implement on an ongoing basis than they will be to put down on paper. For example, since the distinction between hemp and marijuana comes down to the THC level, it is absolutely crucial that any business you are dealing with have appropriate procedures in place to monitor its plants and dispose of marijuana.

Finally, even if you have no desire to get involved with this business, it will impact your credit union. I expect your typical community farmers market to become a hotbed of local producers using hemp as a key ingredient in their products. When these local businesses come to open an account, what procedures are you going to have in place to ensure that their products are legal? These and other questions promise to make this a subject of legal and compliance debate for years to come.

November 5, 2019 at 9:13 am 4 comments

Overdraft Confusion Continues

It’s not like litigation over overdrafts is new. Nevertheless, litigators, banks and credit unions continue to play a game of legal chicken when it comes to debating just what account agreements mean.

The latest example of this confusion comes courtesy of Navy Federal Credit Union which decided to settle a class action lawsuit brought against them in California alleging that it violated its account agreement. An issue in this case was the following language explaining that “an overdraft occurs when you do not have enough money in your account to cover a transaction but we pay it anyway.”

What’s so confusing about that? Well, in an earlier decision decided by the Court of Appeals for the 2nd Circuit which has jurisdiction over New York – Roberts v. CapitalOne, N.A. 719 Fed. App. !x33 2017 – the court held that plaintiffs could bring a claim for breach of contract as well as deceptive practices under New York law because the language is reasonably susceptible to two different interpretations. As the second circuit explained “it is equally reasonable to understand the term “Overdraft” as referring to Capital One’s election to make a payment, which would occur at the time of authorization (as asserted by Roberts), or as referring to the payment itself, which would occur at the time of settlement (as asserted by Capital One). Because this fundamental definition is “subject to more than one reasonable interpretation,” it is ambiguous.”

I’ve said it before and I’ll say it again there’s been enough legal guidance on this issue to avoid costly litigation or at least put your credit union in a darn good position to win it. Check your agreement if you haven’t done so already and see how it measures up against these and the other cases I have referred to periodically.

New York Not Going To Pot

In yet another example of why it’s a good thing I don’t bet for a living, it appears that New York will not be legalizing recreational marijuana before the end of this session. Although some of its proponents may disagree, Governor Cuomo explained yesterday that right now there are not enough votes in the Senate to get legalization through that Chamber this year. While I’m surprised you’re not going to see movement on it this year, if the Governor is correct, this is good news even if you want to see further legalization take place. It makes absolutely no sense for states to move on further legalization until the federal government gets its act together on this issue.

June 4, 2019 at 9:05 am 1 comment

In The Wee Small Hours of The Morning A Budget Is Passed

In the wee small hours of the morning when the whole wide world was fast asleep, the state legislature passed a budget for the 2019-20 fiscal year that starts today. In fact, the Assembly ended its all-night session less than an hour ago.

To give you a sense of what it’s like to be a rank and file New York legislator this time of year, imagine getting a briefing on an all-encompassing budget bill at 12:45 in the morning, delivered by staff that hasn’t gotten more than a few hours’ sleep in the last week. They explain to you the main provisions of a bill you haven’t seen yet but will be expected to vote on in the next hour. Keep in mind many of the major priorities that will define your voting record are contained in this and several other bills which were printed up in the last few days to meet the state’s annual budget deadline. When you get back to your desk here is a copy of the bill you will be voting on.

This is the process that your state representatives and senators went through in the last couple of days as they finalized agreements on a broad range of topics. I’ve only begun skimming the final product but what is clear is that the issue could have had the biggest impact for credit union operations, the legalization of marijuana banking, was left out of the budget. Meaning it promises to be one of the highest profile issues left to be debated as we enter the legislative phase of the session. There is almost always one or two small items which impact your operations and when we get a chance to review all of the bills we will let you know what we find. Here is a copy of the Governor’s press release.

And don’t get me wrong, the process is vastly better than it used to be. In the worst of times, budgets were not finalized until mid-way through summer and usually on the closing days of the legislative session. Besides, there is something strangely enjoyable about an all-night session; it’s kind of like a college party but for adults.

Marijuana Act Advances

Speaking of marijuana, even though New York State’s budget did not include a joint agreement on further legalizing marijuana possession, (did you get the pun?) the House Financial Services did vote out legislation to make it legal as a matter of federal law to provide banking services in states where marijuana possession is legal. As explained by the Chairwoman at the start of the hearing, “The banking bill “addresses an urgent public safety concern for legitimate businesses that currently have no recourse but to operate with just cash,”

While this is an important step forward and of course increases the likelihood that the House will pass this important banking legislation, a recent article in the American Banker pointed out that passage in the republican controlled senate is by no means a sure thing.

April 1, 2019 at 9:07 am Leave a comment

How Last Night’s Elections Impacted NY CU’s

Good morning folks. Here are some quick takeaways from last night’s elections.

  • Will the last New York state Senate Republican please turn out the lights? It’s taken about a decade longer than it probably should have but New York State had its very own blue wave last night and my guess is you will never see a Senate Republican majority again. According to this morning’s New York Post, Democrats will now be in control of the chamber with at least 40 votes to the Republican’s 23. The margin is so big that any speculation about  Republicans cobbling together a working majority as they have done for the last decade is out the window. This is historic. Except for a brief period in the 1960’s. Senate Republicans controlled the chamber since the end of WWII. Not only do the Democrats have control of the Senate but barring a historic meltdown, Democrats will have complete control of all the levers of power when redrawing of the maps begins in 2020.
  • What this means for credit unions? Frankly any change is good news for credit unions which can make arguments for common sense reforms such as municipal deposits to a fresh set of legislators and staff members. Get ready to go to Albany.
  • Are New York Republican Congressmen an endangered species? Three of the pickups which helped Democrats take control of the House of Representatives came courtesy of New York State. My old boss John Faso lost his Hudson Valley seat after just one term to political newcomer and unabashed progressive, Antonio Delgado. And in two of the biggest surprises of the night – for me anyway – Claudia Tenney has probably lost her reelection bid to Assemblyman Anthony Brindisi but has not conceded and Congressman and former District Attorney Dan Donovan lost his reelection bid to Max Rose. Neither of these were high on the prognosticator hit-list and they show just how divided the nation has become. If there were two districts in New York that would benefit from Donald Trump’s high profile campaigning leading up to the midterms, these two districts would have been at the top of the list.
  • What this means for credit unions? Congresswoman Tenney and her staff had an open door policy when it came to New York credit unions which was all the more useful because she was given a seat on the House Financial Services Committee. We will have to get to know the new members and keep in mind that given their more liberal leanings, they may expect more, not less of credit unions. Time will tell.
  • Marijuana banking will be legalized once and for all. The only unequivocal prediction I will make today is that within the next two years  marijuana banking will be legal as a matter of federal law in those states that choose to legalize it. Last night three states Michigan, Missouri and Utah approved referendums legalizing marijuana use in some form. But the really important thing to keep in mind that all three of these states were states that voted for Trump in 2016. I believe that marijuana legalization is one of the few issues that a progressive Democratic majority in the House and a coalition of state’s rights Conservatives in the Senate will be able to agree on.
  • What this means for credit union? For those of you who are interested in marijuana banking, now is the time to start researching how you’re going to design your compliance programs and ultimately determining whether the costs of providing these services are outweighed by the potential benefits.
  • As for the national level, CUNA and NAFCU better get moving quickly because if anything meaningful is going to be passed it is going to be well before the epic battle for the 2020 Presidency begins.

November 7, 2018 at 8:38 am 2 comments

5 Things You Need To Know About Last Week

Increasingly it seems that there’s no down time for credit union news anymore, which is good if you’re a blogger but bad if you are a blogger who took an Easter break. So here in order of descending importance is a look back at some of the key developments that occurred last week with the understanding that I may expand further on these developments in the coming weeks.

DC Federal Court Strikes Down Key Provisions of NCUA’s Community Membership Rules

I know you’ve already heard about this one but considering that it takes about a week to read the decision, there’s still much more that needs to be said about Am. Bankers Ass’n v. Nat’l Credit Union Admin., No. CV 16-2394 (DLF), 2018 WL 1542049, (D.D.C. Mar. 29, 2018). Suffice it to say, that in its ruling the court held that NCUA overstepped its authority in defining a local community as any portion of a combined statistical area that contains no more than 2.5 million people. The court also ruled that the Board did not act rationally in defining a rural district as an area containing up to one million people. The court put a monkey wrench in many credit union expansion plans. Without getting this decision overturned or at least modified on appeal, community based credit unions will find it increasingly difficult to grow to meet member needs. On the bright side, portions of the rule were upheld and there may be a path forward for credit unions and NCUA, even if this decision is not reversed.

Prodigal Son Returns

When I left for vacation, an eight member democratic faction in the state Senate provided an independent power base at the state Capitol. When I came back, the Independent Democratic Caucus was no more. What’s more, Governor Cuomo was vociferously campaigning for Democrats in two upcoming special elections. The practical impact of this development was seen immediately as Senate Majority Leader John Flanagan replaced Jesse Hamilton as the Chair of the Senate Banks Committee with Long Island Republican Elaine Phillips. Remember, for the Democrats to take control of the Senate, they have to win two upcoming special elections in seats vacated by Democrats and convince Democrat Simcha Felder to caucus with them instead of the Republicans.

State Budget Impact

When the legislator finally got the budget deal done on Saturday, it contained a few provisions that will impact credit unions and their operations. S. 7508-C PART QQQQ creates a revolving loan fund for community development financial institution.

The bill imposed a $2.75 charge on ride sharing vehicles in Manhattan. A charge of $2.50 is imposed on medallion taxis. Why does this matter? Because critics of the approach argue that ride sharing vehicles are much more able to absorb the cost of the fee increase than are their medallion counterparts, making it even more difficult for the medallion industry to remain competitive.

This is the way the plan is described in the Governor’s budget press release: “Enact a $2.75 Surcharge on For-Hire Vehicles: To establish a long-term funding stream for the MTA and to reduce motor vehicle congestion, the FY 2019 Budget enacts a surcharge on for-hire vehicles below 96th Street. The surcharge is $2.75 for for-hire vehicles, $2.50 for yellow cabs, and $0.75 for pooled trips. This funding will go into an MTA “lock box,” and will provide long-term funding to sustain for the Subway Action Plan, outer borough transit improvements, as well as a NYC general transportation account.”

 Beneficial Owner Q&A Release

Regulations requiring credit unions and banks to identify the beneficial owners of accounts must be complied with by May 11, 2018. Although many credit unions may not deal with the type of sophisticated entities that this regulation is designed to address, you still need policies and procedures in place to know who the beneficial owner of an account is. You should definitely take a look at this Q&A if you haven’t done so already.

State Treasurers Want Cannabis Meeting With Sessions

With confusion continuing to reign regarding the legal status of marijuana proceeds in states that have legalized its use, a group of state treasurers wrote a letter last Thursday to Attorney General Jeff Sessions requesting a meeting with him to discuss this issue. Since withdrawing the Cole Memorandum in November, the AG has imposed radio silence on how financial institutions should deal with this issue.



April 9, 2018 at 8:59 am Leave a comment

Court Ruling Means Continued Uncertainty For Pot Banking

The legal lunacy surrounding a state chartered Colorado credit union formed to provide banking services to marijuana businesses took another bizarre turn Tuesday, which is great news for lawyers and bloggers, but lousy news for credit unions looking for definitive guidance in states where it is legal.

When I last wrote about The Fourth Corner Credit Union in Colorado, it had sued both the NCUA, which had denied it share insurance, and the Federal Reserve Bank of Kansas City,  which had denied it a “master account” needed to access the  federal reserve system.  A federal district court ruled that these actions were entirely appropriate. The district court explained that forcing the Federal Reserve bank to provide the CU services would be forcing the bank to “facilitate criminal activity.” The CU appealed.

On Tuesday a three judge panel of the Court of Appeals for the 10th circuit  ruled on the credit union’s appeal,  THE FOURTH CORNER CREDIT UNION, a Colorado state-chartered credit union, Plaintiff – Appellant, v. FEDERAL RESERVE BANK OF KANSAS CITY, Defendant – Appellee.., No. 16-1016, 2017 WL 2766364, at *1 (10th Cir. June 27, 2017).

The good news is that the court sent the case back for further fact-finding. The bad news is that the credit union will have to explain how it will uphold its pledge to provide banking services “in strict accordance with state and federal laws, regulations and guidance” even as its business model is to serve businesses violating federal drug laws.

This is not an issue that can be or should be decided by the courts. Here are the short to medium-term options:  Regulators could reclassify marijuana under the controlled substances act, or the new Justice Department could explain if it is going to adhere to the Obama Justice Department’s policy of not prosecuting businesses in states where marijuana is legal provided strict conditions are followed.

I know that there are institutions that already provide these banking services, but many institutions remain justifiably hesitant to help marijuana businesses. Ultimately, Congress and only Congress can amend federal law to reflect the reality that legal marijuana businesses are here to stay. After all, cannabis possession is now legal in some form in 29 states and the District of Columbia, and that number is likely to grow.


June 30, 2017 at 8:55 am 2 comments

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Authored By:

Henry Meier, Esq., Senior Vice President, General Counsel, New York Credit Union Association.

The views Henry expresses are Henry’s alone and do not necessarily reflect the views of the Association. In addition, although Henry strives to give his readers useful and accurate information on a broad range of subjects, many of which involve legal disputes, his views are not a substitute for legal advise from retained counsel.

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