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Stop Congress from Undermining the Open, Nondiscriminatory Internet!

In Competition, Do-Not-Deliver, FCC, FTC & DOJ, Network Neutrality, Rules&Regs, Uncategorized on March 18, 2011 at 6:27 pm

Take Action to Oppose H.J. Res. 37!

Some Members of the House and Senate want to override the modest safeguards finally put in place by the Federal Communications Commission. If successful, their action would say to the handful of major Broadband Internet Service Providers that actually handle the flow of traffic: “The Web is YOURS — Carve it up as you please!” Measures that would amount to a “Congressional Veto” of the FCC, small business and the general public have been introduced on both sides of Capitol Hill. The knee-jerk legislation, H.J. Res. 37 and companion S.J. Res. 6, aim to shred several years worth of diligent policy process at the expert agency and replace it with…nothing. A gaping black hole of uncertainty for every other line of business that is not a monopoly or duopoly ISP.

Members pushing for “Congressional Veto” willfully ignore the exhaustive record in the inclusive, open proceedings at the FCC. But what is worse, from an economic and job creation standpoint anyway, is the blind eye to the current market realities. We noted the lack of broadband competition in nearly all markets in our last post on topic. Here’s another way to look at the sheer market force of the handful of incumbent providers — those who would now be told that our collective internet is really their proprietary internet. While all the rest of us who are dependent on the network are scolded to just click our heels and say competition three times fast, and all evils will just cure themselves.

Even a quick peek through the lens of Moore’s law shows us how the idea of competition gives way to alternate reality in anticompetitive markets. Moore’s law anticipated the technological breakthroughs behind the wonders of computer chip-making. The innovations predicted by Moore, and the numerous corollaries beyond transistors including pixels per dollar, have brought us faster and cheaper computers, cameras, smart phones, tablets and the like. All smaller and more powerful — and cheaper — by the day. Consider the descending arc of the consumer’s cost of a Gigabyte of storage: 1981 = $300,000; ’87 = $50K; ’90 = $10K; ’94 = $1,000; ’97 = $100; ’00 = $10; ’04 = $1…and by 2010 we’re down to tens cents. All thanks to the driving forces of innovation and robust competition.

Now look at your latest Broadband Bill. Compare it to last year and the year before that. The price tag might suggest that the costs of digital data transmission are somehow immune to the otherwise ubiquitous phenomenon predicted by Moore and his innovative peers. But they absolutely are not. Accurate parallels apply to network capacity including Butter’s Law of Photonics — and today the actual bandwidth cost has fallen to an industry average of between 2 and 5 pennies per gigabite. Innovation combined with widespread adoption, has driven down the average cost of digital data transmission to the major incumbent ISPs to a mere $1 per month per customer. That fact that we’re still charged an average between $20 and 50.00 per month for broadband service is proof positive of an anticompetitive market.

But Congress wants to do more than simply ignore the reality that our nation’s wireline broadband markets are so concentrated that they can defy Moore’s law and keep all the savings away from consumers. In pushing this “Congressional Veto” of the FCC — and the rest of America exposed to monopoly or duopoly broadband provider conditions — they are actually signaling to the major ISPs with outsized market power and national footprints to go ahead with plans to set up new traffic-tampering toll booths if the markets will allow. And obviously, a broken market that allows charging up to $50 for something that costs as low as $1 to provide will also “allow” a new profit center built on gatekeeping.

Take Action to Oppose H.J. Res. 37!

The Free Community Paper Industry strongly oppose this “Congressional Veto” of the Federal Communications Commission’s modest safeguards to preserve an Open, Nondiscriminatory Internet. Contrary to some misleading talking points, the FCC’s well-reasoned framework simply establishes Transparency and prohibits Blocking and Unreasonable Discrimination against lawful network traffic. The FCC would have Broadband Internet Access Service Providers clearly disclose to consumers what exactly they are paying for and getting, while guarding against involuntary censorship of their customers’ digital communications. Instead, H.J. Res. 37 would obliterate these most basic rules of the road, scrapping the very conditions which have finally enshrined the longstanding policy and practice that allowed the internet to flourish. This “Congressional Veto” would give the green light to ISPs to launch into the gatekeeping business, and create new profit centers built on censorship and traffic toll booths. In essence, this bill says that after collecting payment for hosting as well as for wholesale and retail connectivity, the limited group of monopoly and duopoly providers can now create a new piggy bank to fill by dictating consumer experience and extorting new access taxes from all content creators including our hometown publishers, or otherwise block content in favor of their own.

The public is clearly on the side of the FCC, and overwhelmingly opposed to this Congressional effort to undermine sound communications policy. For those just entering this important policy debate, please read the latest opinion survey released by CFA and CU, the publishers of unbiased Consumer Reports. Perhaps even more instructive than the data detailing broad public support for Open Internet are the survey questions themselves. Answer them for yourself, as these are the actual network management practices at issue. Doing so, you might note the radical disconnect between real policy substance and distractive talking points on topic. With this understanding of the underlying principles of Open, Nondiscriminatory Internet, you will likely appreciate why this debate has historically been nonpartisan. A broad consensus of consumer and social policy interest groups across the political divide agree on the need to prohibit traffic tampering and corporate censorship. One particularly passionate essay on point was Christian Coalition of America’s “Net Neutrality is Not Some Marxist Plot,” debunking propaganda parroted by pundits on this action issue for them rooted in protecting free speech. Similarly, there is simply no credible reading of the actual FCC safeguards that could confuse network transparency and nondiscriminatory treatment of traffic with a “fairness doctrine of the internet” by any reasonable stretch of the imagination.

Our Industry joins with the broad consensus of job creators that support the FCC policy to preserve our vibrant, interconnected networks. The solid economic case against this “Congressional Veto” has been made universally by innovators, investors and a broad range of job creators operating on the so-called edge of the network. Our collective economic output is orders of magnitude above the solo enterprise of data transmission, and our capacity for innovation is as vast as our lines of business are diverse. Our continued growth and the emergence of new business models are critically dependent on the fair competition fueled by open, nondiscriminatory networks. The “Repeal” offered in H.J. Res. 37 implicitly contemplates a new anticompetitive vision of digital-era commerce, where the game is suddenly changed at halftime. It decides who gets to be the home team, and allows them to make their own new rules while telling the referees to leave the stadium. It’s worth noting that even competitive rivals to the national ISP giants support the FCC’s safeguards for fair competition.

This “Congressional Veto” comes as longstanding policy and practice have been recently undermined by the Courts and demonstrably threatened by implementation of powerful new traffic tampering technologies including Deep Packet Inspection (DPI). It proposes to remove enforceable Open Internet protections in the face of explicit internet carve-up schemes such as the public proposal floated jointly by Google and Verizon, and those buried in the comments of monopoly and duopoly broadband providers filed with the FCC in their exhaustive review. H.J. Res. 37 ignores the record established by the expert agency, and with negligible diligence of its own, torpedos a years-long open and transparent process of consultation, meetings, hearings and countless reams of substantive comments from all stakeholders including our Industry. If Congress moves forward with this ill-conceived and reactionary measure, the participatory internet as we’ve collectively grown it could devolve from a robust information superhighway into a potholed patchwork of fast and slow lanes and new toll booths. Free speech, fair competition, commerce, investment and job creation are all placed in jeopardy by this and similar Congressional proposals to demolish the FCC’s light-touch approach to preserving an Open Internet.


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Community Paper Case to Repeal the 1099 Paperwork Tsunami

In Competition, Healthcare Reform, Rules&Regs, Testimony, Uncategorized on March 18, 2011 at 12:11 pm

For countless months, we have joined with our peers across the small business community in calling for full repeal of the new 1099 reporting provisions. We have made our case to the House and Senate, and gradually they began to listen.

Sort of.

Currently all sides say they want to repeal this job-killing paperwork nightmare. Several bipartisan votes have demonstrated that. Competing legislation has now moved from the Senate to the House and the House to the Senate…and even more repeal language has been attached and will soon be offered to larger pieces of unrelated legislation. Great, freestanding and pin-the-tail-on-the-donkey are both ways to get the job done.

But the Lingering Problem: Repeal is still not legally complete! Please Click Here on Our Industry Action Page to let your House and Senate Members know that you appreciate their efforts so far — BUT it’s now time to Finally Repeal the 1099 Paperwork once and for all!

The Free Community Paper Case for Repeal the 1099 Paperwork Tsunami has been made to Congress from the unique perspective of our industry — as well as part of a much broader coalition of small business groups. For the most comprehensive analysis of the impact to Our Industry, read excerpts of our formal Comments to IRS and Treasury as follow:

 

THE FREE COMMUNITY PAPER INDUSTRY

RE:  Notice 2010–51

Information Reporting Under the Amendments to Section 6041 for Payments to Corporations and Payments of Gross Proceeds and With Respect to Property


The Association of Free Community Papers (AFCP) and Mid-Atlantic Community Papers Association (MACPA) submit these comments to the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) on behalf of the united Free Community Paper Industry (Community Papers)1 in response to Notice 2010-51, regarding guidance concerning new requirements with respect to the reporting of payments made in the course of the payor’s trade or business.  Specifically, the Treasury and the IRS have asked for comments regarding the implementation of the expanded information reporting requirements included in the Patient Protection and Affordable Care Act of 2010, Pub.L.No. 111-148, 124 Stat. 119 (PPACA).

Community Papers are concerned about the increased complexity and cost this new requirement will place on small business generally, and on our hometown publishers and their community advertisers specifically.  The potential reach of the new reporting requirement is vast, requiring small businesses to report almost every business-to-business transaction including commerce-driving advertising services.

It is our understanding that the goal of this exponential expansion of reporting requirements is to increase the aggregate amount of income believed to be currently underreported by some in the business community, and thereby bolster collection of the sum total tax revenue believed to be owed.  Even in theory, it is generally understood that these new burdens will fall on already compliant small business taxpayers.  As a matter of practice, there are concerns even within Treasury and IRS that a tsunami of new 1099s will not provide any practicable new information, or whether this tidal wave of data can even be purposefully integrated into current data analysis systems.

Community Papers appreciate the fact that Treasury and the IRS have requested ways to minimize the expanded burdens on our small business communities. We note that attention has been given to, and comment sought on, specific concerns including duplicative reporting, disproportionate burdens among types of taxpayers and businesses associated with implementation and compliance, as well as the privacy concerns arising from the new, widespread wave of soliciting taxpayer identification numbers (TINs).

It is our strong and considered belief that these new reporting requirements will wreak havoc beyond even that currently contemplated, with a net return to Treasury and IRS far less than hopefully projected. Plainly stated, this costly scheme will do far more harm than good, and we will continue working with small business peers across industries united for full repeal measures before Congress. Here, however, we plead for the specific remedy of exempting advertising expenses from 1099 reporting at the new $600 threshold.

Community Papers offer five (5) concrete reasons why advertising — a commerce-driving, routine business operating expense — should be exempt from the duplicative 1099 reporting and the requisite and potentially hazardous TIN swapping triggered by $600 of services rendered over the course of the year:

• First, in practical terms with tax revenue objectives in focus, 1099 reporting on advertising will not provide any bottom-line information about any unreported revenues from client advertisers. The avalanche of requests for TINs, and subsequent cross-filings of 1099s will not reveal whether or not our advertisers are underreporting the income generated by their own, respective businesses. The overriding goal of making sure — or finding out whether — the plumber, the pizzeria or the seasonal lawn mowing and snow plowing service is reporting all of their income and paying their taxes will not be advanced one penny by this futile enterprise.

• Second, advertising expenses are not even remotely likely to involve any real compliance difficulties. These are tracked by front-end systems, generating a trail of payment and receipts, and presumably our clients already claiming advertising as a deduction.

• Third, a $600 threshold, or any other nominal and arbitrary baseline, could lead to the consolidation of advertising with fewer, larger firms — or even a reduction in advertising by small business altogether. Advertising generates a proven multiplier effect on economies, and since each ad dollar lost compounds to a net economic loss of 4 to 10 times or more, this would be a disaster for small business generally, our hometown publishers particularly — and quite possibly a net loss to Treasury and IRS.

• Fourth, given that TINs are unique, very real and powerful identities — the object of illicit demand and subject of theft and abuse — the forced, widespread unprotected sharing among all businesses based solely on a small dollar amount of aggregate yearly expenditures, would in other applicable contexts be scorned as dangerously promiscuous.  The magnitude of compulsory risk for our industry, and all of small business, is chilling.

• Fifth and finally, disproportionate burden:  Estimates of compliance across industries puts new 1099 reporting at multiples of ten (10) upwards past fifty (50) times current levels — Community Papers, anticipating formal requests for TINs from even our smallest and occasional advertisers, will see increases one thousand-fold (1,000x) and even higher at larger publications.  We are in the business of helping businesses generate business, and over the course of a single year even the smallest hometown publishers provide advertising services totaling $600 to several hundred and more micro and small businesses, in addition to others. For larger community paper publishers, that could run into the tens of thousands over the short span of fifty-two weeks.

The presumption behind these exponentially expanded reporting measures is the hopeful expectation that disclosure of this tsunami of new information will translate into significantly reduced illegal tax avoidance.  At the same time, there is a considerable concern bridging industry and government regarding the resulting paperwork burden and security risks, especially for small businesses.  Treasury and the IRS seek comment and have authority to issue rules exempting certain expenses unlikely to involve compliance difficulties, such as advertising, and in particular print advertising.

For the reasons detailed above, Community Papers urge the exemption of advertising from the duplicative 1099 reporting and the requisite and potentially hazardous TIN swapping triggered by $600 of services rendered over the course of the year.

Notes

………………..

1 The Association of Free Community Papers (AFCP) and Mid-Atlantic Community Papers Association (MACPA) are joined by the following state and regional trade associations of Free Community Paper Publishers:  Midwest Free Community Papers (MFCP), Southeastern Advertising  Publishers’ Association (SAPA), Community Papers of Florida (CPF), Community Papers of Michigan (CPM), Wisconsin Community Papers (WCP), Texas Community Newspaper Association (TCNA), Community Papers of Ohio and West Virginia (CPOWV), Free Community Papers of New York (FCPNY). Collectively, the Industry includes 2,673 hometown publications with a combined, audited circulation 65,187,292, and a small business client base, investing at least $600 a year, well into the millions — all to grow our inter-dependent economies.

Ad Tax Could Result in Net Loss to PA

In Ad Tax, Competition, Rules&Regs on March 2, 2010 at 6:44 pm

In my last post on the perils of Taxing Advertising, I touched on the “multiplier effect” of advertising: Each dollar invested yields a compounded return in economic activity. It can be four-fold, it can be ten-fold and more, but most importantly: It can be quantified. And it has, in robust analysis.

It is critical to understand the commerce-driving function of advertising before looking at it as just another piggy bank to raid. Unfortunately, the Governor’s proposed budget treats it like a static line item on the revenue wish list. Blissfully ignored are projections for decreased spending on advertising, the resulting cascade of lost sales across the economic spectrum and the jobs lost due to imploding revenues at already struggling employers.

So far, even the credible Think Tank analysis of the proposed Expansion of Sales and Use Tax (SUT) to 74 NEW Goods and Services — including competing PA-based heavyweights Commonwealth Foundation and The Pennsylvania Budget and Policy Center, as well as D.C. based Tax Foundation — all seem to swallow the zero-sum fallacy of a New Ad Tax. Meanwhile, the revenue gaps between projected and reality were just released by the Pennsylvania Revenue Department. The farthest off the mark? Sales tax receipts: Year-to-date collections slumped to $265.3 million “less than anticipated.”

We can and must to do a better job “anticipating” the very predictable series of unintended fiscal consequences that would be triggered by a New Advertising Tax. Our Commonwealth’s sluggish sales tax receipts have been driven by numerous interrelated forces in this Great Recession. One of which has been the vicious cycle of declining sales leading to reduced advertising, which have further reduced the volume of goods and services sold. And Taxed. Correspondingly, spending on advertising fell across the media landscape for the sixth consecutive quarter, and the total decline for 2009 was 9% nationally.

These mutually reinforcing trends are finally beginning to reverse. But a New Ad Tax would push commerce, jobs and even the hoped-for tax receipts off the cliff. Projections for Lost Sales across sectors run as high as $14.8 billion. The corresponding Job Loss: A staggering 64,040. Which will mean substantially “less than anticipated” Personal Income Tax (PIT) Receipts and a spike in demand for cash-strapped social services. As for the actual SUT Projections: Lost Sales, even at 4%, will blow a $600 million hole in the happy math on that zero-sum spreadsheet. Factoring these unintended consequences, we clearly won’t raise $534 million in “new” revenue. Just the opposite, a New Ad Tax would likely lead to a Net Loss, all things considered.

Proposed Pennsylvania Ad Tax Would Be a Dubious First in Nation

In Ad Tax, Competition, Rules&Regs on February 23, 2010 at 4:05 pm

Pennsylvania would make history if the Ad Tax — part of the Governor’s 74 count hit list on current, so-called “non-essential” goods and services — were to pass. And stay on the books. That’s because Florida, searching for “soft targets” to tax, actually passed such a measure several years ago. But the economic fallout was immediate and the devastation spilled beyond the imagination of the budget makers.

As a result, the Ad Tax was swiftly repealed. But in dire budgetary times, states succumb to collective amnesia or willfully ignore the critical Florida Ad Tax Lessons: Advertising has a demonstrable multiplier effect in the economy. Each dollar spent on advertising compounds activity across multiple direct and indirect tiers of the economy, in some cases ten-fold and more. The analysis is a Must Read.

The flip side of that complex equation is the chain reaction that follows decreased spending on Advertising: Lost Sales and Lost Jobs. And as we’ve learned from our Community Paper Publishers here in Pennsylvania, an Ad Tax will lead to steep reductions in Advertising from the Mom & Pop merchants already struggling on Main Street.

Beware: Fair Housing Crackdown!

In Fair Housing Rules, Links, Rules&Regs on October 15, 2009 at 9:18 pm

The wrong words could cost you a fortune, and more folks are watching closer than ever before. Your competitors may be looking to turn you in. Worse yet, cash-strapped local agencies are scouring your Housing Ads for something to complain about. Formal complaints, when enforced and ruled against you bring fines in the $1,000s per word. Your settlement becomes their new funding stream.

Feedback I’m getting around the country: Bounty hunters are hungry. First step, be aware of and avoid the wrong words. Check out this word and phrase list. It’s intended as a guideline to assist in complying with state and federal fair housing laws. It is not intended as a complete list of every word or phrase that could violate any local, state, or federal statutes…new words get added by state agencies, court rulings, etc. But this is a really good reference.

If you don’t have a copy on file, here’s HUD’s Fair Housing Advertising Guidelines. If you already have this, it’s worth reading again. Then check out HUD’s Fair Housing and Equal Opportunity (FHEO) Main Page, which has updates and timely resources — and also links to state-specific information.

Saving Newspapers, or…

In Competition, FCC, FTC & DOJ, Rules&Regs, Testimony on October 15, 2009 at 8:07 pm

…Corporate Bailouts. As I wrote before, there’s no shortage of voices on topic. Professors, Think Tanks, Foundations, Advocacy Groups, Big Media…and Us. We’re still at the beginning of this national debate, and we had a seat at the last House Committee Dog & Pony Show. There’s lots more to come and lots at stake. Next up are the Federal Trade Commission and the Federal Communications Commission, and we need to step up our united efforts immediately — Season starts in earnest next month!

Here’s what we can expect from Big Media: On display before a Senate subcommittee this summer, NAA’s reps got softballs on “competition” and hit them over the Sherman, Clayton and Cross-ownership walls, i.e. tear down the last legal barriers to total local market domination for “our survival.” Go figure, their reporters don’t spell it out that nakedly. And recently before the latest House Show, the voice for Gannett, Tribune, NewsCorp & Fortune 500 asked for Tax & Pension Relief.

Sounds good? Here’s my caution on NAA’s ask: Fails to note that businesses with revenue under $15 million got the 5 yr operating loss carryover (v. current 2 yr) as part of the stimulus package that passed. Those above a part of a fairly select group enjoying multiple other perks, loopholes and other advantages we don’t have. Factoring offshore havens, goodwill impairment write-offs and a host of other “savings” that come from complex organization and the ability to hire the very best accountants and tax attorneys, many of these folks already pay proportionately much less than we on gross revenues. (NOTE: They also have better access to cheaper capital, pay 20% less on health insurance not trapped in small group market, and on…)

And on deferred payment to defined benefit plans, just know that we’re all ultimately on the hook. At USPS this makes sense, where H.R. 22 tackles the double funding concession they made to get the Military’s rightful obligations off the Postal books. By contrast, USPS is multiples better funded than the private sector — and my real concern is the fall-back for Fortune 500 pensions is the Pension Benefit Guarantee Corporation (PBGC), which is so disastrously underfunded that over the last yrs they’ve redefined “underfunded” and “at-risk liabilities” a few times to make the looming Armageddon only look like Hiroshima. Big Biz’ underfunded pensions are backed by the underfunded PBGC, which is backed by we taxpaying citizens and small businesses.

United Policy Point #2: Support Net Neutrality!

In FCC, FTC & DOJ, Network Neutrality, Rules&Regs on October 12, 2009 at 11:50 pm

We need laws and policies that protect open and neutral digital networks, and otherwise prevent arbitrary discrimination against traffic and content. In the past, arguments that this was a solution in search of a problem might have made sense.

But now all of the major players — Verizon, AT&T, Comcast, Cox — have been caught tampering with internet traffic — each had previously denied till exposed. Combine that with public statements that they’d like to charge for priority delivery and site-specific load speeds, this is a really big deal. Consider the new Yahoo! & AT&T ad sales partnership, where the national carrier could guarantee the ads they sell load in a heartbeat, and all those they compete with get stuck in molasses.

Our emerging digital enterprises are at risk, but recently introduced H.R. 3458, the Internet Freedom Preservation Act would keep us from being extorted or discriminated against. And just last week the FCC announced a formal Rulemaking to protect open and neutral digital networks. The major monopoly providers are opposed, and since Verizon’s point man chairs this committee at the US Chamber, they oppose on behalf of all business big and small, and several astroturf are also joining the fray.

Our Industry Needs United Voice on Key Policies…

In Cap & Trade, Do-Not-Deliver, Do-Not-Mail, Environmental Impact, FCC, FTC & DOJ, Healthcare Reform, Legal Advertising, Network Neutrality, Rules&Regs on October 12, 2009 at 11:35 pm

…being written in real-time!

As many of you already know, I spent years working inside our industry and now advocate for the specific interests of our industry. Officially, I only consult for MACPA, but in practice I always help any publisher, anywhere, anytime. Those efforts benefit dual members and often publishers well outside the Mid-Atlantic. Today, we and our advertisers — small business, generally — are under assault by both government and much larger competitors. Since the election, a slew of new front groups launched claiming to speak for broad constituencies — from the “public” generally to “small business” specifically. Meanwhile, recent surveys show that 76% of small businesses feel nobody’s speaking for them — but the biggest businesses are spending more than ever to claim to speak for all business.

It would be extremely helpful for me to be able to point to a statement of common purpose when I’m tackling regional and national issues. Current conditions make it more important than ever that the entire industry unite around a few national policy priorities. I’m asking that you please consider adopting some formal positions — a resolution for your board to vote on that your association joins in formally endorsing any, hopefully all of the following:

• legislation affording the legal ability of audited free community papers to publish and bill for legal advertising and public notice;

• laws and policies that protect open and neutral digital networks, and otherwise prevent arbitrary discrimination against traffic and content;

• laws and rules that foster fair competition between media outlets in local media markets;

• voluntary efforts towards greater community recycling, full-circle recycling of newsprint, and incentives towards availability and use of higher recovered fiber newsprint;

• passage of a federal shield law for reporters;

• steadfast opposition to all threats to distribution, including all levels of laws, ordinances and predatory practices relating to: rack, carrier and mail.

• Bonus: Any statements on some key small biz provisions on health care reform would be great, too. All other suggestions welcome!

Beware Federal Regs: Red Flag & Product Safety

In Links, Rules&Regs on October 12, 2009 at 9:50 pm

You’ll need to pay attention to a couple of obscure, new Federal Regulations: The FTC’s Red Flag Rule & the CPSC’s Product Safety Bans on Used Kids’ Stuff.

From the bowels of bureaucracy, the unelected faceless folks that made rules that impact our daily lives, come these efforts to curb identity theft and save children from the harms of toys once recalled but recycled below the retail radar. From the Federal Trade Commission comes the Red Flags Rule, with more in the way of clear guidance to come before they begin enforcement this November 1st. Businesses that extend credit to individuals will be expected to have a written policy in place to detect suspicious activity that could evidence or lead to identity theft. Neither one-off, nor business customer transactions are covered in the scope, but ongoing billable relationships with sole proprietors appear for the moment to require particular scrutiny — as guidance is released, I will share a model policy handbook to handle dealings with contractors and doing-business-as type accounts.

As for the Consumer Product Safety Commission and the “Improvement Act” of the same name, there are new guidelines and ongoing rulemaking process. It is illegal for anyone — from thrift stores to your neighbor by way of yard sale — to sell merchandise recalled from the retail market. And there’s a bigger budget for enforcement, especially for children’s toys, clothing and cribs. Publishers seem to be off the hook for penalties, but it might be good to suggest some warnings for ad copy on choking hazards of small toys. Otherwise, here’s the link to the Official Handbook to point clients to for their own protection.