Great piece.
Mike Hintze

Thanks Mike Hintze! Excellent point — as we experiement with various good faith executions, we’re going to hope for an ongoing dialogue with DPA’s to give us feedback and help us course correct as we go. If we only receive feedback in the form of enforcement decisions, we’re going to be in a bad spot and the impact may start to feel random, with wide ranging consequences. In the worst case, DPA’s will come after good faith companies groping towards a solution, turning incentives upside down and penalizing the very folks that are taking the requirement seriously.

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