Epstein on junk fee enforcement across industries

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

But, you know, one of the benefits of the structure of these laws is that we're able to watch and get the data reporting from the apps on a monthly basis

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

so that we're not only relying on complaints from workers, but also able to watch and identify issues through those reports.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So, you know, with the new street vendor licenses, there's going to be some penalties associated with that.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

And I know mostly DSNY is going to be doing enforcement.

So we're going to be monitoring the student loan marketplace.

And what role do you think you're going to play in coordination with DSNY on that level of enforcement?

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

And what role do you think you'll play in the new licensing scheme on the enforcement side?

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

Our real role is to stand side by side with the street vendors and help them, help to bring them out of the shadows into the New York economy with licenses.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So certainly I can see a role for us educating people along with SVP, along with council members who I know are interested in this.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

But in terms of day-to-day enforcement, for example, the sanitation code, we're going to leave that to DSNY and health.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

Yeah, I'm worried about people not knowing, right?

So we're going to be monitoring the student loan marketplace.

So I'm worried about, like, your role into ensuring that the small businesses

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

understand to avoid the enforcement, you know, nothing to speak against my district or some people in my community.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

I can see someone not liking a new vendor on some street corner and calling every day, and I want to make sure those vendors don't get to a place where they could have enforcement issues.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

Well, if someone doesn't have a license, that would be our responsibility.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

But again, our goal, the reason our administration reversed the last administration to endorse this bill is we want people to get licenses.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

We want small businesses to thrive.

So we're going to be monitoring the student loan marketplace.

So, you know, again, we have a statutory responsibility to make sure folks are licensed.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

But at the end of the day, the orientation of our agency is squarely on the side of the street vendors who the council decided, and we agree, it's long overdue they get licenses.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

And Chair, I would mention as well, I think a lot of the resources that you're talking about, you know, the Division of Street Vendor Services at SBS is actually, they're revamping their website to include a lot of education materials

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

that has included feedback from individual agencies like DCBP, DOHMH, and DSNY to ensure that vendors understand

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

kind of the rules of the road, including mapping that's out there as well as plain language descriptions of their restrictions on the street.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

You know, I mentioned this earlier.

So we're going to be monitoring the student loan marketplace.

I'll just flag again.

This kind of outreach will be critical to avoid.

So we're going to be monitoring the student loan marketplace.

These come in enforcement issues, and I would love to see the administration commit to some of those resources to these organizations who are going to help prevent people from getting these fines and fees and be affected by enforcement.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

Absolutely, and I'm happy to go with you in our district to some of our local street vendors to get the word out.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

Great.

We'll schedule that.

I'm happy to do it.

So we're going to be monitoring the student loan marketplace.

Chair certainly heard on this issue you're raising about funding, so we'll make sure to raise that with our colleagues at OMB and City Hall.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

Yeah.

So I just want to go back to junk fees.

So we're going to be monitoring the student loan marketplace.

And what are you seeing now on junk fees based on the executive order?

So we're going to be monitoring the student loan marketplace.

Where are you seeing violations?

So we're going to be monitoring the student loan marketplace.

Kind of how are those moving forward?

So we're going to be monitoring the student loan marketplace.

Are you seeing a spike since the enactment?

So we're going to be monitoring the student loan marketplace.

We're paying more attention to it.

So we're going to be monitoring the student loan marketplace.

I think it's how, let me put it this way.

So we're going to be monitoring the student loan marketplace.

I think in the past, we've, you know, we looked at different categories, employment agencies, immigration services providers, et cetera, et cetera.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

Now we're sort of creating a new category the way we're thinking about it.

So we're going to be monitoring the student loan marketplace.

Who are charging unlawful fees?

So we're going to be monitoring the student loan marketplace.

So we did a warning blitz with employment agencies.

So we're going to be monitoring the student loan marketplace.

We did a warning blitz with used car dealers.

We did a warning blitz with immigration service providers.

So we're going to be monitoring the student loan marketplace.

We did the warning blitz and the rule with hotels.

So we're going to be monitoring the student loan marketplace.

And I can tell you now, you know, we also co-chair the junk fee task force.

So we're going to be monitoring the student loan marketplace.

We just held a meeting yesterday on this with other agencies, and I don't want to get ahead of the mayor or other agencies, but I can tell you other agencies are doing a really thoughtful job of identifying junk fees that, frankly, we...

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

wouldn't necessarily have visibility into, but because, say, department, I won't name any departments, but that our sister agencies have deep visibility into and understanding of their authority.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So I'm very optimistic about the trajectory on this.

So we're going to be monitoring the student loan marketplace.

We're working very hard both on enforcement and rulemaking.

So we're going to be monitoring the student loan marketplace.

I think Mike wants to add some more.

So we're going to be monitoring the student loan marketplace.

Yeah, just some additional color to add to that, Chair and Council members.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

As the Commissioner alluded to, this has been sort of not always labeled as a junk fee, but core to our work over the last several years.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

Like we've brought three cases recently at Oath over the last 18 months against licensed employment agencies for charging illegal advance fees.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

What are those?

Those are just junk fees by another name.

So we're going to be monitoring the student loan marketplace.

Similarly, we have great laws passed by this council, supplemented by our rules on financing disclosures and what can be charged by used car dealerships.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

We call them secondhand automobile dealers.

So we're going to be monitoring the student loan marketplace.

And we are constantly bringing cases where that's a core part of the investigation.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

We actually have a major trial ongoing right now at the Office of Administrative Trials and Hearings against a major dealership, Victory Mitsubishi.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

We, of course, passed the, as the Commissioner alluded to, the hotel junk fee rule.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

We're monitoring the complaints.

I'm always talking about the consumer complaints.

So we're going to be monitoring the student loan marketplace.

Please give us complaints.

We're monitoring complaints.

So we're going to be monitoring the student loan marketplace.

We're filing our first summons under that rule imminently.

So we're going to be monitoring the student loan marketplace.

So this is a...

This is something that we're always looking at, we've always looked at traditionally, and this sort of been very helpful to name this exact sort of concept and to really like focus our work.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

And let me just underscore, the executive order was very helpful in doing that.

So we're going to be monitoring the student loan marketplace.

And also looking forward to the different types of

So we're going to be monitoring the student loan marketplace.

junk fees and pricing violations that may not exist.

So we're going to be monitoring the student loan marketplace.

It really transcends just narrow junk fees, but like sort of the ideas that we've been talking about, about surveillance pricing, dynamic pricing, these sort of the new generation of how consumers are harmed on a day-to-day basis.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

And so we have our...

So we're going to be monitoring the student loan marketplace.

You're getting in front of our hearing in a couple weeks.

I know, I'm sorry about that.

So we're going to be monitoring the student loan marketplace.

It's like our ear to the ground on that.

So we're going to be monitoring the student loan marketplace.

So we're looking for trends and sort of this commitment by the admin is this type of issue, junk fees, pricing.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

These are things that we are going to dedicate resources to now in a way that's really going to result in dividends for New Yorkers.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.

Yeah, I appreciate that and hopefully you'll have the resources you need to be doing that work.

So we're going to be monitoring the student loan marketplace.

So we're going to be monitoring the student loan marketplace.