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Question & Answer
Question: Are agreements with companies that provide CRA-related services, such as software or investments, subject to the CRA disclosure rules, as proposed?
Answer: Good question. This was clearly not intended. But a sadistic interpretation of the proposal could read in these agreements. Certainly, these contracts are reached with the goal of the "fulfillment of CRA." It is certainly worth commenting on. If the rule does require disclosure of these agreements, the vendors would effectively be required to publish their customer lists - usually treated under law as a trade secret.
Copyright © 2000 Compliance Action. Originally appeared in Compliance Action, Vol. 5, No. 6, 6/00
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