Leave it to JJOKE to try to do something to help the regulated community and end up causing even more confusion and potential liability.
If you or your clients have never filed a client semi annual report late you have no idea what I'm talking about. If you filed late during the previous PIC regime you are looking at a letter from JJOKE signed by Brooke Gander and saying wtf is this and wtf does it mean.
or you are calling someone like me and asking the same questions.
Here is the answer as far as I can tell, I tried to call LT today to get some clarity but she was "unavailable" (which means she was either at the funeral or swamped with calls complaining about JJOKE) In any event it appears JJOKE has granted a general amnesty on all the backlog of late filings Ginsberg and the old Biben crowd could not figure out how to clear - just an aside didn't Uncle Vinny's niece get hired back to do that work?
Now I'm not going to criticize LT for throwing up her hands and deciding not to issue late fees for reports that were filed or not filed 2, 3 or even 4 years ago. Although one has to ask what is going on. When you see a big stack of forms deal with it. But I am going to criticize JJOKE, because I doubt LT even knows, this one feels like a lawyers strategy, for granting amnesty and sending a letter that doesn't state what form you are granting the amnesty for and has a general tone of gotcha. The phone must be ringing off the hook for Brooke. Her voice mail is full and cannot accept anymore calls. Bet the lawyer never considered how clients would react to a vague threatening letter. But wait there is more.
Did anyone think about how those that did pay late fees are going to react? Or how those in the future threatened with late fees will respond. Seems like an arbitrary and capricious decision.
I'm combing my files to see if anyone I know got a late fee for that time period.
Or maybe I'll take a new approach and says its not my problem my clients are never late and don't get fined.