Transition
Once the law comes into force, how does it affect consent?
In order for the transitional period in section 66 of CASL to apply, must the existing business relationship (EBR) or Non-EBR be created before the Coming into force of section 66 (i.e. 1 July 2014) or can it be created at anytime within the 3 year transition period (i.e. 1 July 2014 to 1 July 2017)?
Transition
Once the law comes into force, how does it affect consent?
In order for the transitional period in section 66 of CASL to apply, must the existing business relationship (EBR) or Non-EBR be created before the Coming into force of section 66 (i.e. 1 July 2014) or can it be created at anytime within the 3 year transition period (i.e. 1 July 2014 to 1 July 2017)?
The EBR or Non EBR must be created prior to the coming into force of section 66 (i.e. 1 July 2014) in order to rely on the 3 year transitional provision. Any EBR or Non EBR created after July 1 2014 is subject to the time periods specified in the EBR and Non EBR exemptions (sections 10(10) and 10(13) ), and the 3 year transitional period cannot be relied upon.
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