Your chatbot answers the customer’s email at nine at night so you don’t have to. If any of those customers are in New York City, don’t plan around the $525 fine every outlet quoted this week. Plan around the paperwork. The rule the city proposed on October 20 is twelve pages, and the part nobody wrote up is the part that costs you time.<\/p>\n\n\n\n
What’s settled, from the press release<\/a> and the rule text:<\/p>\n\n\n\n That’s the coverage. The PDF behind the press release<\/a> goes further.<\/p>\n\n\n\n Section 5-313 is a record-keeping rule. A business using a chatbot for customer service “must create and retain records demonstrating compliance with the requirements of this subchapter for a period of at least three years.” Those records include “logs of all covered interactions” showing “the total duration of each covered interaction,” “whether a single-step transfer mechanism was offered to the consumer,” whether the customer pressed it, and where they ended up. Plus yearly totals, in a form the commissioner will set. And the lot has to be kept “in a machine-readable format” and handed over on request.<\/p>\n\n\n\n Does your chat tool keep a per-conversation record of whether the human button was shown? I don’t know which widgets do. That’s the first question for whoever sold you yours.<\/p>\n\n\n\n The penalty schedule lists four separate sections, and says each one charged “shall constitute a separate violation.”<\/p>\n\n\n\n So one bad chat that skipped the disclosure, hid the button and kept no log is three charges. On a first offense that’s 3 times 525, or $1,575. A “contact us” email nobody answers adds the fourth, and 4 times 525 is $2,100. The certification page at the back says the rule “does not provide a cure period because a cure period is not practicable.” As drafted, no warning letter comes first.<\/p>\n\n\n\n What I can’t tell you is whether it reaches a shop outside the city that sells to someone in it. The text says “merchant” and “consumer” under the city’s consumer protection law and draws no map. One source so far, the rule itself, and the agency hasn’t answered that question anywhere I could find.<\/p>\n\n\n\n The one-step transfer has to name the step (“Say or type ‘agent'” is the rule’s own example) and “the estimated wait time if the consumer is placed in a queue.” If nobody’s on, the fallback has to carry hours or a response window: a phone number with hours, a callback “and the timeframe within which the merchant will respond,” an email with the same. Which does your bot say now? A timeframe is cheap to add. A promise with no time on it is the thing the rule is written against.<\/p>\n\n\n\nThe Logs Are the Real Cost<\/h2>\n\n\n\n
Four Fines, Not One<\/h2>\n\n\n\n
Section<\/th> What it covers<\/th> First<\/th> Second<\/th> Third and after<\/th><\/tr><\/thead> 5-311(a)<\/td> A listed phone line or email with no service behind it<\/td> $525<\/td> $1,050<\/td> $3,500<\/td><\/tr> 5-312(a)<\/td> No disclosure that it’s a machine<\/td> $525<\/td> $1,050<\/td> $3,500<\/td><\/tr> 5-312(b)<\/td> Customer service promised and not delivered<\/td> $525<\/td> $1,050<\/td> $3,500<\/td><\/tr> 5-313<\/td> No records, or records not produced<\/td> $525<\/td> $1,050<\/td> $3,500<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n “We’ll Get Back to You” Doesn’t Pass<\/h2>\n\n\n\n
OpenAI’s Agents Muted Their Own Alarm, and the Instruction Was Ordinary<\/h2>\n\n\n\n