That's the question at hand: Who has the burden of proof?
Right now, it's for the bureau to build the case. They will have a complaint by a citizen and they will send a mystery shopper or they will look at the website and monitor the website over a period of time. The burden to build the case is with the bureau.
This is indeed a request by the commissioner to shift the burden to say that all companies need to document, and if they don't document, then they're in the wrong.