With regard to your astute question about whether the exemptions apply or not, the problem is that there was a regulatory process that could have led to the exemptions applying.
There's an exemption for personal relationships. Personal relationship as it's defined as an exemption, a message from one person to another, is so narrowly confined that it really is someone who has an existing relationship and, pretty much, is exchanging views as a best friend. It doesn't include a situation where a person who lives on the same street sends a message to the friend's mother, for example. It's too narrow. It could easily have been broadened.
The family relationship doesn't permit the sending of CEMs to grandparents or cousins. It could easily have been broadened. A lot of these examples.... I did this one on whether you could actually recommend a dentist over Christmas. It just occurred to me. Could I actually recommend a dentist to somebody? Under the law as it appeared, it was impossible. It made me think it made no sense.
That is the kind of thing that could be addressed if the GIC regulations were revised. They could have a de minimis exception. They could more broadly define what is a personal relationship or a family relationship to take those kinds of situations, which should never be illegal, out of play.