It's how one interprets the exceptions. To the extent that the charity is not engaging in a commercial electronic activity, that part of the business is exempt, but then every once in a while they're going to creep into soliciting money. They're going to creep into things, and with the way the language is.... Again, you prohibit everything, and unless you fit within one of the exceptions, you find yourself in this spot, as a charity, where you're not quite sure if you can send out that commercial electronic message, and if you are going to send it, then you need to make sure you meet all of these different obligations. Making it very simple for a charity would go a long way to making it easier for them.
On October 24th, 2017. See this statement in context.