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High Severity

Enforcement Discretion Without Procedural Standards

The Division receives broad investigative and adjudicatory powers to "ensure and monitor compliance," "investigate Complaints or Reports," and "establish liability and impose sanctions" - all as binding decisions. However, the provision provides no procedural standards for investigations, no timelines for decisions, no evidentiary requirements, and no clarity on what constitutes adequate compliance. This creates significant regulatory uncertainty for businesses subject to the bill's compliance obligations, making it impossible to predict enforcement actions or plan compliance strategies. The lack of procedural constraints on the Division's enforcement discretion increases operational risk and compliance costs across all business types.