Code of Virginia 9.1-138  Under definitions:                                                                                       “Business advertising material” means display advertisements in telephone directories, letterhead, business cards, local newspaper advertising and contracts.                                                                                                                                                                           I see nothing in the law that protect the public by allowing an individual to have a one or two line ad in the yellow page under locksmith with no physical address nor a D.C.J.S. number, this also allows a none licensed person to perform locksmith services. The lack of clarity shows signs of discrimination towards other businesses and puts them at a disadvantage.                                          _______________________________________________________________                           Code of Virginia; 9.1-138 definition:                                                                                                                      Employed” means to be in an employer/employee relationship where the employee is providing work in exchange for compensation and the employer directly controls the employee’s conduct and pays some taxes on behalf of the employee.( The term “employed” shall not be construed to include independent contractors.)

6 VAC 20-171-230.                                                                                                                                                  5. Not contract or subcontract any private security services in the Commonwealth of Virginia to a person not licensed by the department. Verification of a contractor’s or subcontractor’s license issued by the department shall be maintained for a period of not less than three years.

            6 VAC 20-171-230     appears to be in direct conflict with the definition section above 6 VAC 20 9.1-138                                                                                                      _________________________________________________________________                                                                                                                                                 6 VAC 20-171-230 Code of Conduct                                                                                                                 20. Not provide information obtained by the firm or its employees to any person other than the client who secured the services of the licensee without the client’s prior written consent. Provision of information in response to official requests from law-enforcement agencies, the courts, or the department shall not constitute a violation of this chapter. Provision of information to law-enforcement agencies pertinent to criminal activity or to planned criminal activity shall not constitute a violation of this chapter.

This code and the one previously (5) are not conducive to the locksmith industry or any retail service business because it interferes with the free market place and interstate commerce. This locksmith business requires the need and skills of other tradesman to provide the necessary service to our customers when the time frame is very important to their safety.                                                                                                                                  Item 20 would led me to believe that you have just thrown out the long standing rule of law known as verbal contract which most retail and services business needs to survive. These regulations are a burden to the industry.                          ____________________________________________________________