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November 5, 2026
Dear Senate President Spilka and Chair Rodrigues:
On behalf of the Greater Boston Chamber of Commerce and our 1,200 member organizations, thank you for the opportunity to provide comments on S.3290, An Act making appropriations for the fiscal year 2026 to provide for supplementing certain existing appropriations and for certain other activities and projects, and several amendments under consideration. As the Senate considers the legislation, we encourage lawmakers to advance policies that provide clear and workable standards for employers, support housing production and innovation, and strengthen Massachusetts’ long-term economic competitiveness.
Comments on Bill Sections
OPPOSE – Negative Options/Automatic Renewals (Section 64)
The Chamber opposes Section 64 as currently drafted. While we support clear and effective consumer protections for automatic renewals, subscriptions, and other negative-option arrangements, Massachusetts businesses are already subject to Attorney General regulations governing these practices, including requirements related to cancellation and renewal notices. Section 64 would layer additional statutory requirements onto this existing regulatory framework, expressly subject violations to Chapter 93A, the Commonwealth’s consumer protection law, and authorize further Attorney General rulemaking.
Rather than providing greater clarity for consumers and businesses, Section 64 risks creating overlapping or potentially conflicting requirements for businesses already navigating state and federal consumer-protection standards. The proposal could increase compliance uncertainty and litigation risk for businesses while granting additional regulatory authority over practices already subject to existing consumer protections. Significant changes to the Commonwealth’s consumer-protection framework should instead be carefully considered through the regular legislative process, with meaningful stakeholder engagement and sufficient opportunity to evaluate their implications for businesses and consumers.
For these reasons, we urge the Senate not to adopt Section 64 as currently drafted. If the Senate moves forward with the provision, however, the Chamber strongly supports Amendments #69 and #123, discussed below, which would provide greater regulatory certainty and address important implementation concerns.
OPPOSE – Alcohol Shipment Reporting Requirements (Section 77)
The Chamber opposes Section 77 as currently drafted. The provision would establish a new monthly reporting requirement for permitted parcel delivery services, express companies, and trucking businesses transporting alcoholic beverages into Massachusetts for delivery to non-licensees. Carriers would be required to report detailed shipment information to the Alcoholic Beverages Control Commission, including the consignor and consignee, package weight, delivery date, and tracking number, with knowing violations subject to permit suspension or revocation.
While the Chamber supports appropriate safeguards governing the delivery of alcoholic beverages, Section 77 would impose a new recurring administrative and compliance obligation on businesses engaged in interstate shipping and logistics. Before establishing a new reporting mandate backed by potentially significant penalties, the Commonwealth should demonstrate the need for the additional reporting and ensure that any requirements are appropriately tailored, administratively workable, and do not unnecessarily burden lawful commerce.
We therefore urge the Senate not to adopt Section 77 as currently drafted and instead engage with affected businesses to develop a more targeted and workable approach.
Comments on Filed Amendments
SUPPORT – Amendment #69 (Driscoll): Negative Option/Recurring Billing
If Section 64 moves forward, the Chamber supports Amendment #69, which would improve the negative-option provisions by clarifying the effect of a consumer’s cancellation and establishing more practical cancellation options. Importantly, the amendment would ensure that cancellation prevents additional charges from accruing while preserving businesses’ ability to collect amounts legitimately owed before cancellation. These changes would make Section 64 more workable for businesses while preserving meaningful and accessible cancellation rights for consumers. We urge the Senate to adopt Amendment #69.
SUPPORT – Amendment #123 (Crighton): Negative Options/FTC Consistency
If Section 64 moves forward, the Chamber supports Amendment #123, which would require Attorney General regulations implementing the section to remain consistent with applicable Federal Trade Commission regulations and relevant federal court decisions interpreting the Federal Trade Commission Act. Businesses operating across multiple jurisdictions increasingly face a complex patchwork of consumer-protection requirements. Aligning Massachusetts requirements with applicable federal standards would provide clearer compliance expectations while maintaining appropriate consumer protections. We urge the Senate to adopt Amendment #123.
SUPPORT – Amendment #116 (Cyr): Manufactured Housing
The Chamber supports Amendment #116, which would modernize Massachusetts law to recognize manufactured homes built with or without the permanent structural chassis traditionally used to transport and support the home. Removing this outdated statutory restriction could enable newer forms of factory-built housing and expand the range of tools available to address the Commonwealth’s housing shortage. The proposal aligns with the Chamber’s priorities of increasing housing production, reducing barriers to development, containing construction costs, and advancing innovative approaches to housing production.
OPPOSE – Amendment #21 (Edwards): PFML Employer Notice Requirements
The Chamber opposes Amendment #21 as currently drafted. The amendment would establish a new proactive obligation for employers to identify potentially PFML-qualifying absences and provide employees with certification forms and other information within five business days. While we support ensuring employees understand and can access benefits available through the Commonwealth’s PFML program, employers may not always have sufficient information to determine whether an employee’s absence may qualify for PFML, particularly when an employee has not requested leave or provided information about the reason for the absence.
Requiring employers to make that determination based on incomplete information could create unnecessary administrative burdens, compliance uncertainty, and potential liability. We encourage the Senate not to adopt Amendment #21 as currently drafted and instead engage with employers on a more workable approach.
Thank you for your consideration. Please do not hesitate to reach out with any questions.
Sincerely,
James E. Rooney
President & CEO
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