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Right, but it's a royal pain in the ass and approval takes waaaaaaaaaaaaaaaaaaaay too long.
We don't need that level of bullshit in our lives just because ARS has legal problems or wants to pop more consoles. Trust me, I sent ARS over 6000 signups during the past 12 months, and they run a solid, if genenric program. However with all the things I have to do each day, you can bet that any additional steps aren't welcome, period.
This new system is designed to net ARS/Global more money while protecting Global's legal liabilities, Marc De has even said words to that effect on the ARS message boards. At least they're honest, but I'm taking my 500 signups a month elsewhere.
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