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Transcript of Public Hearing for Ruleset 2023-80 LR  
00:00:12 Mitchell Page  
Alright good morning, everyone. We're going to get this started.  
This is a public hearing on the proposed administrative ruleset entitled private security guard and  
security alarm agencies. This hearing is being conducted pursuant to provisions of the  
administrative procedures act and the private security business and security alarm act on behalf  
of the Department of Licensing and Regulatory Affairs, Corporations, Securities, and  
Commercial Licensing Bureau. This hearing is being called to order at 9:02 AM on May 20th,  
2025, at the offices of CSCL in Lansing Michigan. This hearing was published in 3 newspapers  
of general circulation as well as the Michigan Register published on May 15th, 2025. My name  
is Mitchell Page, and I will be facilitating this hearing today. Please know per the provisions of  
the administrative procedures act, this public hearing will not take the form of a question-and-  
answer session.  
We are here today to receive your comments and questions on the proposed rules. If you wish to  
speak, please make sure you've signed in and indicated your willingness to speak. I'll call him the  
speakers in the order in which the names are listed. When you come forward to speak you can  
come up and sit here or stand if you wish whatever you're comfortable with.  
Please identify yourself with your name and the organization you represent, and it looks like we  
have your e-mail so we're good there.  
If you have additional comments in writing or if anyone else you know does, you may leave  
them at the desk up there or submit them to the department no later than 5:00 PM this Friday  
May 23rd, 2025.  
So, let's get started first up we got Adam Nelson.  
00:02:16 Adam Nelson  
Forgive me on this, I have not been to one of these meetings before so I will try to be brief. My  
name is Adam Nelson, I'm the director of operations of Cerberus Security. We're based out of  
Muskegon. We do have multiple states that we are licensed in, so we have a lot of understanding  
of what we're dealing with, the rules and regulations that covers security. So, in comparison,  
Michigan is well, kind of referred to as the wild, wild west. There's very few rules, very few  
regulations, and in in some cases that's a benefit and in others it's definitely a negative.  
Especially in the competing agency market when you're dealing with so little regulation - which  
again, I'm not a fan of regulation, but I am a fan of smart regulation - but when you're when  
you're trying to do an apples-to-apples or oranges-to-oranges comparison then you're really  
bidding against or competing with an apples against an orange it's an entirely different world so  
it's uh, further clarification of a lot of the rules.  
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As well as possibly the adoption of more - especially in the armed market - but just as far as the  
rules that are already proposed here, we personally have no issues with those, however we do  
seek to clarify a few things that it mentions specifically that there will be clarification in the  
contractor portion of things but yet I don't know where that clarification of the contractor portion  
is because it doesn't actually mention it specifically in the rules change, it just mentions that in  
the, the meeting notes here. So, if there could be some clarification on that that would be greatly  
appreciated. But also, when referencing the uniform code, is there any provision to that for plain-  
clothed security? Because, as an example, for executive protection you're not necessarily going  
to be in full uniform you're going to be in a suit or what have you but yet you're still qualifying  
through the state rules under security guard.  
Then also along the same lines would be rather than executive protection would be a loss  
prevention person is going to be plain clothes, they're going to be blending in in their  
environment they're not going to be wearing a uniform so we would like to have some further  
clarification on that but other than that just simply other questions that can be handled separate  
and aside from this meeting.  
00:05:17 Mitchell Page  
That's excellent, thank you Adam.  
Next up looks like Mike McDaniel indicated.  
00:05:39 Mike McDaniel  
Good morning. Mike McDaniel, I’m a managing partner and general counsel for City Shield  
Security. We are a woman-owned small business in the city of Detroit. Been in business for 10  
years. Have a couple of concerns with the rules that I would like to bring to your attention.  
The first is with rule 3, under badges the rules proposed rule states that the badge must not be  
star shaped, and it must not resemble a law enforcement personnel badge that could deceive or  
confuse the public. That is written in the conjunctive so that it means to the reader that it, that it  
must fit both of those.  
So, star shape and must not resemble a law enforcement personnel badge? If that is meant to be  
an “or” in the disjunctive, then it would be highly confusing because and “or” would suggest that  
a badge by a security guard cannot resemble a security guard company, could not resemble a law  
enforcement personnel badge. We have a number of problems with that; I suggest that maybe it  
means in the disjunctive because on LARA’s website I see the following guidance: quote, a  
badge or shield may not resemble that of a local police department, The County Sheriff’s  
Department, or the Michigan State Police, giving you examples there.  
So, there's a there's a concern there. First, the word resemble is entirely subjective. Resemble  
under Merriam Webster dictionary just means must “look like” or “it seems to be the same as it  
is”, and in my mind it is. We’ve got a problem with vagueness there, it seems over broad. And  
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most importantly it doesn't provide the security companies fair notice of the conduct that's being  
regulated there.  
There are something like 550 to 560 different police agencies in the state of Michigan. They all  
have their own badges. They pride themselves on having different badges just as security guard  
companies do, and whether or not we quote-unquote “resemble a law enforcement personnel  
badge” is going to be very problematic.  
In essence, agents or officers for LARA would be making a sort of a subjective arbitrary decision  
as to whether the shape, the coloration, internal graphics, the wording, any other accoutrements  
of the badge or the patch of a private security companies resembles that of a police badge.  
Secondly, looking to rule 4. Rule 4 has certain words that cannot be used by security guard  
agencies. The one that we have a problem with is the word officer. If you look at the definition of  
peace officer in the state of Michigan at MCL 750.215(5), it lists officers and it specifically says  
an officer of the state police, an officer of a police department, a security employee by the state  
police or the state, a conservation officer, a motor carrier officer, a park and recreation officer, a  
state forest officer, a federal law enforcement officer.  
There are, in all of those cases there's a modifier in front of the word officer for clarity as to the  
type of officer, which is being uh, which is considered law enforcement within the state. The  
word “officer” by itself is way too broad. Without any modification to the word officer, there's no  
intention to the rule. An officer is generally considered one with some responsibility, with uh,  
functions and duties of an officer in a position of trust. and so it could refer, if there's no  
modifier, it's unknown to the reader whether you intend to refer to a military officer, or peace  
officer, or corporate officer, a publicly elected officer or others. We ask that you delete the word  
officer as the intent of the rule is very clear by using the words police, sheriff, deputy peace  
officer, and marshal, which are certainly all mentioned within the statute that I just cited for the  
definition of law enforcement officers.  
Finally, one that needs clarification. Rule 6 refers to an employee - excuse me - an employer  
shall conduct an annual multi-jurisdictional criminal background check of employees to meet the  
requirements of section 10. Section 10 of the act refers to any of the officers, directors, partners,  
or manager. And then in essence requires a background check because you have to assure that  
they have not been convicted of a felony or misdemeanor. So, the clarification needed under uh  
proposed rule 6(2) is that employees as used in the rule - and it refers to section 10 - is to be  
limited to the officers directed part directors, partners, or managers of a security agency and not  
every single employee.  
Doing a uh, an annual multi-jurisdictional criminal background check on every employee  
employed by a security company would be an incredibly onerous business given the nature of the  
business, the number of employees that large security companies have and the fact that some  
individuals are there for 6 months and then they leave.  
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We certainly do a criminal background check on every employee when we hire them, but to do  
an annual check on every single employee would be too onerous. So those are my comments I  
thank you for your time and we will also submit this in writing.  
00:11:56 Mitchell Page  
Excellent thank you Mike.  
Alright and then we have Stephen Alexander who wishes to speak.  
00:12:17 Stephen Alexander  
Alright good morning. Thank you for having me. My name is Stephen Alexander I represent  
Alliance Risk Mitigation Strategies. Fairly new security company based here in Lansing,  
Michigan.  
I think first I want to join in with the comments that were made prior to me the, the vagueness  
and some of the terminology, the considerations for the for the big companies as it were, for me  
the small guy so to speak my concern, and I think I'll phrase it as a request for clarification.  
This rule 5, daily supervision. As I understand this statement, the qualifying officer needs to have  
it says operational supervision of the agency and David so to me what that says is that someone  
who has an office you know in Lansing is in the office and in Detroit can't have the same. Or  
would you call it can't have the same qualifying officer because you know I may have  
stipulations for this is what needs to happen that's how it goes that doesn't to me satisfy the daily  
operational supervision of the agency component if it does great if I'm mistaken, great, but if not  
I would very much appreciate some clarification on that.  
Yeah, they covered the other one. The other one was about the badges so that's it. So those are  
my concern, clarification on the rule number 5.  
00:14:09 Mitchell Page  
Alright, thank you. Did we have anyone else that wished to speak?  
OK.  
And then the gentleman who just walked in can you make sure to sign in? OK, excellent and you  
don't, do you wish to speak at all? OK.  
Alright, we are going to close out the hearing at this time if there's no further comments. I hereby  
declare that the hearing is closed. Any additional comments regarding the proposed rules you  
may submit in writing to myself, Mitchell Page. My e-mail is [email protected] , the  
record will remain open until this Friday, May 23rd, 2025, at 5:00 PM. The current time is 9:16  
AM and we are done thank you.  
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