I don't see how he can answer that question on a forum without putting himself in jeapordy. How can he interpret a law that hasn't gone into effect?
How exactly does it put him in more jeopardy then previously. If he's retaining them, people need to know so try know who to go to if they have withdrawal problems. If he's passing them onto some other escrow the. It'll also be publicly known for the same reasons.
Last time I checked the wording for the law/statute is always in place and fixed (subject to amendments b parliament) so they don't exactly change before the bill is officially enacted. The law should be pretty clear on what it's stating and generally relatively easy to understand.