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There also might be a bit of a loophole in the law as well - perhaps someone with a better understanding can expand on it, but I believe you can be an 'Agent' of an existing RFD with little or no checks involved.
I believe that some RFD's have exploited this loophole and made all of their delivery drivers 'agents' so they legally fulfill the face-to-face only requirement.. since the delivery driver is an 'RFD' he can sell face-to-face at your front door.
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