BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                      



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          |SENATE RULES COMMITTEE            |                  AB 2035|
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                                 THIRD READING


          Bill No:  AB 2035
          Author:   Bradford (D)
          Amended:  8/21/12 in Senate
          Vote:     21

           
           SENATE HUMAN SERVICES COMMITTEE  :  7-0, 6/12/12
          AYES:  Liu, Emmerson, Berryhill, Hancock, Strickland, 
            Wright, Yee
           
          SENATE APPROPRIATIONS COMMITTEE  :  7-0, 8/16/12
          AYES:  Kehoe, Walters, Alquist, Dutton, Lieu, Price, 
            Steinberg
           
          ASSEMBLY FLOOR  :  73-0, 4/30/12 - See last page for vote


           SUBJECT  :    Electronic benefits transfer cards:  skimming

           SOURCE  :     Western Center on Law and Poverty


           DIGEST  :    This bill protects recipients of CalFresh 
          benefits from losses due to the practice of electronic 
          skimming of their electronic benefit transfer (EBT) cards. 

           Senate Floor Amendments  of 8/21/12 clarify the definition 
          of the electronic theft of benefits in which the EBT card 
          itself is not used by the perpetrator of the theft, 
          commonly known as "skimming," and provide clarification of 
          the Department of Social Services' process to replace lost 
          benefits due to skimming.

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           ANALYSIS  :    

          Existing law:

          1. Establishes, under federal law, the Supplemental 
             Nutrition Assistance Program (SNAP) pursuant to the Food 
             Stamp Act of 1964.

          2. Establishes, under state law, the CalFresh program, 
             which provides assistance using federal SNAP funds to 
             low-income families in order to mitigate hunger, 
             undernutrition and malnutrition in the state.  In 
             California this is accomplished through distribution of 
             EBT cards to CalFresh recipients. 

          3. Creates through the Electronic Benefits Transfer Act an 
             EBT system to store information and distribute benefits 
             to recipients of CalFresh. Regulations issued by the 
             Department of Social Services (DSS) give counties the 
             option of also delivering CalWORKs (California Work 
             Opportunity and Responsibility to Kids) and General 
             Assistance benefits through EBT cards.

          4. Provides that a recipient does not incur any loss of 
             electronic benefits after reporting that his/her EBT 
             card of the personal identification number has been lost 
             or stolen.  

           This bill:

          1. Makes a series of findings and declarations about the 
             need to address a recipient's loss of benefits due to 
             electronic skimming.

          2. Provides that a recipient shall not incur any loss of 
             electronic benefits that are removed from his/her EBT 
             account through skimming and requires that electronic 
             benefits withdrawn by skimming be promptly replaced 
             after the recipient reports the loss, in accordance with 
             existing law governing stolen public assistance 
             issuances. 

          3. Requires that DSS establish a protocol for recipients to 
             report skimming that minimizes the burden to recipients 







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             and ensures a prompt payment of benefits.

          4. Defines skimming as a form of theft by which a 
             recipient's EBT account information, or "PIN" number, or 
             both, are accessed by an unauthorized person, who uses 
             that information to unlawfully remove funds from the 
             recipient's account.

          5. Clarifies the definition of the electronic theft of 
             benefits in which the EBT card itself is not used by the 
             perpetrator of the theft, commonly known as "skimming," 
             and provides clarification of DSS' process to replace 
             lost benefits due to skimming.
           
          Background

          EBT usage  .  Food benefits for CalFresh recipients are 
          distributed through an EBT system, which allows recipients 
          to access funds at point-of-sale terminals, automated 
          teller machines (ATMs) and other electronic fund transfer 
          devices.  EBT cards look similar to ATM debit cards, and 
          are swiped through the same machines using magnetic strips 
          to transfer information.  

          In addition to delivering CalFresh benefits through the EBT 
          system, all of California's 58 counties also deliver either 
          CalWORKs or General Assistance benefits, or both, through 
          the EBT cards.  According to DSS, in May 2012 there were 
          nearly 22.5 million EBT transactions to purchase food 
          through the CalFresh program and nearly three million cash 
          purchase or withdrawals at point-of-sale or ATM machines 
          through the cash benefit programs, CalWORKs and General 
          Assistance.

           Carpio v. Lightbourne  .  In December 2011, Evelyn Carpio 
          filed suit against DSS and its Director, Will Lightbourne, 
          claiming that DSS illegally refused to replace benefits 
          that were stolen electronically.  On October 5, 2009, 
          thieves stole $720 of CalWORKs cash assistance from her EBT 
          account, even though the EBT card never left her 
          possession.  Ms. Carpio, a single mother who works 
          part-time as a sales associate at a department store, 
          discovered the loss when she attempted to access her funds 
          at a Food4Less that afternoon.  She argued in her filing 







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          that the state provides for replacement of stolen EBT 
          benefits through the state's EBT statute, however 
          acknowledges that DSS does not have procedures in place to 
          replace lost benefits when the card itself is not stolen.  
          Although her benefits eventually were restored after two 
          years of appeals, Ms. Carpio argues in her lawsuit that 
          counties continue to deny restoration of benefits that are 
          lost through electronic theft.  The lawsuit seeks to 
          establish that DSS must replace stolen benefits in a timely 
          manner, however it does not seek to remedy the need for 
          state protocols regarding skimming theft.  The next 
          conference in the case is set before the judge on September 
          6.

           FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  Yes   
          Local:  Yes

          According to the Senate Appropriations Committee:

           One-time costs likely less than $50,000 (General Fund) to 
            DSS to develop appropriate protocols.

           Ongoing state-reimbursable county administrative costs or 
            increased staffing costs to DSS potentially in excess of 
            $50,000 (General Fund) to the extent established 
            protocols increase administrative workload to investigate 
            claims for reimbursement of benefits through skimming.

           Minimal automation costs to track recipient claims and 
            benefit reimbursement for cases subject to skimming.  

           Unknown, potentially significant ongoing costs (General 
            Fund) to DSS for reimbursement of CalWORKs grant benefits 
            that are unlikely to be recovered.  Additional ongoing 
            costs to local agencies for reimbursement of General 
            Assistance benefits.

           SUPPORT  :   (Verified  8/22/12)

          Western Center on Law and Poverty (source)
          California Bankers Association
          California Catholic Conference, Inc.
          California Coalition of Welfare Rights Organizations, Inc.
          California Reinvestment Coalition







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          Coalition of California Welfare Rights Organizations
          Consumer Federation of California
          Insight Center for Community Economic Development
          Legal Services of Northern California
          National Association of Social Workers

           ARGUMENTS IN SUPPORT  :    The author states that the 
          emerging practice of illegally "skimming" account numbers 
          and personal identification numbers (PIN) of electronic 
          cards leaves low-income recipients who rely on of CalFresh 
          benefits without protections afforded other victims of 
          theft.  A recent lawsuit highlights the lack of process 
          that would allow a victim this type of theft to recover 
          their EBT benefits.  While California law provides recourse 
          for recipients whose EBT cards have been stolen, it does 
          not extend the same protection for individuals whose EBT 
          benefits have been stolen through the act of skimming 
          because the victims never lose possession of their cards.  
          One of the primary purposes of the EBT system, as stated in 
          the EBT Act, is "to afford public social services 
          recipients the opportunity to better and more securely 
          manage their financial affairs."


           ASSEMBLY FLOOR  :  73-0, 4/30/12
          AYES:  Achadjian, Alejo, Allen, Ammiano, Atkins, Beall, 
            Bill Berryhill, Block, Bonilla, Bradford, Buchanan, 
            Butler, Charles Calderon, Campos, Carter, Chesbro, 
            Conway, Cook, Dickinson, Donnelly, Eng, Feuer, Fletcher, 
            Fong, Fuentes, Beth Gaines, Galgiani, Garrick, Gatto, 
            Gordon, Gorell, Grove, Hagman, Halderman, Hall, Harkey, 
            Hayashi, Roger Hernández, Hill, Huber, Hueso, Huffman, 
            Jeffries, Jones, Knight, Lara, Bonnie Lowenthal, Ma, 
            Mansoor, Mendoza, Miller, Mitchell, Monning, Morrell, 
            Nestande, Nielsen, Norby, Olsen, Pan, Perea, V. Manuel 
            Pérez, Portantino, Silva, Skinner, Solorio, Swanson, 
            Torres, Valadao, Wagner, Wieckowski, Williams, Yamada, 
            John A. Pérez
          NO VOTE RECORDED:  Blumenfield, Brownley, Cedillo, Davis, 
            Furutani, Logue, Smyth


          CTW:m  8/22/12   Senate Floor Analyses 








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                         SUPPORT/OPPOSITION:  SEE ABOVE

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