BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                            



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                                    THIRD READING


          Bill No:  AB 759
          Author:   Daly (D)
          Amended:  3/28/14 in Senate
          Vote:     27 - Urgency

           
          PRIOR VOTES NOT RELEVANT

           SENATE BUSINESS, PROF. & ECON. DEV. COMM  : 9-0, 1/13/14
          AYES:  Lieu, Block, Corbett, Galgiani, Hernandez, Hill, Padilla,  
            Wyland, Yee
          NO VOTE RECORDED:  Vacancy

           SENATE APPROPRIATIONS COMMITTEE  :  Senate Rule 28.8


          SUBJECT  :    Alarm companies

           SOURCE  :     ADT Security Services


           DIGEST  :    This bill expands the locksmith license exemption to  
          include a person licensed, certified, or registered with the  
          Bureau of Security and Investigative Services (BSIS), pursuant  
          to the Alarm Company Act, if the duties of the person that  
          constitute locksmithing are performed in combination with  
          installing, maintaining, moving, repairing, replacing,  
          servicing, or reconfiguring an alarm system, as defined, and  
          limited to work on electronic locks or access control devices  
          controlled by an alarm system control device, including removing  
          existing hardware.

           Senate Floor Amendments  of 3/28/14 separately list the proposed  
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          exemption from the locksmith law for alarm companies and the  
          existing exemption for repossessors; clarify that the alarm  
          company exemption only applies to work on an electronic lock  
          that is connected to an alarm system; and make technical and  
          conforming changes.

           ANALYSIS  :    

          Existing law:

          1.Licenses and regulates alarm companies and employees,  
            locksmith companies and locksmiths, security guards,  
            proprietary private security employers and officers, private  
            investigators, private patrol operators, and repossession  
            agencies and their employees by the BSIS within the Department  
            of Consumer Affairs (DCA).

          2.Licenses and regulates locksmiths and registers employees of  
            locksmiths by the BSIS by:

             A.   Defining "locksmith" to mean any person who, for any  
               consideration or compensation, engages in the business of  
               rekeying, installing, repairing, opening or modifying  
               locks, or who originates keys for locks, including  
               electronic cloning of transponder keys and any other  
               electronic programming of automotive keys and electronic  
               operating devices, such as key fobs, door and ignition key  
               devices, and successive electronic and other high-security  
               key technology.  A "locksmith" does not mean a person whose  
               activities are limited to making a duplicate key from an  
               existing key.  

             B.   Prohibiting a person from engaging in the activities of  
               a locksmith unless he/she holds a valid locksmith license,  
               is registered under the locksmith law, or is exempt from  
               the provisions of the locksmith law.

             C.   Exempting from locksmith licensing and regulation  
               certain individuals and practices, including, but not  
               limited to, tow truck operators, retail services limited to  
               rekeying and recombination of locks, law enforcement  
               officers, firefighters, emergency medical personnel, and  
               new motor vehicle dealers. 


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             D.   Further exempting from locksmith licensing a person  
               registered with the BSIS as an employee of a repossessor,  
               if the duties constituting locksmithing are ancillary to  
               the primary duties and functions of the person's position.   


          1.Licenses and regulates repossession agencies, as defined,  
            repossessors, and repossessor qualified managers by BSIS under  
            the Collateral Recovery Act.  

          2.Licenses and regulates alarm company operators and certifies  
            and registers employees of alarm companies, including alarm  
            agents, under the Alarm Company Act; defines "alarm company  
            operator" to mean any person who, for any consideration,  
            engages in business or accepts employment to install,  
            maintain, alter, sell, monitor, or service alarm systems, or  
            who responds to alarm systems, except for any alarm agent, as  
            specified; and provides that a "person" under this Act means  
            any individual, firm, company, association, organization,  
            partnership, limited liability company (LLC), or corporation.   


          This bill:

          1.Exempts a person licensed, certified, or registered under the  
            Alarm Company Act from locksmithing requirements, as  
            specified, if the duties of that person's position that  
            constitute locksmithing are performed in combination with  
            installing, maintaining, moving, repairing, replacing,  
            servicing, or reconfiguring an alarm system, as defined, and  
            limited to work on electronic locks or access control devices  
            that are controlled by an alarm system control device,  
            including removing existing hardware.

          2.Makes technical and conforming changes.

           Background
           
          The current issue in this bill relating to alarm companies  
          carrying out certain locksmithing functions was raised late in  
          the first year of this Session by the bill's sponsor.  SB 1077  
          (Price, Chapter 291, Statutes of 2012) authorized an alarm  
          company to be organized and licensed by BSIS as an LLC.


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          In applying this new business structure, licensed alarm  
          companies have ran into difficulty because of the crossover  
          between the practice of locksmithing and alarm companies in  
          installing and monitoring electronic surveillance systems that  
          monitor door locks and allow the alarm company and/or the owner  
          to remotely lock and unlock the doors of a building.  Under the  
          provisions of the Locksmith Act, only a licensed locksmith can  
          install and maintain such a system.  Therefore, in order for a  
          licensed alarm company to install door locking devices in an  
          alarm system, the alarm company must either obtain a locksmith  
          license or employ or hire a licensed locksmith to carry out  
          those activities.  Initially, alarm companies licensed as LLCs,  
          sought to become licensed as locksmiths; however, it was found  
          that licensed locksmiths are not allowed to be organized as LLCs  
          under the law.  In addition, since the practice of locksmithing  
          and alarm companies are both licensed and regulated by BSIS,  
          both types of licensees must undergo criminal background checks  
          by BSIS.  

          The proponents of this bill contend that requiring an alarm  
          company to also be licensed as a locksmith, or to use a licensed  
          locksmith is unnecessary and duplicative, since both are under  
          the jurisdiction of the BSIS.  In addition, proponents would  
          suggest this bill narrowly addresses the issue by authorizing  
          only those locksmithing functions that are ancillary to the  
          primary duties and functions of the alarm company practice.

           Comments
           
          According to the author's office, alarm company operators and  
          locksmiths are licensed and regulated by BSIS.  Current statue  
          relating to alarm companies does not reflect the emerging home  
          automation security market.  Home automation security systems  
          include the ability to control locks, turn off lights remotely,  
          open and close window blinds, and adjust room temperature.   
          Installation and altering of locking mechanisms is a major  
          service component of these security systems.  

          The author's office states, that whereas locksmiths must be  
          licensed by the state, certain professions such as tow truck  
          operators and repossessors are not required to do so.  This bill  
          will exempt alarm companies from being required to obtain a  
          locksmith license if locksmithing is part of its service model.


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

           SUPPORT  :   (Verified  4/1/14)

          ADT Security Services (source) 
          California Alarm Association

           OPPOSITION  :    (Verified  4/1/14)

          Accurate Security Pros, Inc.
          California Locksmiths Association
          La Jolla Security Systems, Inc.
          Reed Brothers Security
          Spectrum Security Systems, Inc.
          Warman Security

           ARGUMENTS IN SUPPORT  :     The bill's sponsor, ADT Security  
          Services, argues:  "Licensing requirements and other regulations  
          should be commensurate with the responsibilities performed.  In  
          this case, we believe requiring alarm companies to also hold  
          locksmith licenses is duplicative and unnecessary.  AB 759  
          builds on an existing exemption within the Locksmith Law that  
          was provided to the repossesser industry, because their work  
          with locks is ancillary to their primary duties, just as they  
          are for alarm companies.  Alarm companies should continue to be  
          fully licensed as alarm companies, but we do not believe that  
          they should need a second, duplicative license from the BSIS to  
          offer their products within the State of California."

          The California Alarm Association states:  "The security industry  
          is advancing in leaps and bounds.  Many new security systems  
          allow homeowners and businesses to control their security  
          systems from their phones or other remote devices.  Alarms  
          systems, lights, climate controls, and door locks can now all be  
          controlled remotely.  Installing these new technologically  
          advanced systems requires alarm companies to install new door  
          locks.  Technically this work could be construed to be  
          locksmithing, which would require the alarm company to get a  
          locksmithing license.  However, securing a second license is  
          redundant because both locksmiths and alarm companies are  
          licensed by the BSIS and undergo the same background checks and  
          other similar application processes.  AB 759 would remove a  
          costly and burdensome redundancy in the licensing process by  

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          allowing alarm companies to install new door locks as long as  
          they are part of a new security system."  

           ARGUMENTS IN OPPOSITION  :    Opponents state that this bill will  
          "allow those without the proper training and licensing to  
          install door hardware that could endanger the life and safety of  
          consumers."

          According to the California Locksmiths Association, "Employees  
          of alarm companies would not be required to follow the consumer  
          protection requirements provided in the Locksmith Act.   
          Fragmenting the Locksmith Industry would make it more difficult  
          to regulate.  This exemption would make it more difficult to  
          pass future consumer protection legislation to protect consumers  
          of locksmith services.  The bill would cause confusion.  Two  
          different technicians (lock and alarm) while performing the same  
          type of work on the same type of door would be held to two  
          different standards.  One would have to follow the Locksmith Act  
          and one would not.  The consumer would not know that they are  
          not afforded the same level of consumer protection.  There would  
          be no state oversight of the locksmithing activities alarm  
          companies would be providing under the exemption proposed by AB  
          759.  AB 759 would enable locks to be installed without state  
          oversight protecting public safety and providing consumer  
          protection.  There is no urgent need for the California  
          Legislature to enact AB 759 as an urgency measure.  Instead of  
          the proposed expedited rush towards a new exemption from  
          consumer protection, the development and implementation of new  
          technologies in the field of home automation security systems  
          support a thorough review of these technologies and the  
          identification of appropriate protections for consumers who  
          purchase these products and services. ? There is no finding that  
          the California Locksmith Act is preventing consumers from  
          promptly securing residential and business properties using  
          alarm systems with automated locking features that warrants the  
          AB 759-proposed exemption from the Act."  
           

          MW:nl  4/2/14   Senate Floor Analyses 

                           SUPPORT/OPPOSITION:  SEE ABOVE

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