BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  AB 759
                                                                  Page  1

          CONCURRENCE IN SENATE AMENDMENTS
          AB 759 (Daly)
          As Amended  March 28, 2014
          2/3 vote. Urgency
           
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          |ASSEMBLY:  |     |(May 23, 2013)  |SENATE: |33-0 |(April 7,      |
          |           |     |                |        |     |2014)          |
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                (vote not relevant)

          Original Committee Reference:    B., P. & C.P.  

           SUMMARY  :  Expands the locksmith licensure exemption to include a  
          person who is licensed, certified, or registered with the Bureau  
          of Security and Investigative Services (BSIS) pursuant to the  
          Alarm Company Act, if the locksmithing duties of that person are  
          performed in combination with the installation or maintenance of  
          an alarm system, as specified, and limited to work on electronic  
          locks or access control devices that are controlled by an alarm  
          system.
            
           The Senate amendments  delete the Assembly version of this bill,  
          and instead:

          1)Exempt any person licensed, certified, or registered with BSIS  
            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 the  
            installation, maintenance, moving, repairing, replacing,  
            servicing, or reconfiguration of 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 the removal of existing hardware.  

          2)Make technical and conforming changes. 

          3)Declare that the bill is to take effect immediately as an  
            urgency statute.
           
          EXISTING LAW  :  

          1)Licenses and regulates, generally, alarm companies and  
            employees, locksmith companies and locksmiths, security  
            guards, proprietary private security employers and officers,  








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            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 under the locksmith law.  (Business and  
            Professions Code (BPC) Section 6980 et seq.)

          3)Defines "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, and does not include a  
            person whose activities are limited to making a duplicate key  
            from an existing key.  (BPC Section 6980(j))

          4)Prohibits a person from engaging in the activities of a  
            locksmith unless he or she holds a valid locksmith license, is  
            registered under the locksmith law, or is exempt from the  
            provisions of the locksmith law.  (BPC Section 6980.10)

          5)Exempts from locksmith licensing requirements certain  
            individuals and practices, including tow truck operators,  
            retail services limited to rekeying and recombination of  
            locks, law enforcement officers, firefighters, emergency  
            medical personnel, and new motor vehicle dealers.  (BPC  
            Section 6980.12)

          6)Exempts from locksmith licensing requirements 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.  (BPC  
            Section 6980.12(e))

          7)Licenses and regulates alarm company operators and certifies  
            and registers employees of alarm companies, including alarm  
            agents, under the Alarm Company Act.  (BPC Section 7590 et  
            seq.)

          8)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  








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            systems, or who responds to alarm systems, except for any  
            alarm agent, as specified.  (BPC Section 7590.2)

          9)Defines "alarm agent" to mean a person employed by an alarm  
            company operator whose duties include selling on premises,  
            altering, installing, maintaining, moving, repairing,  
            replacing, servicing, responding, or monitoring an alarm  
            system, or a person who manages or supervises a person  
            employed by an alarm company to perform any of those duties or  
            any person in training for any of those duties.  (BPC Section  
            7590.1(o))

           FISCAL EFFECT  :  According to the Senate Appropriations  
          Committee, pursuant to Senate Rule 28.8, negligible state costs.  
           

           COMMENTS  :

          1)This bill expands the locksmith license exemption to include  
            an alarm company operator or employee if the locksmithing  
            duties of that person are performed in combination with the  
            installation or maintenance of an alarm system, as specified,  
            in order to reflect new technologies in alarm systems and  
            eliminate duplicative licensure requirements.  Authorizing  
            alarm companies to install and maintain locks that are part of  
            an alarm system and for which they have special expertise  
            without requiring dual licensure or the use of an outside  
            professional would reduce the cost of doing business, which  
            would also benefit consumers.  The bill is sponsored by ADT  
            Security Services.

          2)According to the author, "Currently, [some] alarm companies  
            are required by law to undergo two background checks by the  
            Bureau of Security and Investigative Services (BSIS) as both  
            an alarm company and as locksmiths.

          "Since some security systems allow the ability to remotely lock  
            and unlock doors, BSIS has determined that alarm companies  
            must obtain a secondary locksmith license to continue business  
            operations.

          "Current [statutes] relating to alarm companies [do] 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  








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            room temperature. Installation and altering of locking  
            mechanisms is a major service component of these security  
            systems.

          "Whereas locksmiths must be licensed by the state, certain  
            professions such as tow truck operators and re-possessors are  
            not required to do so.  [This bill] streamlines state law on  
            locksmith licensing requirements, as well as reflects  
            technological advances in home security systems, by exempting  
            alarm companies from locksmith licensing requirements if the  
            management of locks is part of their service models.

          "Recent Senate [amendments] further clarified the conditions  
            upon which an exemption would apply for alarm companies."

          3)Many alarm companies incorporate the use of electronic  
            surveillance systems that monitor door locks and allow the  
            alarm company or the owner to remotely lock and unlock doors  
            of a building.  Under existing law, 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.       
             

          SB 1077 (Price), Chapter 291, Statutes of 2012, authorized alarm  
            companies to be organized and licensed by BSIS as a limited  
            liability company (LLC).  Initially, alarm companies licensed  
            as LLCs sought to become licensed as locksmiths; however, it  
            was found that licensed locksmiths are not authorized to  
            organize as LLCs.  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 the BSIS.

          The proponents of this bill contend that requiring an alarm  
            company to also be licensed as a locksmith is unnecessary and  
            duplicative, since both are under the jurisdiction of the  
            BSIS, and that the bill makes clear that the exemption only  
            applies to door locks that are part of an overall alarm  
            system.  

          4)According to the sponsors, "Advances in technology have  
            allowed traditional alarm companies to expand their system  
            capabilities to include additional features.  Alarm companies  








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            can now offer customers the ability to receive text and video  
            alerts from their homes, view real time video, remotely adjust  
            and monitor the heating and air conditioning systems for  
            comfort or energy efficiency, and control lighting and door  
            locks as part of the overall alarm system.

          "Recently, it has come to our attention, and that of BSIS, that  
            alarm companies be licensed and background checked as both  
            alarm companies and as locksmiths due to the fact that some  
            security systems include the ability to remotely lock and  
            unlock doors.  This double-licensure is required despite the  
            fact that these locks are ancillary to the work alarm  
            companies perform.  Licensing requirements and other  
            regulations should be commensurate with the responsibilities  
            performed.  In this case, requiring alarm companies to also  
            hold locksmith licenses is duplicative and unnecessary.

          "[This bill] builds on an existing exemption within the  
            Locksmith law that was provided to the repossessor industry.   
            The door locks that are included in this exemption are as much  
            a part of the alarm system as all the components that make up  
            that system, and [the] recent amendments make it clear that  
            the exemption is only for locks that are part of an overall  
            alarm system.  Alarm companies will 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."

          5)According to the California Locksmith's Association (CLA),  
            "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] 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 [this bill].

          "There is no urgent need for the California Legislature to enact  
            AB 759 as an urgency measure. Instead of the proposed  








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            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."

          6)This bill was substantially amended in the Senate and the  
            Assembly-approved version of this bill was deleted.  This  
            bill, as amended in the Senate, is inconsistent with the  
            Assembly actions and the provisions of this bill, as amended  
            in the Senate, have not been heard in an Assembly policy  
            committee.  
           

          Analysis Prepared by  :    Eunie Linden / B., P. & C.P. / (916)  
          319-3301


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