BILL ANALYSIS Ó SB 1234 Page A Date of Hearing: June 22, 2016 ASSEMBLY COMMITTEE ON LABOR AND EMPLOYMENT Roger Hernández, Chair SB 1234 (De León) - As Amended June 15, 2016 SENATE VOTE: 26-13 SUBJECT: Retirement savings plans SUMMARY: Provides legislative approval for the California Secure Choice Retirement Savings Program (SCRSP) and sets forth recommendations and requirements for the design and implementation of that program. Specifically, this bill: 1)Incorporates the findings and recommendations of the California Secure Choice Retirement Savings Investment Board (Board) that were made upon conclusion of the market analysis authorized in the original version of SB 1234 (De Leon, Chapter 734, Statutes of 2012) and deletes obsolete requirements that are inconsistent with those findings. 2)Defines a provider of in-home supportive services as an employer if the Board determines their inclusion to be legally permissible under federal and state laws and regulations. (Section 100000, 100046) 3)Requires that contract administrators and consultants also discharge their duties as fiduciaries with respect to the SB 1234 Page B program. (Section 100002) 4)States that investment policy decisions, including asset allocation and investment options, shall be entrusted to the Board subject to its fiduciary duties; specifies that the primary objective of the investment policy is, through pooled investing, to leverage economies of scale, lower risks, and provide participants with stable and reasonable rate of return; and eliminates language limiting the Board's options as to which asset categories it may consider. (Section 100002) 5)Provides that the California Secure Choice Retirement Savings Trust (Trust) is an instrumentality of the state and that any security issued, managed, or invested by the Board shall be exempt from specified provisions of law regarding the qualification of securities for sale. (Section 100004) 6)Eliminates language requiring the Board to annually adopt a stated rate of return for the following program year and stating that an individual's retirement savings benefit under the program shall be equal to the balance in the individual's account at retirement. (Section 100008) 7)Requires the Treasurer to appoint an executive officer for the program who shall serve at the pleasure of the Board. The Board may authorize the director to enter into contracts or conduct business on behalf of the Board. The Treasurer shall determine the duties of the executive director and other necessary staff and set his or her compensation. (Section 100010) 8)Requires the Board to collaborate with and evaluate the role of insurance and financial advisors in assisting and providing guidance for eligible employers and employees. (Section 10010) 9)Authorizes the Board to disseminate educational information designed to educate participants about the benefits of planning and saving for retirement and information to help SB 1234 Page C them decide the level of participation and savings strategies that may be appropriate for them. (Section 100012) 10)Eliminates the requirement for the Board to ensure that an insurance, annuity or other funding mechanism is in place at all times that protects the value of individuals' accounts and holds the state harmless. (Sections 100012, 100036) 11)Changes the timeframes of implementation requirements for employers to the following and allows the Board to extend the timelines if it deems necessary (Section 100032): a) Within 12 months after opening of enrollment, employers of 100 or more employees (that do not offer an employer-sponsored retirement plan or automatic enrollment payroll deduction IRA) must have an arrangement to allow employees to participate in the SCRSP. b) Within 24 months after opening of enrollment, employers of 50 or more employees (that do not offer an employer-sponsored retirement plan or automatic enrollment payroll deduction IRA) must have an arrangement to allow employees to participate in the SCRSP. c) Within 36 months after opening of enrollment, employers of five or more employees (that do not offer an employer-sponsored retirement plan or automatic enrollment payroll deduction IRA) must have an arrangement to allow employees to participate in SCRSP. 12)Allows the Board to implement annual automatic escalation of employee contributions subject to the following limitations (Section 100032): a) Contributions subject to automatic escalation cannot exceed 8 percent. b) Automatic escalation cannot amount to more than a 1-percent-of-salary increase in employee contributions per SB 1234 Page D calendar year. c) An employee may opt out of automatic escalation and set his or her contribution rate at a level determined by the employee. 13)Allows the Board, unless otherwise specified by the employee, to adjust the employee contribution into the SCRSP between 2 percent and 5 percent. (Section 100032) 14)Provides that an employer shall not have civil liability, and no cause of action shall arise against an employer, for acting pursuant to the regulations prescribed by the board defining the roles and responsibilities of employers that have a payroll deposit retirement savings arrangement to allow employee participation in the program. (Section 100034) 15)Eliminates requirements for the Board to conduct an initial market analysis and to present findings to the Legislature before the SCRSP may be implemented, and related statutes. (Sections 100040, 100042. 100043.5) 16)Provides that, prior to opening the program for enrollment, the Board shall report to the Governor and Legislature the specific date on which the program will start to enroll program participants and that the following prerequisites and requirements for the program have been met: a) The United States Department of Labor has finalized a regulation setting forth a safe harbor for savings arrangements established by states for nongovernmental employees for the purposes of the federal Employee Retirement Income Security Act. b) The SCRSP is structured in a manner to meet the criteria of the United States Department of Labor regulation. SB 1234 Page E c) The payroll deduction IRA arrangements offered by the SCRSP qualify for the favorable federal income tax treatment ordinarily accorded to IRA arrangements under the Internal Revenue Code. d) The Board has defined in regulation the roles and responsibilities of employers pursuant to the criteria outlined in specified United States Department of Labor regulation described and any associated guidance. e) The Board has adopted an operational model that limits employer interaction and transactions with the employee to the extent feasible. (Section 100043) 17)Expresses the approval of SCRSP by the Legislature and its implementation as of January 1, 2017, and requires the Board, subject to its fiduciary responsibility, to design and implement SCRSP while utilizing and considering the following parameters (Section 100046): a) For up to three years, the Board may establish managed accounts invested in U.S. Treasuries or similarly safe investments, during which time the Board may develop investment options that address risk-sharing and smoothing market gains and losses, as specified. b) The Board shall seek to minimize participant fees. c) The Board shall strive to implement features that provide maximum income replacement balanced with appropriate risk in an IRA based environment. d) The Board shall determine the default payout method for retirees. e) The Board shall include a provider of in-home supportive services in the SCRSP if it determines the inclusion to be SB 1234 Page F legally permissible under federal and state laws and regulations. f) The Board shall structure SCRSP so as to ensure that the state is prohibited from incurring liabilities associated with administering the program and that the state has no liability for the program or its investments. g) The Board shall determine all necessary costs related to SCRSP, as specified. h) The Board shall partner with employer representatives to create an administrative structure that addresses employer needs, as specified. i) The Board shall include comprehensive worker education and outreach and may collaborate with public and nonprofit agencies and organizations and other entities to develop education and outreach, as specified. j) Requires the Board to include comprehensive employer education and outreach with an emphasis on employers with less than 100 employees, with the integration of the following components: a. A program Web site to assist the employers of participating employees. b. A toll-free help line for employers with live and automated assistance. c. Online Web training. d. Live presentations to business associations. e. Targeted outreach to small businesses with 10 or less employees. 1)Gives the Board flexibility to design SCRSP in order to ensure timely implementation and states that the parameters are not SB 1234 Page G conclusive but may be augmented as needed to fully implement the program and comply with the Board's fiduciary duties. (Section 100046) 2) Allows the Board to adopt emergency regulations for the purposes of implementing the SCRSP. (Section 100048) 3) Specifies that a payroll IRA arrangement offered pursuant to SCRSP shall have the same status and be treated consistently with any other IRA qualified under specified federal law for the purpose of determining eligibility or benefit level for a program that uses a means test. (Section 100049) 4) States that start-up and first-year administrative costs for SCRSP may be appropriated from the General Fun dand shall be repaid by the Board with interest calculated at the rate of the Pooled Money Investment Account. Future administrative costs shall be paid from the administrative fund. (Section 100050) 5) Makes other minor, technical, and clarifying changes. EXISTING LAW: 1)Establishes the California Secure Choice Retirement Savings Investment Board, as defined, and the California Secure Choice Retirement Savings Trust, a continuously appropriated fund, for the purpose of creating a statewide program known as SCRSP. 2)Defines who shall be appointed to the Board, the Board's fiduciary role, and entrusts the Board with investment policy oversight and design. SB 1234 Page H 3)States that the primary objective of the investment policy is to preserve the safety of principle and provide a stable and low-risk rate of return, as specified. 4)Requires that the program include, as determined by the Board, one or more payroll deposit individual retirement account (IRA) options; requires the Board to annually declare a stated rate of return at which interest shall be allocated to program accounts for the following year; and states that an individual's retirement savings benefit under the program shall be an amount equal to the balance in the individual's account on the date the retirement savings benefit becomes payable. 5)Defines the Board's duties and powers, in the capacity of trustee to administer and invest the Trust, and establishes guiding principles and restrictions for investment policy of Trust assets, and limits the types of investments which shall be permitted for the investment of funds. 6)Requires the Board to ensure that an insurance, annuity or other funding mechanism is in place at all times that protects the value of individuals' accounts. Such funding mechanism shall protect, indemnify and hold the state harmless at all times against any and all liabilities in connection with funding retirement benefits under the SCRSP. 7)Provides that the state shall not have any liability for the payment of the retirement savings benefit earned by SCRSP participants. The state, and any of the funds of the state, shall have no obligation for payment of the benefits arising from the SCRSP. 8)Clarifies that employers shall not be fiduciaries of the SCRSP nor be liable for employees' investment decisions. 9)Provides that after the Board opens the SCRSP for enrollment, any employer may choose to have a payroll deposit retirement SB 1234 Page I savings arrangement to allow employee participation in the SCRSP. Thereafter the following timeline would apply: a) Beginning three months after opening of enrollment, employers of 100 or more employees must have an arrangement to allow employees to participate in the SCRSP. b) Beginning six months after opening of enrollment, employers of 50 or more employees must have an arrangement to allow employees to participate in the SCRSP. c) Beginning nine months after opening of enrollment, employers of five or more employees must have an arrangement to allow employees to participate in SCRSP. 1) Provides that, unless otherwise specified by the employee, a participating employee shall contribute 3% of their annual salary or wages into the SCRSP (which may be adjusted by the Board to between 2% and 4%). 2) Requires the Board, using private or non-profit funds, to conduct an initial market analysis to determine whether the necessary conditions for implementation of the SCRSP can be met, as specified, and to report to the Legislature on its findings, as specified. 3) Provides that the SCRSP will only become operative if the Board determines, based upon the market analysis, that the SCRSP can be self-sustaining and only if implementation costs are made available from a nonprofit or private entity, the federal government, or a budget appropriation. 4) Provides that the Board shall not implement the SCRSP if the IRA arrangements offered fail to qualify for the favorable federal income tax treatment ordinarily accorded IRAs under SB 1234 Page J the IRC, or if it is determined that the SCRSP is an employee benefit plan under the federal Employment Retirement Income Security Act (i.e., ERISA). FISCAL EFFECT: According to Senate Appropriations Committee: "An accurate depiction of exact costs to operate the Program cannot be ascertained in advance. Costs would be determined by several factors that are currently unknown, including (1) the number of employers participating in the Program, (2) the number of employees participating in the Program, (3) costs related to recordkeeping, (4) the investment performance of the Program, and, (5) the level of contributions made by participants to the Program. In addition, the Employment Development Department would incur costs associated with program operation, and the Board would require staff and office space. Modeling done by the market analysis firm that performed the feasibility study indicates that up to $134 million would be required to finance implementation of the Program and assure that participants would not be subject to administrative fees exceeding 100 basis points. As noted previously, though the Board has determined that the Program could ultimately be operated solely from Program assets, a loan would be required to develop and implement the program during the first few years of operation. Options for startup financing include a line of credit or a General Fund loan." COMMENTS: SCRSP's Board was statutorily required to perform a feasibility study to determine whether the legal and practical conditions for implementation of SCRSP could be met. The Board approved an approach to the study analysis that included four distinct, but well-coordinated focus areas: program design, SB 1234 Page K market analysis, financial feasibility, and legal feasibility. Key Findings in the Report<1>: About 6.8 million workers are potentially eligible for the California Secure Choice Retirement Savings Program. Likely participation rates (70-90%) are sufficiently high to enable the Program to achieve broad coverage well above the minimum threshold for financial sustainability. Eligible participants in California are equally comfortable with a 3% or 5% contribution rate. The vast majority of likely participants are also comfortable with auto-escalation in 1% increments up to 10%. To start, the program should offer a default investment option consisting of a diversified portfolio with long-term growth potential and the choice to opt into a low-risk investment. Given its inherent portability, the Program should have a lower incidence of rollovers and cash-outs than employer-sponsored 401(k) plans, which often force workers with low balances to close their accounts. At the same time, pre-retirement withdrawals are likely to be higher for the Program given eligible workers' income profile. The Program launch should include a concerted public education campaign focused on workers and small businesses. Federal Regulations --------------------------- <1> SCRSP Board Report with the California State Treasurer: http://www.treasurer.ca.gov/scib/report.pdf SB 1234 Page L President Obama directed the U.S. Secretary of Labor, to issue regulations that would clarify how states could move forward with retirement plans for private sector workers without being preempted by the Employee Retirement Income Security Act (ERISA). In the fall of 2015 the U.S. DOL Employee Benefits Security Administration (EBSA) released a proposed regulation that designates a safe harbor from ERISA for state laws that facilitate enrollment in state-administered payroll deduction individual retirement accounts (IRAs). which created a safe harbor from ERISA for savings arrangements established by states for non-governmental employees. The proposed rule allows programs like Secure Choice to move forward without ERISA preemption. The catalyst for this safe harbor is the employer mandate. Employers acting pursuant to a state mandate to enroll or auto-enroll their employees into Secure Choice or a similar Individual Retirement Account (IRA) model would have no liability or fiduciary duty for the plan. These new federal regulations are expected to be finalized by summer 2016. Arguments in Support California Secure Choice Retirement Savings Investment Board writes that, "In accordance with Government Code Section 100040, the California Secure Choice Retirement Savings Investment Board (Board) finds the Secure Choice Retirement Savings Program (Secure Choice or Program) to be a feasible, sustainable, and legally permissible program that could help 6.8 million workers start saving for their future. Based on the findings of the final report, stakeholder feedback, and public comment, the Board recommends that legislative language, consistent with the following principles be adopted to SB 1234 Page M provide the Board sufficient flexibility, including if necessary repealing statutory language impeding such flexibility, so that it can shape the program as it develops and reacts to changes in the market, while protecting workers' contributions and limiting employer burdens. The Board recommends that Senate Bill 1234 allow the Board to: 1) Establish managed accounts that would be invested in U.S. Treasuries or similarly safe investments within the first three years of the program 2) The Board recognizes there are legal and practical hurdles to overcome before the various investment options could be implemented. Within the first three years, the Board should begin to develop investment options that address risk-sharing and smoothing of market losses and gains at inception. Options could include but not be limited to custom pooled, professionally managed funds that minimize management costs and fees, the creation of a reserve fund, or the establishment of investment products 3) The Board will conduct an annual peer review to compare California Secure Choice funds with similar funds on performance and fees 4) The Board will be required to seek to minimize participant fees 5) Implement program features that provide maximum possible income replacement in an IRA based environment 6) The Board will establish an initial automatic contribution rate of between 2% and 5% of salary 7) The Board may implement automatic escalation of participants' contribution rates up to 10% of salary with the option for participants to stop automatic escalation and change their contribution rates SB 1234 Page N 8) The Board and its contracted administrators and consultants shall have a fiduciary duty to the participants of the Program. Investment policy decisions, including asset allocation and investment options, will be entrusted with the Board subject to fiduciary duties 9) Include quasi-public and quasi-private workers to be enrolled if found legally permissible 10) Conduct communication and education on the Program, including the inherent risks of its investment strategy or strategies, the purposes and inherent risks of investing in U.S. Treasuries or similar safe investment options for the first three years of the Program, therefore the state does not have liability for the investment performance or payment of benefits to Secure Choice participants 11) Determine the default payout method to retirees 12) Clearly define "ministerial duties" expected of employers in the implementation of the program and limit liability for all employers if an employer inadvertently provides more than ministerial duties 13) Fully determine all necessary costs associated with outreach, customer service, enforcement, Board staffing and consultant costs, and all other costs necessary for the administration of the program and to ensure all investment options are appropriated considered by the Board for the Program 14) Make determinations on how to structure the Program to ensure the state is prohibited from incurring liabilities associated with administering the Program The board acknowledges the concerns raised by business associations and will partner with employer representatives as it creates the administrative structure to ensure their concerns are addressed. The business community is a vital stakeholder in SB 1234 Page O this work and we will ensure they are partners with us as we form the outreach and education to California businesses. The education campaign to California's employers will be a top priority as we understand that employers must not hold any liability. Additionally, it must be clear both in statute and as part of the education campaign that the State of California has no liability for the program or its investments. We encourage the Legislature and the Governor to move forward with Secure Choice. While the preliminary work for this endeavor has come to a close, there is much more to do. We must continue to collaborate with members of the Legislature, workers, businesses and other stakeholders to improve the Program as it develops. There are some outstanding legal questions with respect to how this fund would be treated by the Securities and Exchange Commission. However, these issues will not thwart the ability of the Board to implement the Program. California continues to be a thought leader on this front and believes that every worker deserves the option to retire with dignity." The California Black Chamber of Commerce is in support and argues that, "Establishing this program will play a vital role in keeping small businesses competitive and helping small business owners and their employees prepare for retirement. Retirement plans are crucial to employers' ability to attract and retain employees in today's economy; yet, many small businesses are unable to provide such a program because they do not have the resources to staff a human resources department and navigate ERISA requirements. The California Secure Choice Retirement Savings Program offers an easy way for small business owners to solve this problem by offering employees access to a retirement plan with minimal administrative responsibilities on the part of small employers and most importantly no fiduciary responsibilities. A recent poll by the Small Business Majority and AARP found two-thirds of small business owners in California support a state retirement savings program that would help small businesses and their employees save for the future. Nearly SB 1234 Page P three-fourths of respondents think offering such a program would give their business a competitive edge. Our members are always concerned about cost and administrative complexity, so as the bill moves forward, we hope you will continue to ensure that the program is simple to administer and low cost for small businesses." Arguments in Opposition The Financial Services Institute (FSI) opposes this bill, arguing that it would disrupt the already healthy and competitive retirement plan market in California. They contend that a state-run retirement plan for private employees will disrupt the pre-existing market of retirement plan providers already serving businesses of all sizes, including self-employed and non-profit organizations. The existing market of retirement plan providers consists of qualified independent financial advisors and is robust, healthy, and competitive. In addition, they argue that enrolling private employees into a state-run retirement plan will also place a heavy administrative burden on the state, and taxpayers may be forced to shoulder the costs in the event of economic difficulty. Further, employers will be saddled with the additional responsibility of ensuring their employees are enrolled in the plan and processing the necessary payroll contributions. Many small business owners do not have the time or resources for these added administrative tasks. In addition, a coalition of organizations, including the California Chamber of Commerce and the California Manufacturers & Technology Association opposes this bill unless amended. They state that they recognize the importance of encouraging people to save for retirement, and acknowledge that there is a retirement crisis facing California and our nation. However, opponents are concerned that the program that would be implemented by this bill could create costs to the state, as SB 1234 Page Q well as potential employer liabilities, costs and administrative burdens. They urge the author to include solutions to these critical issues in this bill and not simply them to be worked out by the Board. Opponents have suggested a number of amendments that would address these issues. This bill was recently amended by the author in an attempt to address many of these concerns. However, at the time of preparation of this analysis, the opponents were reviewing the amendments and it was unclear whether the amendments would change their position on this bill. Liability - In particular, opponents have raised concerns regarding potential employer liability and have expressed a desire that this bill provide indemnification for employer. They argue that when things go wrong, people will look for a target for a lawsuit and it is imperative that employers be protected. They contend that rules and procedures as well as the employer responsibilities remain vague in the legislation, which creates open ended liabilities and administrative burdens which can lead to increased costs. To strengthen protection from liability for the employer as intended by the enabling legislation, and to make it crystal clear that employers have no liability and are immune from liability associated with all aspects of the mandate and their participation in the program, they have proposed language to address these issues. In an attempt to address this concern, the author has amended the bill to provide that an employer shall not have civil liability, and no cause of action shall arise against an employer, for acting pursuant to the regulations prescribed by the Board defining the roles and responsibilities of employers that have a payroll deposit retirement savings arrangement to allow employee participation in the SCRSP. The author notes that this bill also directs the Board to partner with employer SB 1234 Page R representatives to clearly define the employers' duties and liability exemption. However, the author states that the opponents' suggested amendment requiring the state to intervene and indemnify an employer for any and all costs associated with federal litigation are unreasonable and unprecedented. Enrollment Prerequisites - Opponents also argue that the Secure Choice program should not begin to enroll employees until certain enrollment prerequisites are met, such as until the program is deemed to be in compliance with the United States Department of Labor safe harbor under ERISA, as well as other prerequisites deemed completed to ensure the program has addressed liability issues for employers. In addition, opponents state that they have a higher level of comfort with an operational model that includes a third party as the interface between employer and employee, thus limiting the interaction between employer and employee - rather than a model whereby employers must handle all employee inquiries and transactions. In response to this concern, the author has amended this bill to provide that, prior to opening the program for enrollment, the Board shall report to the Governor and Legislature the specific date on which the program will start to enroll program participants and that the following prerequisites and requirements for the program have been met: The United States Department of Labor has finalized a regulation setting forth a safe harbor for savings arrangements established by states for nongovernmental employees for the purposes of the federal Employee Retirement Income Security Act. SB 1234 Page S The SCRSP is structured in a manner to meet the criteria of the United States Department of Labor regulation. The payroll deduction IRA arrangements offered by the SCRSP qualify for the favorable federal income tax treatment ordinarily accorded to IRA arrangements under the Internal Revenue Code. The Board has defined in regulation the roles and responsibilities of employers pursuant to the criteria outlined in the federal regulations and any associated guidance. The Board has adopted an operational model that limits employer interaction and transactions with the employee to the extent feasible. Education and Outreach - Opponents also argue that employer and employee education and outreach are integral to the success of the SCRSP, yet are not adequately addressed in this proposal. They argue that, in order to facilitate the conduct of adequate outreach, this bill must include language that specifies required elements of the education and outreach plan to employers and employees in advance of enrollment, with particular emphasis on businesses with fewer than 100 employees. The Board must be required to establish the specifics of the employer outreach and education plan through consultation with employer representatives engaged through an advisory committee format. SB 1234 Page T In response to this concern, the author has amended the bill to require the Board to include comprehensive employer education and outreach in the SCRSP, with an emphasis on employers with less than 100 employees, developed in consultation with employer representatives, with the integration of the following components: A program Web site to assist the employers of participating employees. A toll-free help line for employers with live and automated assistance. Online Web training. Live presentations to business associations. Targeted outreach to small businesses with 10 or less employees. Definition of "Eligible Employer" - Opponents state that the purpose of the legislation is to give access to retirement vehicles to those who currently do not have it. If an employer is providing their employees with a retirement plan option, they should not be subject to the mandate. However, the proposed legislation, in some provisions, chooses certain retirement plans to the exclusion of others which would inappropriately limit employer options. The types of retirement savings plans that may be chosen by the employer must include the array of SB 1234 Page U choices that are federally qualified and authorized. An employer must not be limited to a choice simply between a 401(k) or the SCRSP. They also suggest the bill should be amended to include other "federally qualified retirement savings programs." The author emphasizes that automatic enrollment is critical because the goal of this legislation is for all workers to be offered a meaningful retirement savings opportunity. The author is open to discussing this issue further with the opponents, but will likely insist that there be auto-enrollment for the workers. Emergency Rulemaking - Opponents contend that regulations promulgated by the Board deserve adequate time for deliberation and collaboration. They argue that the proposed emergency rulemaking procedure in this bill may shorten the process so that meaningful participation by stakeholders would be limited. The rulemaking procedures should follow normal Administrative Procedures Act rules. If an emergency is present for a rulemaking, then it would meet the criteria for emergency rulemaking. The author responds that the emergency rulemaking process still allows for public comment, and that this provision of the bill is consistent with rulemaking authority currently held by other boards, commissions, and financing authorities that are administered through the State SB 1234 Page V Treasurer's Office. Opponents conclude that they urge the Legislature to move carefully, thoughtfully and deliberately so that employers, employees and the state are not at risk, and that the program is beneficial to those who participate. Previous Related Legislation SB 1234 (De León) Chapter 734, Statutes of 2012 created the initial statutory framework for SCRSP and required the Board to perform a market analysis and feasibility study to determine if SCRSP could be implemented and to publish its findings and bring a recommendation to the Legislature for approval. REGISTERED SUPPORT / OPPOSITION: Support American Association of Retired Persons American Retirement Association Asian Business Association California Advocacy Network for Aging Latinos SB 1234 Page W California Asset Building Coalition California Association of Nonprofits California Black Chamber of Commerce California Capital Financial Development Corporation California Commission on Aging California Conference Board of the Amalgamated Transit Union California Conference of Machinists California Council of Churches IMPACT California Employment Lawyers Association California Labor Federation, AFL-CIO California Secure Choice Retirement Savings Investment Board California Teamsters Public Affairs Council CaliforniaHealth+ Advocates SB 1234 Page X California-Nevada Conference of Operating Engineers Carson Black Chamber of Commerce CFED CIO Congress of California Seniors Corporation for Enterprise Development Courage Campaign Earned Assets Resource Network Engineer & Scientists of California, IFPTE Local 20 Fresno Metro Black Chamber of Commerce Insight Center for Community Economic Development International Longshore and Warehouse Union John Chiang, California State Treasurer SB 1234 Page Y LA Metro Hispanic Chamber of Commerce Latin Business Association Los Angeles Latino Chamber of Commerce National Council of La Raza Pico Rivera Chamber of Commerce PolicyLink Professional & Technical Engineers, IFPTE Local 21 Riverside County Black Chamber of Commerce Sacramento Black Chamber of Commerce San Francisco Office of the Treasurer and Tax Collector Service Employees International Union, California Service Employees International Union, Local 1000 Service Employees International Union, State Council SB 1234 Page Z Small Business Majority Social Action Commission of the African Methodist Episcopal Church South Asian Business Alliance Network State Building and Construction Trades Council of California United Domestic Workers of America, AFSCME, Local 3930 United Ways of California UNITE-HERE Utilities Workers Union of America, Local 132 Vasquez & Company, LLP Ward Economic Development Corporation Women's Institute for a Secure Retirement Young Invincibles SB 1234 Page A Opposition Financial Services Institute Oppose Unless Amended American Council of Life Insurers Associated Builders and Contractors of California Association of Ca Life and Health Insurance Companies California Asian Pacific Chamber of Commerce California Association of Health Services at Home California Building Industry Association California Business Properties Association California Business Roundtable SB 1234 Page B California Chamber of Commerce California Farm Bureau Federation California Framing Contractors Association California Grocers Association California Hotel & Lodging Association California League of Food Processors California Lodging Industry Association California Manufacturers & Technology Association California Professional Association of Specialty Contractors California Restaurant Association California Retailers Association California Travel Association Camarillo Chamber of Commerce SB 1234 Page C CAWA-Representing Automotive Parts Industry Culver City Chamber of Commerce Family Business Association Fresno Chamber of Commerce National Federation of Independent Business North Orange County Chamber Oxnard Chamber of Commerce Palm Desert Area Chamber of Commerce Redondo Beach Chamber of Commerce Residential Contractors Association Santa Maria Chamber of Commerce & Visitor and Convention Bureau Securities Industry and Financial Markets Association South Bay Association of Chambers of Commerce SB 1234 Page D The Greater Conejo Valley Chamber of Commerce Western Carwash Association Western Electrical Contractors Association Western Growers Association Western Manufactured Housing Communities Association Analysis Prepared by:Ben Ebbink /Taylor Jackson / L. & E. / (916) 319-2091