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
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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
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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
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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.
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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
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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
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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.
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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
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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
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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,
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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
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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
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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
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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
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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
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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
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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
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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.
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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.
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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
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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
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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
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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
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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
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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