BILL ANALYSIS                                                                                                                                                                                                    






           SENATE TRANSPORTATION & HOUSING COMMITTEE       BILL NO: AB 519
          SENATOR ALAN LOWENTHAL, CHAIRMAN               AUTHOR:  Duvall
                                                         VERSION: 6/17/09
          Analysis by: Mark Stivers                      FISCAL:  Yes
          Hearing date: June 23, 2009








          SUBJECT:

          Towing charges and access to towed vehicles

          DESCRIPTION:

          This bill requires towing companies to provide consumers with a  
          Towing Fees and Access Notice and an itemized invoice of all  
          towing and storage fees.  The bill also specifies who is  
          authorized to retrieve or inspect a towed vehicle and relives  
          the towing company of responsibility for determining the  
          authenticity of documents provided to demonstrate a person's  
          authority. 

          ANALYSIS:

          Current law allows a peace officer, traffic control officer, or  
          parking control officer to have a vehicle towed in various  
          circumstances, such as when the vehicle impedes the flow of  
          traffic or when the driver is arrested or cited for specific  
          offenses.  Such tows are referred to as "public tows."  The  
          charges for towing and storage related to a public tow are set  
          by the law enforcement agency that requested the tow.  

          Current law also allows private property owners to have vehicles  
          towed when they are illegally or improperly parked on their  
          property, subject to specified conditions and procedures.  These  
          are referred to as "private property tows."  Current law limits  
          what a towing company can charge for towing and storage related  
          to a private property tow to the rate approved by the law  
          enforcement agency or the towing company's approved rate from  
          the California Highway Patrol.  





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          In addition, a vehicle owner may hire a tow-truck company to tow  
          his or her vehicle.  These are "owner's request tows."  The  
          rates for towing and storage related to this type of tow is  
          generally established by mutual agreement between the requestor  
          and the towing company but may be dictated by agreements  
          established between the requestor's motor club and the tower.

          For all three types of tows, the towing company has a lien  
          against the vehicle for costs related to towing, storage, or  
          labor associated with recovery or load salvage of the vehicle.   
          The lien arises on the date that the tower takes possession of  
          the vehicle.  The towing company may commence lien sale  
          proceedings to recover uncollected costs within 15 days of the  
          date the lien arises.

           This bill  :

           Places into statute a form known as the "Towing Fees and  
            Access Notice," which answers questions relating to how much a  
            towing company can charge, where a person can complain, one's  
            rights when a vehicle is towed, and what happens if the towing  
            and storage fees are not paid.  The notice includes a  
            disclaimer stating that the notice does not summarize all of  
            the laws that may be applicable to towing nor does it fully  
            and completely state the entire law with respect to any  
            specific question.

           Requires a person or towing company that charges for towing  
            and storage to post in the office area of the storage  
            facility, to make available upon request to vehicle owners,  
            and to have copies readily available to the public of the  
            Towing Fees and Access Notice.

           Requires a person or towing company that charges for towing  
            and storage to print on every invoice for towing or storage  
            charges a statement alerting the payer that the Towing Fees  
            and Access Notice is available upon request.  

           Requires a person or towing company that charges for towing  
            and storage, prior to receiving payment for any towing,  
            recovery, or storage-related fees, to provide an itemized  
            invoice of actual charges to the vehicle owner or his or her  
            agent.  The invoice must include:

             ?    The name, address, telephone number, and carrier  
               identification number of the person or towing company that  




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               is charging for towing and storage.

             ?    If ascertainable, the registered owner or operator's  
               name, address, and telephone number.

             ?    The date service was initiated.

             ?    The location of the vehicle at the time service was  
               initiated.

             ?    A vehicle description that includes, if ascertainable,  
               the vehicle year, make, model, odometer reading, license  
               plate number, or if a license plate number is unavailable,  
               the vehicle identification number.

             ?    The service dispatch time, the service arrival time at  
               the vehicle, and the service completion time.

             ?    A detailed explanation of any additional services that  
               caused the total towing-related service time to exceed one  
               hour between service dispatch time and service completion  
               time.

             ?    The hourly rate or per item rate used to calculate the  
               total towing and recovery-related fees. 

             ?    The daily storage rate and the total number of days  
               stored, if applicable.

             ?    If subject to a gate fee, the date and time the vehicle  
               was either accessed or released after normal business  
               hours.  

             ?    A description of the method of towing.

             ?    If the tow was not at the owner's request, the identity  
               of the person or governmental agency that directed the tow  
               unless protected by law. 

             ?    A clear, itemized, and detailed explanation of any  
               additional services or fees.

           Provides that prior to paying any towing, recovery, or  
            storage-related fees, a vehicle owner or his or her agent has  
            the right to all of the following:  





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             ?    To receive his or her personal property, at no charge,  
               during normal business hours, which are Monday through  
               Friday from 8:00 a.m. to 5:00 p.m., except state holidays.

             ?    To retrieve his or her vehicle during the first 72 hours  
               of storage and not pay a lien fee.  

             ?    To request a copy of the Towing Fees and Access Notice.   


             ?    To be permitted to pay by cash or a valid bank credit  
               card. 

           Provides that a person who fails to honor the rights described  
            above, to provide all the information required in the invoice,  
            or to make available the Towing Fees and Access Notice is  
            civilly liable to the person tendering payment for up to two  
            times the amount charged, not to exceed $500.

           Exempts from the bill the towing or storage of a repossessed  
            vehicle pursuant to the Collateral Recovery Act.

           Specifies that the documents entitling a person to retrieve a  
            vehicle from the storage yard include, but are not limited to:

             ?    A certificate of ownership

             ?    The vehicle registration

             ?    Information in the possession of the towing company such  
               as ownership information obtained from the Department of  
               Motor Vehicles or a valid registration found within the  
               vehicle

             ?    A notarized letter or statement from the legal or  
               registered owner providing authorization to release to a  
               particular person with a government-issued photographic  
               identification card

             ?    A letter from the owner's insurance company establishing  
               that the person is a person is the owner's insurance  
               representative

           Provides that a towing company is not responsible for  
            determining the authenticity of documentation establishing a  
            person's authority to retrieve the vehicle or that a person is  




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            the owner's insurance representative.    

           For purposes of allowing inspection of the vehicle at the  
            storage yard, clarifies that the owner's agent includes, but  
            is not limited to, any person that the legal owner designates  
            in writing or by telephone to inspect the vehicle and provides  
            that the towing company is not responsible for determining the  
            authenticity of documentation establishing a person's  
            authority to inspect the vehicle.

          
          COMMENTS:

           1.Purpose of the bill  .  The intent of this bill is to protect  
            consumers from abusive towing practices and to address  
            consumer confusion over towing laws.  According to the author,  
            a few non-professional, dishonest towing operators capitalize  
            on consumer confusion in order to charge excessive fees and  
            increase profits.  These actions hurt honest towing operations  
            through loss of goodwill and trust among potential customers.   
            In addition, excessive charges have led to an increasingly  
            antagonistic relationship with insurance companies, who pay  
            the bill for frustrated policyholders on many accident-based  
            tows and who dispute these charges as not reasonable or  
            ordinary.  

            This bill addresses these issues by requiring towers to  
            provide detailed invoices of all charges and to provide  
            consumers with a notice describing their rights at the time  
            they seek to retrieve their vehicles.  In an attempt to both  
            protect consumers and provide greater direction to towing  
            companies, the bill also seeks to clarify what types of  
            documentation are appropriate to release or allow inspection  
            of the vehicle.  As a result of this notice, the author  
            believes that consumers will know exactly what to expect,  
            exactly what questions to ask, and where to go to seek redress  
            of any improprieties.  

           2.Product of a working group  .  This bill is the product of  
            working group of insurance companies, auto clubs, and the  
            towing industry that has met for 18 months.  While consumer  
            groups did not participate directly in the working group, the  
            insurers represented consumer interests to some extent.  

           3.Applies to repair shops and dealers  .  This bill applies to any  
            "person or towing company that charges for towing and  




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            storage."  As a result, it applies not just to towers but also  
            to any entity, such as an auto body shop or car dealership,  
            that retrieves the vehicle from the tower, pays the tower, and  
            then passes on the towing and storage costs to the vehicle  
            owner or insurer.  This ensures that the ultimate payer of the  
            charges has an itemized invoice with which he or she can  
            dispute any unauthorized or illegitimate charges from the  
            tower if necessary.  

           4.Suggested amendments  .  The committee may wish to consider the  
            following substantive amendments:

                 Add to the notice information about the court remedies  
               available to consumers for violations of the rights  
               described.
                     Add to the notice information about who is  
               responsible for any damage to the vehicle that may have  
               occurred during towing and storage.
                     On page 11, line 39 make a person or towing company  
               liable to track the language in earlier subdivisions.
                     On page 11, line 40, allow the legal owner,  
               registered owner, or agent to bring the action.
                     With respect to the provisions on documentation,  
               provide that a towing companys non-responsibility for  
               determining the authenticity of documents only applies to  
               documents specifically listed and not to those that a tower  
               may accept under the "including, but not limited to"  
               phrase.  

             The committee may also wish to consider the following  
               technical amendments:

                 On page 8, line 23 strike "a clear and"
                 On page 8, lines 27-28 strike "California Consumer Bill  
               of Rights for Towed Vehicles"
                 On page 9, strike lines 4-28.
                 On page 10, lines 25-27 strike "and may document that  
               substantially complies with this subdivision shall be  
               deemed an "itemized invoice" for purposes of this section"
                 On page 11, line 3 strike "of" and insert "at"
                 On page 11, strike lines 29-31 (this is redundant) and  
               renumber the subsequent paragraphs.

           1.Double referral  .  The Senate Rules Committee has referred this  
            bill both to this committee and the Judiciary Committee.  In  
            particular, the provisions of the bill relating to a towing  




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            company's non-liability for determining the authenticity of  
            documents fall within the jurisdiction of the Judiciary  
            Committee.

          Assembly Votes:
               Floor:    77-0
               Appr: 16-0
               Trans:    14-0

          POSITIONS:  (Communicated to the Committee before noon on  
          Wednesday, 
                     June 17, 2009)

               SUPPORT:  Allstate Insurance
                         Association of California Insurance Companies 
                         California State Automobile Association/AAA
                         Personal Insurance Federation of California
                         State Farm Insurance

               OPPOSED:  None received.