BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 2770
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          ASSEMBLY THIRD READING
          AB 2770 (Monning)
          As Amended  April 13, 2010
          Majority vote 

           LABOR & EMPLOYMENT     6-0      APPROPRIATIONS      12-5        
           
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          |Ayes:|Swanson, Bill Berryhill,  |Ayes:|Fuentes, Ammiano,         |
          |     |Furutani, Monning,        |     |Bradford,                 |
          |     |Yamada, Ma                |     |Charles Calderon, Coto,   |
          |     |                          |     |Davis, Monning, Ruskin,   |
          |     |                          |     |Skinner, Solorio,         |
          |     |                          |     |Torlakson, Torrico        |
          |     |                          |     |                          |
          |-----+--------------------------+-----+--------------------------|
          |     |                          |Nays:|Conway, Harkey, Miller,   |
          |     |                          |     |Nielsen, Norby            |
          |     |                          |     |                          |
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           SUMMARY  :   

          1)Requires the Labor and Workforce Development Agency (Agency)  
            in consultation with the Franchise Tax Board (FTB) and the  
            Economic and Employment Enforcement Coalition (EEEC) to  
            develop and implement a set of standards that, if met by an  
            employer, would trigger a recommendation for a tax audit or  
            investigation of employers violating state laws regarding  
            wages, hours and working conditions.  

          2)Requires the Labor Commissioner (LC) to take specified actions  
            to facilitate audits and investigations of employers who meet  
            the standards required by this bill after July 1, 2011.

          3)States related findings and declarations to the underground  
            economy.

           EXISTING LAW : 

          1)Establishes the Joint Enforcement Strike Force on the  
            Underground Economy (JESF) to combat the underground economy  
            and to report to the Legislature by June 30 of each year.   
            JESF is a partnership involving the Employment Development  
            Department (EDD), the Division of Labor Standards Enforcement,  








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            the Department of Consumer Affairs, FTB, the State Board of  
            Equalization, and the United States Department of Justice.

          2)Designates the Director of EDD as the chairperson of JESF and  
            authorizes employees of any of the agencies that participate  
            in JESF to issue Labor Code citations and penalty assessment  
            orders to employers found in violation of the law.  

          3)Establishes the EEEC, which consists of investigators from the  
            Division of Labor Standards Enforcement (DLSE), the Division  
            of Occupational Safety and Health (DOSH), the EDD, the  
            Contractor's State License Board, and the U.S. Department of  
            Labor (DOL).

           FISCAL EFFECT  :   According to the Assembly Appropriations  
          Committee, significant costs to DLSE totaling $590,000 in  
          2011-12 and $444,000 in 2012-13.  Potential revenue gain, to the  
          extent coordination between state labor enforcement and tax  
          collection agencies produces high-value audit leads.


           COMMENTS  :   According to the author, California's vast  
          underground economy is thriving. According to EDD analysis of  
          IRS data, California's underground economy is worth between $60  
          and 140 billion a year.  Because business in the underground  
          economy is conducted outside the bounds of state law, businesses  
          operating there are able to gain an unfair advantage over their  
          law-abiding competitors by flouting labor laws and ignoring  
          their tax obligations to state and local governments.

          The author argues that violations of labor and tax laws often go  
          hand in hand.  Every time an employer fails to pay a worker  
          minimum wage, ignores overtime pay requirements, or simply pays  
          in cash under the table, the state loses revenues from income  
          and payroll taxes that fund the unemployment insurance system,  
          paid family leave, disability insurance and vital state general  
          fund programs.

          FTB and the Board of Equalization estimate that an average of  
          $8.5 billion in owed corporate, personal, and sales and use  
          taxes go uncollected in California each year, with unreported  
          and underreported economic activity responsible for the vast  
          majority of that total. The State Controller's office estimates  
          that 11% of taxes owed in California go uncollected, and another  








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          3% are collected only through state enforcement.

          The author notes that as the state faces a multi-billion dollar  
          budget deficit, increased collection of already-owed taxes  
          should be a top budget priority.  Despite the clear nexus  
          between employers that violate both sets of laws, there is no  
          formal process to ensure that the enforcement efforts of one  
          department are reflected in the work of another.  This lack of  
          coordination is worsened by the limited enforcement resources  
          available in California.  For the past several decades, labor  
          law enforcement has been on the decline.  Between 1980 and 2000,  
          California's workforce grew 48 percent, but the DLSE staffing  
          levels went down 7.6%.

          The author argues that with such constrained enforcement  
          capacity, the state should do all it can to maximize the impact  
          of the enforcement activities that are taking place.  This bill  
          allows them to do this, while building on the work of the EEEC  
          and without being unnecessarily prescriptive.  This bill is  
          necessary to better leverage limited state resources, encourage  
          compliance with state labor laws, and maximize state revenues by  
          collecting funds otherwise lost to the underground economy.

          This bill is supported by the Spa & Pool Industry Council  
          (SPEC), who states that employers operating in the underground  
          economy hurt everyone, the state loses billions of dollars each  
          year in tax revenues, workers are forced to go without basic  
          employment protections, and law-abiding businesses are  
          confronted with unfair competition from scofflaw competitors.   
          SPEC states that, as legitimate employers working in the pool  
          and spa industry in California, they support the efforts of this  
          bill to target those employers that operate in the underground  
          economy in flagrant violation of the law, and not employers that  
          commit minor or inadvertent violations of existing law.

           
          Analysis Prepared by  :    Ben Ebbink / L. & E. / (916) 319-2091 


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