BILL ANALYSIS                                                                                                                                                                                                    



                                                                 
           AB 2770
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          CONCURRENCE IN SENATE AMENDMENTS
          AB 2770 (Monning)
          As Amended  August 18, 2010
          Majority vote
           
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          |ASSEMBLY:  |58-17|(June 1, 2010)  |SENATE: |24-3 |(August 25,    |
          |           |     |                |        |     |2010)          |
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           Original Committee Reference:    L. & E.  

           SUMMARY  :  Establishes a pilot program related to the underground  
          economy.

          The  Senate amendments  :

          1 Limit the provisions of the bill to a pilot program directed  
            at the swimming pool and spa construction industry.

          2)Designate the Employment Development Department (EDD) as the  
            lead agency to develop and implement the pilot program, in  
            consultation with other state entities, as specified.

          3)Provide that the set of criteria developed by EDD shall take  
            into account enforcement tools, including but not limited to,  
            reported workers' compensation exemptions and the ratio of  
            building material purchases to reported labor costs.

          4)Require EDD to develop these criteria in consultation with  
            industry representatives.

          5)Add a January 1, 2017, sunset date for the provisions of the  
            bill. 
             
           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 EDD, the Division of Labor  
            Standards Enforcement, the Department of Consumer Affairs, the  
            Franchise Tax Board (FTB), the State Board of Equalization,  
            and the United States Department of Justice.








                                                                 
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          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 Economic and Employment Enforcement Coalition  
            (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 United States  
            Department of Labor (DOL).
           
          AS PASSED BY THE ASSEMBLY  , this bill:

          1)Required the Labor and Workforce Development Agency (Agency)  
            in consultation with the FTB and the 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)Required 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)Stated related findings and declarations to the underground  
            economy.

           FISCAL EFFECT  :   According to the Senate Appropriations  
          Committee, a minimum of three positions would be needed to  
          implement an effective pilot program, with an annual cost of  
          $300,000 in future years.  These costs may be offset by an  
          unknown increase in penalty revenue.

           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.









                                                                 
           AB 2770
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          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  
          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%, 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  








                                                                 
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          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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