BILL ANALYSIS                                                                                                                                                                                                    






                             SENATE JUDICIARY COMMITTEE
                           Senator Ellen M. Corbett, Chair
                              2009-2010 Regular Session


          SB 933 (Oropeza)
          As Amended March 8, 2010
          Hearing Date: April 27, 2010
          Fiscal: No
          Urgency: No
          SK:jd
                    

                                        SUBJECT
                                           
                              Debit Cards: Service Fees

                                      DESCRIPTION  

          This bill would extend current law which prohibits retailers  
          from imposing a surcharge on credit card purchases to also  
          include debit card purchases.

                                      BACKGROUND  

          A recent study by the Federal Reserve Bank of Boston found that  
          "[c]onsumers make 53 percent of their monthly payments with a  
          payment card (credit, debit, and prepaid).  More consumers now  
          have debit cards than credit cards [80.2 percent versus 78.3  
          percent], and consumers use debit cards more often than cash,  
          credit cards, or checks individually." ("The 2008 Survey of  
          Consumer Payment Choice," April 2010, Federal Reserve Bank of  
          Boston.)

          Accepting all of these payments imposes costs on merchants.  A  
          May 2008 report by the General Accounting Office (GAO) explained  
          the system of "interchange fees" in which the merchant's bank  
          pays an "interchange fee" to the cardholder's bank when the  
          payment is made by credit or debit card, and stated: 

            The majority of the costs associated with accepting cards are  
            the "merchant discount fees" paid to the banks that merchants  
            use to process their transactions.  Generally, for each Visa  
            or MasterCard transaction, a portion of the merchant discount  
            fee is paid from the merchant's bank-called the acquiring  
            bank-to the bank that issued the card.  This portion, called  
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            the interchange fee, reimburses card issuers for a portion of  
            the costs they incur in providing card services.  The balance  
            of the merchant discount fee is retained by the acquiring bank  
            to cover its costs of providing services.  . . .  Interchange  
            fee amounts are calculated using rates, typically between 1  
            and 2 percent of a purchase's value [or they can be a flat  
            rate].  (GAO, "Credit and Debit Cards," GAO-08-558, May 2008.)
          Under California law, retailers are prohibited from imposing a  
          surcharge on a consumer who uses a credit card to make a  
          purchase.  This provision was added to the Song-Beverly Credit  
          Card Act in 1985 by SB 848 (Rosenthal, Ch. 913, Stats. 1985).   
          This bill would extend these surcharge protections to debit  
          cards.     

                                CHANGES TO EXISTING LAW
           
           1.Existing law  prohibits retailers from imposing a surcharge on  
            a cardholder who uses a credit card.  Existing law permits a  
            retailer to offer a discount for the purpose of inducing  
            payment by means other than a credit card as long as the  
            discount is offered to all prospective buyers.  (Civ. Code  
            Sec. 1748.1(a).)

           Existing law  provides that any retailer who willfully violates  
            these provisions and fails to pay the amount of the surcharge  
            back to the cardholder, after the cardholder's written request  
            to do so, is liable to the cardholder for three times the  
            amount of actual damages and reasonable attorney's fees and  
            costs.  (Civ. Code Sec. 1748.1(b).)

           This bill  would apply all of the above-described provisions to  
            debit card purchases. 

           2.Existing state law  limits a debit cardholder's liability for  
            unauthorized use of a debit card.  (Civ. Code Sec. 1748.31.)

           This bill  would revise the definition of "debit card" to also  
            include a prepaid card or other means of access to prepaid  
            funds that may be used for electronic funds transfers and may  
            be used without a personal identification number (PIN) to  
            access the funds. 

                                        COMMENT
           
          1.   Stated need for the bill  

                                                                      



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          In support of the bill, the author writes:

            SB 933 prohibits retailers from imposing a surcharge on  
            consumers who elect to use their debit card when making a  
            purchase.  Current law prohibits retailers from imposing a  
            surcharge on consumers who use their credit card; SB 933 seeks  
            to provide the same consumer protection enjoyed by those who  
            use their debit cards.  Presently and without SB 933, a  
            consumer who elects to pay with their debit card can actually  
            pay more than somebody who uses their credit card.

            Furthermore, debit card usage has increased exponentially over  
            the years as we continue to move to an increasingly cashless  
            society.  Since 2005, more than half of total retail  
            transactions nationwide have been made with either a credit  
            card or debit card.  Since 2006, more purchases have been  
            made, in terms of volume, with debit cards than credit cards.   
            The California Employment Development Department is currently  
            considering issuing unemployment insurance payments through  
            prepaid cards.  Without the protection provided under SB 933,  
            those receiving unemployment benefits could be charged a  
            surcharge by retailers on their newly issued EDD unemployment  
            prepaid card.

            Lastly, many prepaid card products are being used by younger  
            consumers, underbanked, or unbanked consumers who do not use  
            or have bank accounts, consumers are obtaining their pay  
            through payroll cards or government issued benefits on prepaid  
            cards.  The prepaid cardholding population is expected to  
            increase even more rapidly; thus making it important to  
            include prepaid cards within the surcharge prohibition. 

          2.   Extending surcharge protections of Song-Beverly Credit Card  
          Act to debit cards  

          Under Song-Beverly, retailers may not impose a surcharge when a  
          consumer decides to pay for his or her purchase using a credit  
          card.  This bill would add Civil Code Section 1748.33 to the  
          provisions of law relating to debit cards.  That new section  
          would extend the same surcharge protections as contained in  
          Song-Beverly to debit card users.  While these provisions would  
          prohibit a retailer from imposing a surcharge when a consumer  
          uses a debit card to make a purchase, they would not prohibit  
          the retailer from offering a discount in order to induce payment  
          by means other than a debit card, as long as the discount is  
          offered to all prospective buyers.  
                                                                      



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          Consumers Union, in support of this bill, writes that  
          "[c]onsumers should not be penalized for choosing to use 'pay  
          now' payment methods instead of paying later by using their  
          credit cards, which may lead to only growing personal and  
          household debt.  . . .  numerous studies have shown the use of  
          debit is rising at a rapid pace." 

          3.   Revising definition of "debit card"
           
          This bill would include prepaid cards in existing law's  
          definition of "debit card" so that those cards would also get  
          the protection of existing law and this bill.  With respect to  
          debit cards, existing law provides that when there is an  
          unauthorized use of a debit card the cardholder is only liable  
          for $50 as long as the cardholder notifies the issuer that an  
          unauthorized use has occurred or may occur because the card was  
          lost or stolen within specified timeframes.  By including  
          prepaid cards in the definition of "debit card," this bill would  
          extend these provisions to prepaid cards.  It would also extend  
          the protections of this bill's surcharge prohibition to prepaid  
          cards.  

          The use of prepaid debit cards has also been increasing.  Those  
          cards are reloadable and allow the cardholder to add funds to  
          the card.  According to a New York Times article, prepaid cards  
          are most often used by consumers who do not have a bank account  
          or cannot get a credit card. ("Prepaid, but Not Prepared for  
          Debit Card Fees," New York Times, October 6, 2009.) Many  
          government agencies and companies are beginning to use prepaid  
          cards instead of paper checks.  For example, retirees without  
          bank accounts can get their Social Security payments on a  
          prepaid debit card.  According to the author, the Employment  
          Development Department (EDD) is planning on issuing unemployment  
          benefit payments on prepaid debit cards.  This bill is intended  
          to ensure that Californians who use this form of payment receive  
          the debit card protections contained in existing law as well as  
          the debit card surcharge protections proposed by this bill. 

          4.   Remedies available  

          Song-Beverly's prohibition on the imposition of a surcharge for  
          credit card purchases may be enforced by a consumer in small  
          claims court, if it does not exceed the jurisdiction of that  
          court, or in any other appropriate court.  Express statutory  
          authorization is not necessary, however, to bring an action in  
                                                                      



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          small claims court or in any other appropriate court.  Rather,  
          actions may be brought in small claims court if they meet the  
          jurisdictional limits.  Including express statutory  
          authorization creates the implication that a claim may not be  
          brought to enforce a statute if the statute does not contain  
          that authorization.  

          At the request of the Judicial Council, the author deleted this  
          provision because it has the potential to create confusion.  It  
          is important to note, however, that this deletion is not  
          intended to be interpreted as removing the ability to bring an  
          action in small claims court, or in any other appropriate court,  
          for enforcement of this bill.  In order to make this clear, the  
          Committee may wish to amend the bill to include uncodified  
          intent language stating this fact.  The following language would  
          accomplish this: 

             Suggested amendment  : Add uncodified intent language providing  
            that the deletion of the small claims language is not intended  
            to be interpreted as removing the ability to bring an action  
            in small claims court, or in any other appropriate court, for  
            enforcement of this bill.
           
          5.   Opposition  

          BP America writes in opposition: 

            . . . by prohibiting retailers from imposing a surcharge on  
            consumers that use debit cards, the bill would require ARCO  
            dealers and franchisees to incur the cost of interchange fees  
            that are imposed by credit card companies and payment  
            networks, thereby increasing the cost on ARCO consumers who  
            purchase other goods and services at our stations.  Indeed, SB  
            933 would ultimately hurt ARCO and ampm consumers because ARCO  
            dealers and franchisees would be prevented from passing some  
            of the cost of the interchange fee to consumers.  By stopping  
            this practice, our dealers and franchisees would be unable to  
            reduce the risk of the escalating cost of interchange fees  
            while continuing to offer gasoline at a lower price. 

          The California Retailers Association (CRA) also opposes the  
          bill, writing that "[v]ery few retailers charge customers for  
          debit transactions even though we incur fees on every card  
          transaction.  Those that impose a charge are smaller merchants  
          or retailers who are recognized for offering low price products  
          or services.  If those retailers are prohibited from imposing  
                                                                      



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          debit card surcharges, they will ultimately be forced to raise  
          their prices which will have a negative impact on all  
          customers-not just those paying with debit cards."

          CRA also states that it would not oppose the bill if it  
          "mandated disclosure of any surcharge on debit transactions and  
          required an opt-out for consumers that elect not to pay the  
          additional cost."  The author is not supportive of taking this  
          amendment, arguing the proposed amendment does not sufficiently  
          protect consumers. 


           Support  :  AARP; California Labor Federation, AFL-CIO; Center for  
          Responsible Lending, City of Lakewood; Coalition of California  
          Welfare Rights Organizations, Inc.; Consumer Action; Consumer  
          Federation of California; Greenlining Institute; National  
          Employment Law Project; San Francisco Chamber of Commerce; San  
          Jose Silicon Valley Chamber of Commerce; Visa Inc.

           Opposition  :  BP America, Inc.; California Grocers Association;  
          California Retailers Association; National Federation of  
          Independent Business

                                        HISTORY
           
           Source  :  Consumers Union

           Related Pending Legislation  :  None Known 

           Prior Legislation  :  SB 848 (Rosenthal, Ch. 913, Stats. 1985)  
          (See Background.)

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