BILL ANALYSIS                                                                                                                                                                                                    Ó




                                                                  SB 1234
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          Date of Hearing:   June 20, 2012

                     ASSEMBLY COMMITTEE ON LABOR AND EMPLOYMENT
                                Sandre Swanson, Chair
                    SB 1234 (De Leon) - As Amended:  June 13, 2012

                                       REVISED

           SENATE VOTE  :   23-13
           
          SUBJECT  :   Retirement savings plans.

           SUMMARY  :   Establishes the California Secure Choice Retirement 
          Savings Program (Program) to operate as a state-administered 
          retirement savings plan for private sector workers who do not 
          participate in any other type of employer-sponsored retirement 
          savings plan.  Specifically,  this bill  :

          1)Establishes the California Secure Choice Retirement Savings 
            Investment Board (Board) to consist of the State Treasurer, 
            the Director of Finance (or his or her designee), the State 
            Controller, an individual with retirement savings and 
            investment expertise appointed by the Senate Committee on 
            Rules, a small business representative appointed by the 
            Governor, a public member appointed by the Governor, and an 
            employee representative appointed by the Speaker of the 
            Assembly.

          2)Requires the Board to conduct an initial market analysis to 
            determine whether the necessary conditions for implementation 
            of the Program can be met, as specified.

          3)Provides that the Program will only become operative if the 
            Board notifies the Director of Finance that, based upon the 
            market analysis, the Program 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)Establishes the Program to include one or more payroll deposit 
            retirement savings accounts for private sector employees to 
            operate under the following parameters:

             a)   Individual accounts under the program shall be nominal 
               accounts and contributions shall be treated as credits to 









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               an individual's account along with interest and any 
               additional earnings.

             b)   The balance of the credits in an individual's account 
               shall determine the amount to which they are entitled under 
               the Program upon termination.

             c)   Requires the Board, prior to July 1 of the initial 
               Program year and annually thereafter, to adopt a Program 
               amendment to declare the stated rate at which interest 
               shall be credited to accounts for the following year.



             d)   Provides that an individual's retirement savings benefit 
               under the Program shall be an amount equal to the balance 
               of the credits in the individual's program account on the 
               date the retirement savings account becomes payable.

          5)Provides that after the Board opens the Program for 
            enrollment, any employer may choose to have a payroll deposit 
            retirement savings arrangement to allow employee participation 
            in the Program.  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 Program.

             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 Program.

             c)   Beginning nine months after opening of enrollment, 
               employers of five or more employees must have an 
               arrangement to allow employees to participate in the 
               Program.

          6)Requires the Board, prior to opening the Program for 
            enrollment, to disseminate an employee information packet and 
            disclosure form to employers that, among other things, clearly 
            articulates that the program is privately insured and not 
            guaranteed by the State of California.

          7)Provides that an employer who, without good cause, fails to 









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            allow its employees to participate in the Program within 90 
            days after being notified of failure to comply by the 
            Employment Development Department, shall pay a penalty of $250 
            per eligible employee.  If the employer if found to be in 
            willful noncompliance 180 days after the notice shall be 
            subject to an additional penalty of $500 per eligible 
            employee.

          8)Requires each eligible employee to be enrolled in the Program 
            unless the employee opts out as specified, and provides for an 
            open enrollment period.

          9)Provides that, unless otherwise specified by the employee, a 
            participating employee shall contribute three percent of their 
            annual salary or wages into the Program (which may be adjusted 
            by the Board to between two percent and four percent).

          10)Establishes a trust (Trust) to be administered by the Board 
            and requires moneys to be segregated into a program fund and 
            an administrative fund.  Annual expenditures from the 
            administrative fund shall not exceed more than one percent of 
            the total program fund.

          11)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.

          12)Provides that equities shall not exceed 50 percent of the 
            overall asset allocation of the fund. 

          13)Provides that employers shall not have any liability for an 
            employee's decision to participate or opt out of the Program, 
            or for the investment decisions of employees.



          14)Provides that employers shall not be a fiduciary over the 
            Program and shall bear no responsibility for the 
            administration, investment, or investment performance of the 
            Program.  An employer shall not be liable with regard to 
            investment returns, program design, and benefits paid to 
            participants.

          15)Requires the Board to submit an annual independently-audited 









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            financial report, as specified.

          16)Provides that the state shall not have any liability for the 
            payment of the retirement savings benefit guaranteed to 
            Program participants.  Any financial liability for the payment 
            of benefits in excess of funds available shall be borne by 
            insurance underwriters pursuant to a contract entered into 
            with the Board, as specified.  The state, and any of the funds 
            of the state, shall have no obligation for payment of the 
            guaranteed benefits arising from the program.

          17)Makes related and conforming changes to implement the 
            provisions of this bill.

          18)Makes related legislative findings and declarations.

           COMMENTS  :   This bill would establish a supplemental retirement 
          savings program for California's private sector workers that do 
          not have access to retirement plans through their jobs.  The 
          author states that the program created by this bill would 
          provide a reliable, affordable and completely portable 
          retirement savings plan for the millions of Californians without 
          access to a workplace retirement plan.

           The Problem of Retirement Savings for Private Sector Employees  

          For private sector employees, the American retirement system has 
          traditionally relied upon a three-prong approach - Social 
          Security benefits, private savings and employer-provided 
          pensions.  Therefore, a large component of the traditional 
          retirement system was an employer-based retirement component, 
          which was generally provided through a defined benefit pension 
          where the benefit was defined by years of service and the final 
          wages of the employee.  By some estimates, as recently as 25 
          years ago more than 80 percent of large and mid-sized employers 
          offered a defined benefit pension.  Today, less than a third of 
          such employers offer such a pension.

          In recent decades, employer-sponsored defined benefit pensions 
          have been largely replaced by defined contributions pensions 
          such as 401(k) and 457 retirement plans.  In these plans, 
          employees generally make their own decisions about how the funds 
          are invested, taking on the entirety of the risk of their own 
          retirement savings.  While these plans are portable and have 
          certain tax advantages, critics have pointed out that the nature 









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          of the risk shift leaves workers with the sole responsibility of 
          making investment decisions (for which they may or may not be 
          prepared) and leaves nest eggs vulnerable to shifts in the stock 
          market (of which recent retirees are painfully aware).

          Another problem which has received less attention is the large 
          number of private sector employees who have no access to an 
          employer-sponsored retirement plan at all.  Critics contend that 
          this undermines the historical three-prong retirement system 
          upon which employees have traditionally relied.  This problem is 
          particularly severe in California, and it is particularly severe 
          for California's middle class and lower-middle class retirees 
          and employees of small businesses.
          According to a recent UC Berkeley study<1>, 52 percent of 
          Californians have access to employee-sponsored retirement plans 
          and 44 percent of California's workers choose to participate in 
          these plans (nationally, the rate is 58.1 percent and 49 
          percent, respectively).  However, such an aggregation masks 
          disparities among firm sizes.  For firms with 1,000 or more 
          employees, 75.4 percent of the firms offer access to 
          employer-sponsored retirement plans, and more than 65 percent of 
          the workers chose to participate in the plans.  For firms that 
          are 25 employees or less, only 19.7 percent of the firms offer 
          an employer-sponsored retirement plan and only 16.5 percent of 
          workers employed by firms of that size actually participate in 
          these plans.

          Similarly, there are significant disparities among upper-middle 
          class retirees and middle class and lower-middle class retirees 
          when it comes to the sources of income available retirees.  
          According to the same UC Berkeley study, the mean total income 
          for retirees in California is $25,984; 43.5 percent of the 
          income comes from Social Security and 38.9 percent of the income 
          comes from retirement funds, dividends, and rental income.  
          However, when the data is disaggregated, significant disparities 
          can be seen:

                     For retirees in the bottom 25 percent of income 
                 brackets, the mean total income for retirees is $6,902; 
                 79.1 percent comes from Social Security and 4.8 percent 
                 comes from retirement funds, dividends, and rental 
                 income.

               -------------------------
          <1> Rhee, Nari.  "Meeting California's Retirement Security 
          Challenge."  U.C. Berkeley Center for Labor Research and 
          Education (October 2011).








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                     For retirees in the middle 50 percent of income 
                 brackets, the mean total income for retirees is $18,145; 
                 70.3 percent comes from Social Security and 18.9 percent 
                 comes from retirement funds, dividends, and rental 
                 income.

                     For retirees in the top 25 percent of income 
                 brackets, the mean total income for retirees is $60,713; 
                 23.4 percent comes from Social Security and 54.8 percent 
                 comes from retirement funds, dividends, and rental 
                 income.
           
          A more recent update to the U.C. Berkeley study<2> indicates 
          that access is worst among low-wage workers, where only 22 
          percent have access to workplace retirement plans.  Only 25 
          percent of employees of small firms with less than 100 employees 
          have access to such plans.  And only 32 percent of Latino 
          workers have access to such plans.

          The U.C. Berkeley study concludes as follows:

               "For most people, retirement security is not about living 
               in luxury, nor is it about just surviving; it is about 
               having adequate resources to enjoy their families and 
               interests after a lifetime of hard work while they are 
               still in good enough health to do so.  This is an integral 
               part of the American Dream which traditional pensions, 
               combined with Social Security, once made achievable for 
               average working people.  Unfortunately, declining access to 
               employer-sponsored pensions and retirement accounts, 
               inadequate assets, and a large share of the workforce on 
               track to retire into serious economic hardship are cause 
               for deep anxiety among workers about their ability to 
               retire with dignity, or even to retire at all.  Surveys and 
               journalistic accounts abound with stories of people hoping 
               they are physically able to "work until I die" because they 
               have so few assets, and-especially among young 
               workers-because they believe that Social Security will not 
               be there for them.

               Such a bleak future does not have to come to pass.  Social 

               -------------------------
          <2> Rhee, Nari.  "6.3 Million Private Sector Workers in 
          California Lack Access to a Retirement Plan on the Job."  U.C. 
          Berkeley Center for Labor Research and Education (June 2012).








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               Security can be strengthened to ensure that it continues to 
               protect American retirees from poverty for generations to 
               come.  Meanwhile, states like California can take 
               leadership in building toward retirement security for all 
               by establishing a publicly sponsored retirement system for 
               private sector workers who lack access to an 
               employer-sponsored plan.  Given the needs of California 
               workers, such a system should be thoughtfully designed to 
               pool some of the risks that have been shifted onto 
               vulnerable workers to the great detriment of families. 
               Closing the private sector pension gap will not only help 
               individual workers take responsibility for their 
               retirement; it will improve the social and economic future 
               of California."

           How This Program Would Operate
           
          In terms of retirement products currently in use, the Program 
          proposed under this bill would most closely follow the structure 
          of a cash-balance retirement type plan<3>.  With a cash-balance 
          retirement plan, the plan tries to blend components of a defined 
          benefit and defined contribution plan by providing a guaranteed 
          benefit, but tying that guaranteed benefit to a balance in the 
          account.

          In a traditional defined benefit plan, the employee is 
          guaranteed a benefit based on a formula, generally reflecting 
          the employee's age, final compensation and years of service at 
          retirement.  However, in a cash balance plan, payment of a 
          benefit is also guaranteed, but the nature of the guarantee is 
          different than in a traditional defined benefit plan. Rather 
          than basing the benefit on a formula, the payment of 
          contributions previously made is guaranteed, as well as the 
          earnings that were credited to the account.

          In a defined contribution plan, often a 401(k), the employee has 
          an individual account in which contributions and any investment 
          earnings are credited to the employee's account.  At the time of 
          retirement, disability, death or termination of employment, the 
          ---------------------------
          <3> Although the Program created by this bill resembles a "cash 
          balance" type plan, supporters of the bill argue that because 
          the "balance of credits in an individual's account shall 
          determine the amount to which the individual is entitled" and 
          other features of the Program, it is really more akin to a 
          defined contribution plan under federal law.








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          employee receives a benefit equal to the balance in that 
          account.  However, in a cash balance plan, the employee also has 
          a nominal account in which contributions and any investment 
          earnings are credited to the employee's account.  At the time of 
          retirement, disability, death or termination of program 
          membership, the employee also receives a benefit equal to the 
          balance in that account as they would in a defined contribution.

          With a typical cash-balance plan, a participant's account is 
          credited each year with a "pay credit" (such as five percent of 
          compensation from his or her employer) and an "interest credit" 
          (either a fixed rate or a variable rate that is linked to an 
          index such as the one-year Treasury bill rate.  With this bill, 
          the employee puts his or her own compensation into the Program, 
          rather than a payment from the employer.  The Board would then 
          have the responsibility of setting an interest rate/credit on an 
          annual basis.
          Similar to the CalSTRS cash-balance type retirement plan, this 
          bill also requires the creation of a Gain and Loss Reserve 
          Account, which brings in money during good years and disburses 
          money during bad years in order to credit the rate of interest 
          set by the Board.  Such decisions would be based on an annual 
          actuarial valuation.  Additionally, this bill requires the Board 
          to purchase insurance against any loss and secure underwriting 
          to insure that the benefits are paid to participants.

          The actual day-to-day operation of the Program is left largely 
          unspecified in the bill.  There are allowances for the 
          appointment of a Program Administrator and staff, but there is 
          also the flexibility to retain or contract with CalPERS and/or 
          private financial institutions "as necessary".  Finally, there's 
          also a catch-all to allow for collaboration with CalPERS and 
          private entities for outreach and administration.

           The Model "Secure Choice Pension" Program  

          This bill appears to be patterned, at least in part, after the 
          "Secure Choice Pension" program developed by the National 
          Conference on Public Employee Retirement Systems (NCPERS) as a 
          program to enhance retirement security and income for private 
          sector workers.













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          A recent white paper<4> prepared by NCPERS states that the model 
          program is designed to provide the following:

                 The Secure Choice Pension is designed as a 
               public-private enterprise for those who currently do not 
               have a pension (particularly for small and mid-sized 
               businesses).

                 The Secure Choice Pension is not a replacement for 
               existing pension plans in the public or private sectors, 
               nor is it intended to replace 401(k)s.

                 The Secure Choice Pension will be modeled after a "cash 
               balance" type defined benefit plan.

                 The Secure Choice Pension in conjunction with Social 
               Security and personal savings, including 401(k)s, will help 
               close the existing $4-8 trillion retirement savings gap as 
               estimated by several research groups.

                 The Secure Choice Pension will decrease the burden on 
               state and local governments by reducing the need for 
               retirees to rely on public assistance. 

                 The Secure Choice Pension will manage downside funding 
               risk through conservative assumptions as developed in a 
               model plan design and/or determined by each state.

                 The Secure Choice Pension will provide workers with a 
               guaranteed pension but will permit some opportunity for 
               increased benefits in good economic times. 

          NCPERS concludes that, "In summary, the goal of the Secure 
          Choice Pension is to provide private-sector workers who 
          currently do not have access to a pension - particularly those 
          who work for small to mid-sized companies - with a guaranteed, 
          affordable, sustainable pension through a public-private 
          structure that shares the risk between employers and employees 
          and manages funding risk."
           
          "Opt-Out" or "Automatic Enrollment" Features of This Bill
          ---------------------------
          <4> Kim, Hank H., Esq.  "The Secure Choice Pension: A Way 
          Forward for Retirement Security in the Private Sector."  
          National Conference on Public Employee Retirement Systems 
          (September 2011).








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           This bill provides that each eligible employee shall be enrolled 
          in the Program unless the employee elects not to participate.  
          An eligible employee may elect to opt out of the Program by 
          making a notation on an exemption certificate produced by EDD.  
          The bill also provides that, at least once every two years, 
          participating employers shall designate an open enrollment 
          period during which eligible employees that previously opted out 
          of the Program shall be enrolled unless the employee again 
          elects to opt out.

          The bill provides that an employee who elects to opt out of the 
          Program who subsequently wants to participate through the 
          employer's payroll deposit retirement savings arrangement may 
          only enroll during the employer's designated open enrollment 
          period or if permitted by the employer at an earlier time.  
          Finally, an eligible employee may also terminate his or her 
          participation in the Program at any time in a manner prescribed 
          by the Board and thereafter by making a notation on the 
          exemption certificate produced by EDD.

          According to the author, the opt-out nature of this bill 
          conforms to recent research that suggests that individuals need 
          a "nudge" in the form of automatic enrollment in retirement 
          savings programs<5>.  According to information submitted by the 
          author, in one study comparing opt-in to automatic enrollment, 
          researchers found that participation rates in opt-in plans were 
          just 20 percent after three months, increasing to 65 percent 
          after 36 months.  With automatic enrollment, by contrast, the 
          rates were 90 percent and 98 percent, respectively<6>.

          In a recent report by the United States Government 
          Accountability Office (GAO) examining enrollment in 401(k) 
          plans, the GAO stated that automatic enrollment "appears to 
          significantly increase participation in 401(k) plans according 
          to existing studies, but may not be suitable for all plan 
                                                         sponsors.  Some studies found that participation rates can reach 
          as high as 95 percent under automatic enrollment?In most cases, 
          these plans automatically enroll only new employees, rather than 
          all employees.  We also found that automatic enrollment may not 
          be suitable for all plan sponsors, such as those with a 


          ---------------------------

          ---------------------------
          <5> See, for example, Thaler, Richard.  Nudge: Improving 
          Decisions About, Health, Wealth and Happiness (2008).
          <6> Id.








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          high-turnover workforce."<7>
           
          ARGUMENTS IN SUPPORT  :

          The author states the following in support of this bill:

          "Across the United States, millions of workers will retire into 
          poverty because they will not have enough in assets to meet 
          their basic needs in their senior years.  Here in California, 
          nearly one-half of workers will face significant economic 
          hardship in retirement, with incomes below 200% of the federal 
          poverty threshold.  
          The most at-risk groups are young workers age 25-44 and 
          low-income workers, but even middle-income workers will be at 
          substantial risk of not having enough retirement income to be 
          self-sufficient.

          Since the nation's personal savings rate is extremely low and 
          retirement planning is now largely controlled by private 
          for-profit Wall Street investment firms, the United States is 
          staring at an economic time bomb that left unaddressed will 
          overwhelm taxpayer-funded entitlement and other safety net 
          programs.  The lack of retirement savings affects all 
          Californians, as seniors without sufficient retirement savings 
          will more likely need to rely on government assistance for 
          housing, health care and other basic necessities?

          ? California workers in the private sector need a lifelong 
          retirement savings system that provides them with the 
          opportunity to build their assets and achieve financial 
          stability in retirement.  The California Secure Choice 
          Retirement Savings Program would provide a vital supplement to 
          Social Security income by offering participants a low-risk, 
          low-cost, and completely portable retirement savings plan that 
          will have a guaranteed interest rate on their retirement 
          savings. 

          Employers that want to offer their employees a retirement 
          savings plan also need a way to help their employees save for 
          retirement.  Private sector employers often face significant 
          barriers in setting up their own workplace retirement plans-in 
          addition to the costs of hiring service providers and paying 
          service fees, plans such as 401(k)s can be complex to maintain 
          ---------------------------
          <7> United States Government Accountability Office.  "Retirement 
          Savings: Automatic Enrollment Shows Promise for Some Workers, 
          but Proposals to Broaden Retirement Savings for Other Workers 
          Could Face Challenges."  (October 2009).








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          and administer, employers must accept fiduciary responsibility, 
          and they are subject to an array of rules and regulations.

          Under the California Secure Choice Retirement Savings Program, 
          voluntary contributions from employees and employers would be 
          pooled into a professionally-managed retirement fund that 
          leverages economies of scale and longer investment horizons to 
          offer every California worker the chance to enroll in a 
          retirement savings plan.

          Here in California, over 6.3 million private sector workers do 
          not have access to a retirement plan at their place of 
          employment.  If these workers contributed 3% of their earnings 
          towards a retirement fund, the fund would have over $6 billion 
          to invest in the first year alone."

           Taxpayer Protections  

          The author also contends that this bill contains the following 
          protections for California taxpayers:
           
                  Prior to the development of the California Secure Choice 
               Retirement Savings Program, direct the Board to conduct a 
               market analysis to determine the viability of 
               implementation, including the assessment of likely 
               participation rates, contribution levels, and the 
               feasibility of investment vehicles.  

                 The market analysis would only be conducted if 
               sufficient funds are made available through a non-profit or 
               private entity, federal funding, or an annual Budget Act 
               appropriation for this purpose.

                 Following the market analysis, forward the Board's 
               findings to the Chairs of the Senate Public Employment and 
               Retirement Committee and the Assembly Public Employees, 
               Retirement and Social Security Committee.
          
                 The implementation of the California Secure Choice 
               Retirement Savings Program would only move forward if the 
               Board notifies the Director of Finance that based on the 
               market analysis the program will be completely 
               self-sustaining.  
               
                 Before studying, developing and obtaining the necessary 









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               approvals to fully implement the California Secure Choice 
               Retirement Savings Program, the Board would have to receive 
               sufficient funding to cover start-up costs through a 
               non-profit, private entity, federal funding, or an annual 
               Budget Act appropriation.

                 Once fully implemented, the California Secure Choice 
               Retirement Savings Trust would be self-sustaining and 
               extremely low-risk due to the modest guaranteed benefit 
               (likely tied to the 30-year Treasury-bond rate) and long 
               investment horizon.  In guaranteeing the rate of return for 
               the retirement savings plans, ensure zero-liability to the 
               state by requiring the Board to secure private underwriting 
               and reinsurance to manage risk.

                 There would be no state liability for the retirement 
               savings benefit that is guaranteed to program participants. 
                Any financial liability for the payment of benefits that 
               exceeds the funds available in the program would be borne 
               by the private underwriters pursuant to the contract 
               entered into with the Board on behalf of program 
               participants.
          
           Employer Liability Protections and Disclosures for Employees  

          The author also argues that the bill contains the following 
          protections for employers and employees:
           
                  Employees would receive a program information packet 
               with a disclosure form that includes the benefits and risks 
               of making retirement contributions, the mechanics of how to 
               participate or opt out of the program, the process for the 
               withdrawal of retirement savings, and how to obtain 
               additional information about the program.  

                 The disclosure form would clearly inform employees that 
               employers are not liable for their decisions whether to 
               participate in or opt out of the program, or for employee 
               investment decisions, and state that their employer is not 
               a fiduciary of the California Secure Choice Retirement 
               Savings Trust or program, the employer does not bear 
               responsibility for how the program is administered, and the 
               employer is not liable with regard to investment returns 
               and benefits paid to program participants.










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                 In addition, the disclosure form would notify employees 
               that their employers are not in a position to provide 
               financial advice, and that they should contact financial 
               advisors if they want to seek financial advice.  

                 To notify employees that the state is not liable for the 
               retirement savings benefit, the form would also specify 
               that the program fund is privately insured and is not 
               guaranteed by the State of California.
                 Employees would be required to sign and date the 
               disclosure form acknowledging that they have read all of 
               the disclosures and understand their content.

           ARGUMENTS IN OPPOSITION  :

          Opponents, including the Securities Industry and Financial 
          Markets Association, argue that California already faces 
          hundreds of billions of dollars in unfunded pension liability 
          for its public sector workers.  They contend that now is not the 
          time for the state to create and assume liability for any new 
          plan for private sector employees.  Moreover, they contend that 
          the legislation is unnecessary as California already has a 
          robust and highly competitive retirement savings market.

          Opponents contend that, among other things, this bill could 
          create undue pressure on the General Fund, could create a 
          multi-billion dollar liability for the state, unnecessarily 
          enters the federal government's domain, and is inconsistent with 
          the Administration's efforts to reduce government.

          Opponents also argue that this bill continues to raise problems 
          for the small employers by imposing a mandated benefit rather 
          than giving employers the flexibility to offer the mix of 
          compensation and benefits that best meets the needs of their 
          employees.  They note that this bill seeks to eliminate an 
          employer's potential federal liability and responsibility but do 
          not believe that a state bill has that authority under federal 
          law (ERISA or the Internal Revenue Code).  Opponents also state 
          that recent amendments reduce but do not eliminate the 
          employers' operational responsibilities and compliance costs.  
          Employers will still have to distribute information, answer 
          questions, collect opt-out forms, and transfer contributions to 
          the Program. 

          Opponents object that this bill raises "serious cost issues."  









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          Initial costs to study and develop the program and to obtain the 
          necessary federal approvals will likely be significant.  Such 
          costs will increase dramatically if the program faces a legal 
          challenge.  While this bill sets aside one percent (1%) of the 
          total program fund to administer the program trust on an ongoing 
          basis, it is highly likely that administrative, compliance, 
          insurance, premiums and other costs will exceed that amount. 

          Opponents contend that the guaranteed rate of return on 
          investment creates the very real possibility that the state will 
          have to fill the gap between the promised and the realized rates 
          of return. Insurance - which, of course, comes at a cost - may 
          assist in this process, but the ultimate responsibility rests 
          with the state, either as an explicit or "implied" guarantee.  
          With respect to potential "funding shortfalls" opponents state 
          the following:

               "As with any defined benefit plan, the employer/plan 
               sponsor bears investment risk. Changes in the value of the 
               plan's investments (usually managed by the employer or an 
               investment manager) generally do not affect the amount of 
               benefits owed to participants. The funding rules for 
               defined benefit plans also apply to cash balance plans. 
               Under a cash balance plan, funding obligations are 
               determined actuarially based on the plan's benefit 
               commitments which include interest credits, the value of 
               the plan's asset and expected plan demographic experience. 
               Required contributions do not necessarily equal the sum of 
               contributions to the hypothetical accounts. Under the 
               Program, based on annual actuarial valuations of plan 
               assets, if participant contributions to the plan do not 
               equal the required minimum funding obligation for a year 
               based on the funding rules, then additional contributions 
               must be made. 

               Under the bill, the Board is directed to annually adopt a 
               statement of investment policy and to select an investment 
               management entity or entities. However, it does not address 
               who is responsible for any funding shortfalls. Generally, 
               under the Ýfederal law] provisions applicable to multiple 
               employer plans, each employer is treated as maintaining a 
               separate plan for purposes of minimum funding standards. 
               This would suggest that each participating employer will be 
               left liable for any funding deficiencies. What if a 
               participating employer has gone out of business? What if 









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               the employer no longer employs any participating employees? 
               Would the State (state taxpayers) step in? 

               Sponsors of the bill counter that an insurance policy will 
               address this issue. The state assumes the existence of an 
               insurance policy that would cover market risk regarding the 
               assets, longevity risk (because defined benefit plans must 
               offer an annuity form of payment), benefit guarantees set 
               by the Board, and a risk regarding administration. If this 
               type of coverage is available, we expect it will be very 
               expensive. This expense would also likely be paid from the 
               administrative fund, which has the 1% limit on expenses 
               cited above. Note however, that even if an insurer did 
               cover these costs, ERISA would not shift liability to the 
               insurer; the participating employer would retain liability 
               for payment of any underfunding. This is significant 
               because in the event the insurance contract is discontinued 
               or for some reason the specifics of the contract do not 
               require payment in any case, the participating employer is 
               the entity who would be left responsible for these amounts 
               under the federal tax code."

          Opponents conclude that, "In the case of a market downturn, such 
          as occurred in 2008, a devastating funding shortfall would be 
          likely.  The liability will be left to a state which is already 
          struggling financially, or to California employers who were 
          forced to participate.  We do not believe that an insurance 
          contract is enough to address these significant concerns."

           PRIOR RELATED LEGISLATION  :

          AB 125 (De Leon) of 2009 would have created a California 
          Employee Savings Program to be administered by CalPERS.  That 
          bill was held in the Senate Committee on Appropriations.

          AB 2940 (De Leon) of 2008 was nearly identical to AB 125 of 
          2009.  AB 2940 was held in the Senate Committee on 
          Appropriations. 

           REGISTERED SUPPORT / OPPOSITION  :

           Support 
           
          AARP-California
          American Federation of State, County and Municipal Employees, 









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          AFL-CIO
          Association of California School Administrators
          California Association of Professional Scientists 
          California Association of Psychiatric Technicians
          California Communities United Institute
          California Faculty Association
          California Labor Federation, AFL-CIO
          California Professional Firefighters
          California Retired County Employees Association
          California School Employees Association
          California Teachers Association
          California-Nevada Conference of Operating Engineers
          Congress of California Seniors
          Earned Assets Resource Network
          East Hollywood Chamber of Commerce
          Faculty Association of California Community Colleges
          Greenlining Institute
          JERICHO
          Latinos for a Secure Retirement
          Little Armenia Neighborhood Association
          National Conference on Public Employee Retirement Systems
          National Hispanic Council on Aging
          Numerous individuals 
          Peace Officers Research Association of California
          Professional Engineers in California Government
          SEIU United Long Term Care Workers
          Service Employees International Union Local 1000
          Service Employees International Union Local 99
          State Association of County Retirement Systems
          TELACU
          United Food and Commercial Workers Local 1428
          United Teachers Los Angeles
          Western Prelacy Armenian Schools
          Workers United-SEIU Western States Regional Joint Board
           
            Opposition 
          
          American Council of Life Insurers
          Association of California Life and Health Insurance Companies
          California Association of Health Underwriters
          California Chamber of Commerce
          California Farm Bureau Federation
          California Grocers Association
          California Independent Grocers Association
          California Manufacturers & Technology Association









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          California Retailers Association
          California Small Business Association
          Financial Planners Association
          Financial Services Institute
          Fullerton Chamber of Commerce
          Garden Grove Chamber of Commerce
          Hispanic Engineers Business Corporation
          Howard Jarvis Taxpayers Association
          Insurance Brokers and Agents of the West
          Investment Company Institute
          Long Beach Area Chamber of Commerce
          National Association of Insurance and Financial Advisors of 
          California
          National Federation of Independent Business
          Orange Chamber of Commerce
          Pacific Life Insurance Company
          Plumbing-Heating-Cooling Contractors Association of California
          San Gabriel Valley Legislative Coalition of Chambers
          Securities Industry and Financial Markets Association
          Small Business California
          Western Electrical Contractors Association


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