BILL ANALYSIS �
AB 1927
Page 1
Date of Hearing: April 28, 2014
ASSEMBLY COMMITTEE ON BANKING AND FINANCE
Roger Dickinson, Chair
AB 1927 (Frazier) - As Amended: April 10, 2014
AS PROPOSED TO BE AMENDED
SUBJECT : Student financial aid: debit cards.
SUMMARY : Specifies the creation of policies concerning the
issuance of financial aid via debit cards. Specifically, this
bill :
1)Requires the Board of Governors of the California Community
Colleges and the Trustees of the California State University
and requests the Regents of the University of California as
well as the governing bodies of private institutions
(henceforth be referred to as "educational institutions") to
adopt policies relating to the disbursement of financial aid
via debit cards, prepaid, or preloaded card (All further
references will be to "debit cards").
2)Specifies that the aforementioned policies should be used for
negotiating contracts between educational institutions and
financial institutions.
3)Provides that the policies adopted shall be consistent with
federal law, and ensure that contracts between educational
institutions and banks or other financial institutions to
disburse financial aid onto debit cards shall meet the
following standards:
a) Prohibit revenue sharing between educational
institutions and banks or other financial institutions;
b) Prohibit the sale or sharing of private information that
the student or the educational institution provides the
bank or other financial institution;
c) Prohibit the bank or other financial institution from
imposing unreasonable fees, including a point of sale
transaction fee on a student for the use of the debit card;
d) Provide that if the card is cobranded the student shall
receive a disclosure that the card is not endorsed by the
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educational institution;
e) Require a disclosure of all fees associated with the
debit card;
f) Ensure that the student does not incur any cost in
opening the account or initially receiving the debit card;
g) Ensure that the student has convenient access to a
branch office of the bank or an automated teller machine
(ATM) of the bank in which the account was opened or of
another bank, so that the student does not incur any cost
in making withdrawals from that office or those ATMs;
h) The branch office or ATMs must be located on the
educational institution's campus, in an institutionally
owned or operated facility, or immediately adjacent to and
accessible from the campus;
i) Ensure that the debit card can be widely used;
j) Not market or portray the account or debit card, prepaid
card, or preloaded card as a credit card or credit
instrument, or subsequently convert the account or debit
card to a credit card or credit instrument; and,
aa) Disclose to students the benefits and responsibilities
of all options of financial aid disbursement that are
offered by the educational institution.
EXISTING FEDERAL LAW
1)Pursuant to 30 C.F.R., Section 668.164, provides that an
educational institution may establish a policy requiring its
students to provide bank account information or open an
account at a bank of their choosing, as long as this policy
does not delay the disbursement of specified federal loan
funds to students. Requires institutions that open bank
accounts on students' or parents' behalfs, establish a process
that students or parents can follow to open a bank account, or
assist students or parents in opening accounts to do all of
the following:
a) Obtain written consent from the student or parent to
open the account;
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b) Inform the student or parent of the terms and conditions
associated with accepting and using the account, before
opening it;
c) Refrain from making any claims against the funds in the
account without the written permission of the student or
parent, except to correct an error in transferring the
funds;
d) Ensure that the student or parent does not incur any
cost to open the account or initially receive any type of
debit card, stored-value card, or other type of ATM card,
or similar transaction device used to access the funds in
that account;
e) Ensure that the student has convenient access to a
branch office of the bank or an ATM of the bank in which
the account was opened (or an ATM of another bank), so that
the student does not incur any cost to make cash
withdrawals from that office or those ATMs. This branch
office or these ATMs must be located on the institution's
campus, in institutionally-owned or operated facilities, or
immediately adjacent to and accessible from the campus;
f) Ensure that the debit card, or other device, can be
widely used (e.g., the institution may not limit the use of
the card or device to particular vendors); and
g) Not market or portray the account, card, or device as a
credit card or credit instrument, or subsequently convert
the account, card, or device to a credit card or credit
instrument;
2)Allows schools to contract with servicers for the
administration of any aspect of the school's participation in
Title IV programs and specifies that a school may accept the
standard contract terms and conditions in a servicer's
proposal for delivering credit balances or negotiate the terms
and conditions to meet the specific needs of the school or its
students (34 CFR � 668.25).
EXISTING STATE LAW
1)Defines the term "debit card" as an accepted card or other
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means of access to a debit cardholder's account that may be
used to initiate electronic funds transfers and may be used
without unique identifying information such as a personal
identification number to initiate access to the debit
cardholder's account (Civil Code [CIV] � 1748.30).
2)Limits a debit cardholder's liability for unauthorized use of
a debit card (CIV � 1748.31).
3)Provides for a variety of student financial aid programs
including the Cal Grant programs and the CCC Board of
Governors fee waiver program. Current law requires that
eligibility for a Cal Grant and the determination of financial
need be accomplished using the Free Application for Federal
Student Aid (FAFSA), and that this application be used for all
programs funded by the state or a public institution of
post-secondary education, as well as all federal programs
administered by an educational institution. Current law makes
an exception to this requirement for the Board of Governors
fee waiver program which is authorized to use a simplified
application designed for that sole purpose (Education Code �
69432.9 and � 69433).
FISCAL EFFECT : Unknown
COMMENTS :
In citing the need for the bill, the author's office provides
the following:
According to a 2012 report by the U.S. Public Interest
Research Group, Campus Debit Card Trap, banks and financial
firms are forming partnerships with colleges and
universities to produce campus ID cards and to offer
student aid disbursements on debit or prepaid cards. The
federal government requires that schools disburse financial
aid refunds to students free of charge; however, these
debit cards can come with fees for other services that can
take away from students' aid. As a result students end up
bearing some costs directly, including per-swipe fees,
inactivity fees, overdraft fees, ATM fees and more.
The report contends that debit cards for disbursing funds
may be good for colleges, but argue that cash-strapped
students absorb the costs. The U.S. Public Interest
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Research Group study finds that some debit cards come with
fees as high as 50 cents per swipe in transaction fees,
$38.00 per overdraft and $10.00 for inactivity after six
months without use. The PIRG study also finds that
students do not fully realize what they are signing up for
when they elect to receive their financial aid award via
debit card.
A February 2014 report by the United States Government
Accountability Office (GAO) identified the nonbank
financial firm Higher One as the dominant provider with 57
percent of the market share. Higher One has contracts with
a number of the California Community Colleges and
Districts, as well as a partnership with California State
University Fresno to distribute financial aid, including
CalGrants.
In August 2012, the Federal Deposit Insurance Corporation
(FDIC) ordered Higher One to pay restitution of nearly $11
million to approximately 60,000 students for unfair and
deceptive practices, and was obligated to pay $110,000 in
civil penalties. Most recently in November 2013, Higher One
entered an agreement to settle a class action lawsuit for
$15 million. The lawsuit was initiated by students who
claimed they were being charged excessive fees and were
misled by marketing that inferred Higher One's product was
the schools' preferred method of receiving financial aid.
The GAO also reports that many concerns have been raised
over revenue sharing agreements that may exist between
colleges and contracted third-parties. Federal officials
and consumer advocates question whether the payments or
benefits that a college receives may encourage schools to
choose a contract that provides the school the most
revenue, as opposed to a contract that best serves the
needs of the students.
AB 1927 arises out of concern that college students in
California that receive some form of financial aid via debit
card may not be aware of the actual costs of using this method
of receiving aid, and that the relationship between educational
institutions and financial institutions has created pressure to
over promise and under deliver the benefits of a debit card use
for financial aid delivery. The GAO released a report in
February 2014, College Debit Cards, Actions Needed to Address
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ATM Access, Student Choice, and Transparency that raised several
concerns that are the subject of this legislation. The GAO
report found that the use of debit cards can be beneficial for
students and schools. The use of cards for aid disbursement can
lower the costs of issuing paper checks, decrease chances of
fraud, expand functionality and defray costs of student ID
cards. These cards also provide revenue generation
opportunities for campuses as some campuses and card providers
have payment arrangements based on card activity that can bring
in extra money to the campus. Additionally, financial aid
offices can outsource their disbursement activities and the
accompanying overhead costs to the card providers. These cards
can benefit students by providing a way to enter the mainstream
as some college students are unbanked. When such cards are
linked to the student's ID card it can provide multipurpose
convenience as a single card can perform banking functions and
facilitate access to campus buildings and library services.
Funds can be available the same day that they are released to
the provider, versus 2-3 business days of direct deposit, or 5-7
days for paper check.
The GAO report examined the common complaints arising from the
use of debit cards for financial aid disbursement. The
following are some of the GAO findings:
Fees: Generally the fees charged for the use of college debit
cards were similar to those fees charged for basic checking
accounts offered by national banks. Fees were also lower for
college debit cards than for alternative financial services like
check cashing stores. The GAO found that fees for transactions
involving personal identification numbers (PIN) exceeded those
of traditional bank accounts as Higher One and Citibank,
representing 60% of the market charge $0.50 for transactions
that use PIN rather than signature. No other basic or student
checking account reviewed by GAO charged this fee. The fee can
be avoided by authorizing a purchase with signature, but the
signature option involves choosing the "credit" option on the
point of sale device which be confusing for students as the card
is a debit card, not a credit card. The use of student debit
cards can also lead to the imposition of ATM charges if the
student uses an out of network ATM. Typically, these fees range
from $2.00-$3.00 per transaction plus the operator of the out of
network ATM may also impose a surcharge of around $2.00.
However, these out of network ATM fees are very common across
all types of traditional banking accounts.
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ATM access: Out of network ATM charges may be common among all
types of bank accounts, but the access to ATMs for college debit
cards may create situations where students face surcharges that
could otherwise be avoided. ATM coverage varies from school to
school. Also, at some schools, students may face lengthy lines
to access free ATMs, or that ATMs are in locations that are not
available outside of normal business hours. Federal Department
of Education (Education) regulations require that students have
"convenient access" to ATMs or a branch office where students
will not incur any costs making cash withdrawals from the bank
in which the account was opened. The definition of "convenient"
is that the branch office or ATM must be located on the
institution's campus, in institutionally owned or operated
facilities, or a location immediately adjacent to and accessible
from the campus.
Neutrality: Concerns have arisen that school and industry
practices may influence student's choice of the debit card
option even when it may not be the best choice. Schools can
appear to implicitly or explicitly endorse college cards via
their relationship with the card provider and co-branding of the
card. Many students believe that the co-branding is an
endorsement and indication that the school has negotiated the
best terms. Four of eight card providers interviewed by the GAO
said that at least some of their agreements with schools include
exclusivity clauses that bar other financial institutions from
locating ATMs or an office on campus. Signing up for a college
debit card is the option of the student, yet in some cases
schools do not provide payment options in a clear or neutral
fashion which appear to encourage the students to pick the
college card over other options.
The GAO is not the only entity to report on this subject. On
March 10, 2014 the United States Department of Education, Office
of Inspector General (DOEOIG) released a report, "Third-Party
Servicer Use of Debit Cards to Deliver Title IV Funds." DOE OIG
performed work at schools that outsourced credit balance
delivery gave servicers significant control over the Title IV
funds delivery process and relied on them to meet Title IV
regulations. However, the schools did not appear to routinely
monitor all servicer activities related to this contracted
function, including compliance with all Title IV regulations and
student complaints.
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1)Schools did not prevent their servicers from using marketing
and other strategies to persuade students to select their
debit card over other available options.
2)The schools' servicers appeared to deliver Title IV funds to
students without charging fees. However, students who chose a
servicer's debit card option could incur fees after the
servicer deposited the funds into the student accounts. In
some cases, those fees appeared to be unique or higher than
those of the alternative financial service providers.
3)Schools had financial incentives in their contracts with
servicers that created the potential for conflicts of interest
that could influence school officials' decisions and actions
at the expense of student interests.
4)Schools that contracted with Higher One had fee-free ATMs on
campus, but one school that contracted with Sallie Mae did
not.
5)Schools provided, or servicers collected, student information
that was not needed to deliver credit balances. In addition,
the schools did not monitor servicer activities for compliance
with Federal requirements for handling personally identifiable
information.
Pending federal rules.
In response to a series of public hearings and outreach efforts,
Education began a negotiated rule making process to expand the
rules governing disbursement of financial aid via debit cards.
The proposed rules are as follows:
1)The school must disclose conspicuously on its website, or
otherwise make public, the contract arrangement in its
entirety.
2)Prior to the student or parent activating a debit card for the
disbursement of funds the school must do the following:
a) Inform the student or parent of the terms and conditions
of the account, and obtain in writing affirmative consent
from the student or parent to open the account;
b) Review any information that is provided to the student
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or parent about the account, and the debit card associated
with the account, to ensure that the information is
presented to the student in an objective and neutral
manner;
c) Acquire consent from the student or parent prior to
sending a debit card, prepaid car, or access device
associated with the account;
d) The school may not offer a debit card associated with
the account that bears the institution's logo or mascot, or
that otherwise implies an affiliation with the institution;
e) The school may not make any claims against the funds in
the account without the written permission of the student
or parent, except for correcting an error in transferring
the funds in accordance with banking protocols;
f) The school shall ensure that the student does not incur
any cost in-
i) Opening the financial account or initially receiving
the debit card, prepaid card, or access device associated
with the account;
ii) Maintaining the account; or
iii) Using the debit card to conduct any transaction at
any ATM located in any State as defined in 600.2;
g) Must ensure that the debit card associated with the
account can be used nationally;
h) May not market or portray the financial account, debit
card as a credit card or credit instrument, or subsequently
convert the account, card, or device to a credit card or
credit instrument;
i) May not charge the student or parent any overdraft fees
if the financial account is overdrawn;
j) Must ensure that:
i) The provider of the card or device provides the
student or parent with pass-through deposit or share
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insurance; and,
ii) The card or device does not have an attached line of
credit or loan feature under which repayment from the
account is triggered upon the delivery of a Federal
payment, including a deposit or transfer of title IV, HEA
program funds into the account; and
aa) The account provides the student or parent with all the
consumer protections that apply to a payroll card account
under the Electronic Fund Transfers Act; and,
bb) Ensure that the financial account is in the student's or
parent's name, or for a financial account that is a pooled
custodial account, the subaccount (or card or device) is in
the student's or parent's name. The custodial bank account
must be established in the name of the institution or the
institution's third party servicer, and must be set up to
ensure that any title IV, HEA program funds that become the
pooled funds of the custodial account are credited
immediately to the student's or parent's subaccount (or
card or device).
These proposed rules are subject to ongoing negotiations as
Education has recently announced the addition of a fourth round
of meetings to occur in mid-May 2014. The background documents
and comments submitted concerning these proposed rules and the
rule making process are available at
http://www2.ed.gov/policy/highered/reg/hearulemaking/2012/program
integrity.html .
Discussion.
The April 10, 2014 version of this bill was heard in Assembly
Banking & Finance Committee on April 21st. The bill was not
taken up for a vote at that time as the committee and author
wanted to provide more time for various parties to address some
of the issues brought up during the hearing.
Fees.
The proposed mock-up under consideration would require that the
contracts between educational institutions and card issuers
avoid unreasonable fees, including any fees charged by the
financial institution for point of sale transactions. It is
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next to impossible to avoid all fees relating to financial
account transactions and maintenance. Even debit cards issued
for unemployed insurance benefits, or public assistance have the
potential for user fees. As the GAO report compared financial
aid debit cards with typical financial institution checking
accounts they found that even with the most basic starter
checking account not all fees can be avoided. This
unfortunately has become part of life for consumers. However,
the mock-up of AB 1927 attempts to address the one specific fee
that is rarely, if ever, included with traditional checking
accounts. That is the imposition of a PIN fee by the financial
institution. It is possible to be charged a fee by a retailer
when using a debit card, but typically the issuer of the card
does not charge such fees. The GAO report found that some
financial aid debit card issuers have charged this fee to
students and that this type of fee is not in the conventional
checking account marketplace. This bill would prohibit
unreasonable fees, including a point of sale fee charged by the
card issuer. This would place the potential fees that could be
charged to a student debit card more in align with the fees that
they would face if they established a checking account with a
bank or credit union.
Pending federal regulations.
As referenced earlier, the issues around student debit cards
have raised a number of questions and concerns. The concerns
have led to a rulemaking process that is currently underway with
Education and various stakeholders in order to finalize proposed
rules (Outlined on page 6 of this analysis) that in many ways
significantly overlap with the proposed policies of AB 1927.
Typically, when these cases arise in which a legislative remedy
is proposed to an issue that is subject to pending federal
regulatory action the committee is advised to act with caution.
Often, this caution is reflected via a recommendation that the
proposed legislative solution should be held in committee until
such time as the federal regulatory landscape becomes clear.
Nevertheless, delayed action is not always recommended, as each
case must be evaluated subject to the specific facts relating to
the policy issues.
This committee, has on some occasions, allowed measures to move
forward even with pending federal action. Several reasons may
justify further action. First, that the issue is of such
importance to the state of California that the Legislature has a
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duty to react to federal action to potentially enhance and
exceed federal regulations. Second, that the proposed federal
rules, subsequent to the rule making process, may not provide
the protections that the Legislature deems necessary for the
issue at hand. Finally, that potential state action does not
create conflict, or the potential for different sets of federal
and state rules that could actually weaken the regulation of a
specific issue, rather than strengthen it. In weighing these
issues staff identifies that the issues contained in AB 1927
meet the tests as outlined previously. Is this issue of such
importance to California that specific state action may be
needed? Yes, According to the National Center for Education
Statistics, California is number one in the nation with 2.6
million students attending post-secondary institutions meaning
that the issue of student debit cards potentially harms
California more than other states. Will the proposed rules
provide the protection necessary? While the proposed draft
rules are strong, it is difficult to determine how they will
look after completion of the federal rulemaking process.
Finally, would AB 1927 create a conflict? The proposed
Education rules and AB 1927 may overlap but staff does not
believe that the federal rules and AB 1927 create conflict in
California.
In spite of the reasons outlining why pending federal regulation
should not delay this proposal, the committee may want to
consider that once the regulations are finalized that the this
bill should be called back to committee for further action in
order to resolve any conflict that could occur.
Preemption
Opposition to AB 1927 has argued that the ban on fees in the
bill is prohibited under the National Bank Act (NBA) and
therefore should AB 1927 become law it would be preempted in
relation to its enforcement pertaining to national banks. The
issue as to whether a state law is preempted is best left to the
courts to decide. Conversely, at times some issues are clearer
as to whether they may be potentially preempted. In the present
case, the preemption argument is very tenuous. The NBA and
subsequent court decisions that preempt state law typical
preempt direct state action or enforcement against national
banks. AB 1927 requires educational institutions to meet the
standards in the bill when negotiating contracts for student
debit cards. National banks are not required to do anything
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specified in AB 1927. Frankly, in the post Dodd-Frank era
federal preemption doctrine is not a broad battle axe swinging
its way through state laws allowing national banks to abandon
compliance with state laws. National banks, may in some way,
be indirectly affected by the outcome of AB 1927, but that does
not equate to federal preemption. AB 1162 (Frazier) of 2013 is
telling in this regard. The provisions of AB 1162 were
substantially similar to the provisions of AB 1927. This is
important because the author requested an opinion from
Legislative Counsel on the preemption question as it related to
AB 1162. Staff believes these two bills are so similar that the
Legislative Counsel Opinion on AB 1162 is analogous to AB 1927.
The following are some highlights of that opinion:
In our view, merely encouraging a educational institution
to consider certain issues when adopting contract
negotiation policies, even if those issues relate to
banking account fees, does not amount to regulation of the
manner, content, or terms and conditions of a financial
transaction or related account. AB 1162 would not prohibit,
or set any condition on, the exercise of a power granted to
a national bank. Further, if a national bank agreed to a
contract with a postsecondary educational institution that
included contract provisions relating to those specified
issues then the contract would not be preempted because
contractual obligations voluntarily agreed to by a national
bank that are more restrictive than federal law are not
preempted-See Smith v. Wells Fargo Bank, N.A. (2005) 135
Cal.App.4th 1463, 1483; Gibson v. World Savings & Loan
Assn. (2002) 103 Cal.App.4th 1291, 1299-1300.
Even if a court were to interpret the provisions of AB 1162
to require postsecondary educational institutions to
include a specific contractual provision relating to fees
in certain contacts with a national bank, we think that the
marketplace participant doctrine exception to federal
preemption?would apply in this context.
We believe the provisions of AB 1162, if enacted, would
reflect only the state's desire to ensure that certain
postsecondary educational institutions of the state deliver
goods and services efficiently, and are not intended to
impose a particular policy on a national bank. Moreover,
since AB 1162 is narrowly drawn to apply only to specific
types of contracts and to provisions that best serve the
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needs of students, we think that the marketplace
participation doctrine would apply.
When supplying financial aid to a student, the state has an
interest, just as any private party that provides financial
aid would have, to ensure that the financial aid is
delivered to the student in a form that is efficient and
cost effective, and in a readily accessible manner."
Indeed, federal regulations require an institution that
provides federal financial aid to a student by creating an
account for that student at a bank, to ensure that "the
student or parent does not incur any cost in opening the
account or initially receiving any type of debit card,
stored-value card, or other type of automated teller
machine (ATM) card, or similar transaction device that is
used to access the funds in that account." (34 C.F.R. �
668.164.) Thus, the state requiring, in a capacity,
specified protections for students would appear to be
consistent with the goals federal regulatory law that also
relate to the protection of students. In short we think
that AB 1162 would not be enforcing a particular policy on
a national bank, but, instead, would only be rationally
exercising the authority of the state to narrowly use its
proprietary powers to ensure an effective delivery of goods
and services for contracts in which it is directly
involved. -See South Coast Air Quality Management, supra,
498 F.3d at p. 1041; Mayor of City of New York, supra, 4
Misc.3d at pp. 155-156.
Furthermore, opponents have pointed to an overly broad legal
opinion that claims that AB 1162 would be preempted and by
extension so would AB 1927. Much of the justification for this
belief relies on previous court cases such as:
Municipal ordinances that prohibited national banks from
charging ATM fees to nondepositors. Bank of America, N.A.
v. City and County of San Francisco, 309 F.3d
551, 564 (9th Cir. 2002), cert denied, 538 U.S. 1069
(2003).
$800 underwriting fee imposed by a national bank for the
refinancing of mortgage
loans. Martinez v. Wells Fargo Home Mortg., Inc., 598 F.3d
549, 556 (9th Cir.
2010).
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State law claims alleging that bank's practice of ordering
customer checks and debit
card instructions using a protocol of "high-to-low" posting
is an "unfair" business
practice. Gutierrez v. Wells Fargo Bank, N.A., 704 F.3d 712
(9th Cir. 2012).
State law claims alleging that federal savings and loan
association's policy not to
refund lock-in fees after applicants cancelled transaction.
Silvas v. E*Trade Mortg.
Corp. 514 F3d 1001, 1006 (9th Cir. 2008).
Claim by judgment creditors seeking to compel national bank
to turn over garnished
funds without deducting a garnishment fee. Monroe Retail,
Inc. v. RBS Citizens,
N.A., 589 F.3d 274, 284 (6th Cir. 2010.) State law claims
by mortgagor that attacked lender's allegedly hidden fees.
Newsom v. Countrywide Home Loans, Inc., 714 F.Supp.2d 1000,
1010-1011 (N.D. Cal. 2010).
State law claims that mortgage lender failed to adequately
disclose that the "teaser"
rate would only apply for one month and that the scheduled
monthly payments would
be insufficient to repay interest and principal. Conder v.
Home Sav. of America, 680
F.Supp.2d 1168, 1176 (C.D. Cal. 2010).
While these cases establish the core case law of federal
preemption of state laws regarding national banks, not one of
these cases is analogous to AB 1927. Each case involved a state
law that directly regulated the actions of a national bank
whereas AB 1927 specifies the minimum contract standards between
an educational institution and a student debit card issuer. The
responsibilities and burden of compliance is placed on the
educational institutions. Furthermore, the Office of
Comptroller of Currency (OCC) regulations contained in 12 C.F.R
�704007(b)(2) specify:
State laws on the following subjects are not inconsistent
with the deposit-taking powers of national banks and apply
to national banks to the extent consistent with the
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decision of the Supreme Court in Barnett Bank of Marion
County, N.A. v. Nelson, Florida Insurance Commissioner, et
al. 517 U.S. 25 (1996):
(1) Contracts;
(2) Torts;
(3) Criminal law;
AB 1927 is clearly a case concerning the state's authority to
regulate contracts.
Amendments.
This bill is being heard in mock-up form. This analysis
reflects the changes in the mock-up.
REGISTERED SUPPORT / OPPOSITION :
Support
California Communities United Institute
CALPIRG
Faculty Association of California Community Colleges (FACCC)
The Student Senate for California Community Colleges
University of California Student Association (UCSA)
9 individuals
Opposition
California Bankers Association (CBA)
Higher One
Analysis Prepared by : Mark Farouk / B. & F. / (916) 319-3081