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This is Jim Butler, author of www.HotelLawBlog.com and hotel lawyer. Please contact me at Jim Butler at jbutler@jmbm.com or 310.201.3526.

Published on:

17 June 2024

See how JMBM’s Global Hospitality Group® can help you.
Click here for the latest articles on Junk Fee Litigation.

Note: If you are a consumer with a Junk Fee issue, please do NOT contact us! We do not represent consumers against hotels, restaurants, or other business owners. We are part of the fabric of the hospitality industry and are committed to informing, educating, and assisting the industry. We represent business owners, helping them to understand and comply with applicable laws and defending them from consumer charges.

As of July 2, 1024, California’s Business and Professions Code is amended to impose a civil penalty of up to $10,000 for each knowing violation of strict transparent pricing standards for short-term lodging.

AB 537 applies to any hotel, residence or other place offering short-term” lodging (for 30 days or less), as well as any person or entity advertising a short term lodging price in California or from California (such as an internet site or platform).

The new law will be enforced by city, county and state legal officers. There is not private right of action under this statute.

AB 537 requires transparent pricing for all short-term lodging
Effective July 1, 2024

by

Mark S. Adams
Hotel Dispute Lawyer, Partner & Senior Member
JMBM’s Global Hospitality Group

AB 537, the California Resort Fee Law is misnamed. It should be the “Transparent Pricing for Short-Term Lodging Law”

Assembly Bill 537 (AB 537) was signed into law by Governor Gavin Newsom on October 13, 2023. It becomes effective on July 1, 2024, and adds a new Section 17568.6 to the California Business and Professions Code applicable to all advertising for short-term lodging.

The bill was originally nicknamed the “California Resort Fee Law,” but it applies to so much more than just “resort fees.” It applies to any advertising of a rate or charge for short-term lodging (hotel, motel, residence or other place for 30 days or less) in this state or from this state

What activity is covered?

The amended B&P Code section applies to all advertising (in this state or from this state) for short-term lodging.

What is short-term lodging?

Short-term lodging is defined to include hotels, motels, bed and breakfast inns, or other transient lodging.

It also includes any residential property advertised on a centralized platform and rented to a visitor for 30 consecutive days or less.

Who is covered?

The law applies to all of the following:

  • Place of short-term lodging
  • Internet website, application, or other similar centralized platform — such as a brand website, Airbnb, Expedia, Travelocity, Hotels.com, hoteltonight.com, or other travel booking platforms
  • Any other person

What 2 things are required or prohibited to avoid violation?

There are two prongs or tests for transparency in short-term lodging under AB 537. It is a violation if a covered person does either of the following:

  1. Advertises a rate for the lodging, which does not include all mandatory fees, except taxes and government charges. (no drip pricing at any time)
  2. Takes a reservation from a consumer before disclosing the “total price” of the lodging with all taxes and government charges included.

AB 537 is the only legislation we know of that requires disclosure of all taxes and government charges before taking a reservation from a guest. CONTINUE READING →

Published on:

13 June 2024
See how JMBM’s Global Hospitality Group® can help you.
Click here for the latest articles on Junk Fee Litigation.

Note: If you are a consumer with a Junk Fee issue, please do NOT contact us! We do not represent consumers against hotels, restaurants, or other business owners. We are part of the fabric of the hospitality industry and are committed to informing, educating, and assisting the industry. We represent business owners, helping them to understand and comply with applicable laws and defending them from consumer charges.

HR 6543: The US Congress wants in on Junk Fee regulation for hotels

Over the past several weeks, we have written about recent major regulatory developments concerning Junk Fees, Hidden Fees, and Drip Pricing:

  • California’s SB 478, The California Junk Fee Law, Honest Pricing Law, Transparent Pricing Law or Hidden Fees Statute
  • California’s proposed SB 1524, which will carve out an exception for the restaurant industry from the application of SB 478, and an update on its
  • FTC’s proposed rule on Unfair or Deceptive Fees, adding Part 464 to 16 CFR, defining junk fees and drip pricing to be unfair or deceptive acts or practices under Section 5(a)(1) of the FTC Act (15 U.S.C. 45(a)(1)

We now turn our attention to the very latest – the Federal proposed “No Hidden FEES Act of 2023”.

The House passes HR 6543 and enters the ring to regulate Junk Fees
for hotels and short-term lodging

by

Mark S. Adams
Hotel Dispute Lawyer, Partner & Senior Member
JMBM’s Global Hospitality Group

On June 11, 2024, the United States House of Representatives passed HR 6543, the so-called “No Hidden FEES Act of 2023” which introduces federal regulations aimed at enhancing transparency and fairness in the advertising of hotel room and short-term lodging prices. A critical component of this Act is its preemption clause, found in Section 4(a), which establishes a national standard prohibiting states from enforcing any laws that conflict with the federal mandate. This provision has significant implications for state regulations, such as California’s SB 478, which also aims to protect consumers from hidden fees in various transactions. The scope and application of this preemption clause are essential for assessing how state laws will be affected and ensuring compliance with the new federal standards.

Below, we compare the No Hidden FEES Act of 2023 to the Proposed FTC Rule on Junk Fees and California’s SB 478: CONTINUE READING →

Published on:

10 June 2024
See how JMBM’s Global Hospitality Group® can help you.
Click here for the latest articles on Junk Fee Litigation.

Mark S. Adams is the go-to senior lawyer in JMBM’s hospitality litigation team for assessing legal exposure, pursuing legitimate claims, and defending a client’s rights involving hospitality matters.

Jim Butler caught up with Mark to find out what all the fuss is about over California’s Junk Fee law (SB 478) and a proposed amendment by SB 1524 that has consumer advocates for transparent consumer prices in an uproar.

Jim Butler

 

 

As a hospitality litigator and advisor, you have been at the forefront in junk fee matters for many years, and have written extensively about the latest developments.

Tell us what all the fuss is about concerning the California Junk Fee Law.

Mark S. Adams

 

 

 

 

 

 

 

 

 

 

 

 

In October 2023, California passed a law (SB 478) that declared junk fees to be a prohibited, misleading business practice. Anyone who advertises a price for goods or services must provide the total cost on first contact. In other words, drip pricing is illegal. Sellers cannot use a come-on price to get attention with later disclosure of additional mandatory fees or charges.

See California bans Junk Fees as of July 1, 2024. Good bye to junk fees, resort fees, mandatory service charges, and drip pricing. Hello to – the fruits of SB 478.

California was the first state in the country to adopt such a comprehensive law, and it was widely hailed as a consumer victory. However, the substantive provisions of the California Junk Fee law are scheduled to become effective on July 1, 2024. And on June 6, 2024, William Dodd (with the support of the California Restaurant Association) introduced SB 1524 to exempt the restaurant industry from the California Junk Fee Law.

See Pricing transparency without hidden mandatory junk fees. Does this apply to restaurants too? New California proposed law (SB 1524 ) says “No!” Can this be right?

Jim Butler

 

Isn’t this blatant preference of special interest legislation over consumer protection?
Mark S. Adams

 

 

 

 

 

 

 

 

 

 

 

I have seen some strong criticism of the proposed SB 1524 as special interest legislation gutting landmark consumer protection. It certainly does make the playing field uneven. We have heard complaints from many other businesses affected by SB 478 who are not getting similar benefits. Just ask hotel owners or ticket sales companies.

Before Senator Dodd’s latest proposal, there were a couple of exemptions in SB 478 for certain highly regulated businesses who comply with their primary regulator’s detailed rules (such as broadband services complying with FTC regulations, or financial entities complying with relevant regulations such as the Financial Code, Truth in Lending or the Federal Reserve Act).

But SB 1524 is an outright exemption from SB 478 for any “items sold by a restaurant, bar, or other food service provider, or pursuant to a contract for banquet or catering services.”

The bill would permit drip pricing, as long as the additional mandatory fees are conspicuously set out in the advertisement, menu or other display.

Jim Butler Doesn’t that provision gut SB 478?
Mark S. Adams

 

 

 

 

 

 

 

 

 

 

 

 

Yes and no. It does exempt the restaurant industry from SB 478’s ban on junk fees, as long as the service charge or administrative fee or health compliance charge is disclosed. The consumer is not entitled to get the total cost on first exposure to price, as she would be if looking at a promotion for a hotel stay. Some people feel this is a violation of the honest pricing or transparent pricing mandate behind the reform legislation.

But unless further amended, as of July 1, 2024, SB 478 will affect every other business dealing with California consumers. Of course, most of these other affected businesses feels this is unfair. Most of them disclose various mandatory fees somewhere in the sale process. It is just that they disclose them after the initial advertised price, and after the consumer has invested time in researching the goods or services, or filling in required information to get to a form. Hiding the additional fees just frustrates open competition and makes it difficult for consumers to make wise decisions.

SB 478 is only gutted as to the restaurant industry. It applies to everyone else. Is that fair? Does that serve the public?

I guess we will have to see what the California legislature decides.

California DOJ SB 478 FAQs

Anticipating the effectiveness of the law, on May 8, 2024, the California Department of Justice released a set of SB 478 Frequently Asked Questions (SB 478 FAQs) to provide guidance on the law.

Although these SB 478 FAQs may become moot as to restaurants, they will continue to apply to all other businesses, unless exempted.

 

CONTINUE READING →

Published on:

6 June 2024
See how JMBM’s Global Hospitality Group® can help you.
Click here for the latest articles on Junk Fee Litigation.

Note: If you are a consumer with a Junk Fee issue, please do NOT contact us!  We do not represent consumers against hotels, restaurants, or other business owners. We are part of the fabric of the hospitality industry and are committed to informing, educating, and assisting the industry. We represent business owners, helping them to understand and comply with applicable laws and defending them from consumer charges.

Pricing transparency without hidden mandatory junk fees. Does this apply to restaurants too? New California proposed law (SB 1524 ) says “No!” Can this be right?

by

Mark S. Adams
Hotel Dispute Lawyer, Partner & Senior Member
JMBM’s Global Hospitality Group

For more than 20 years consumers have complained about hidden mandatory fees, junk fees, resort fees, destination fees, service fees, administration fees, health fees, surcharges, connection fees, and similar charges, whatever they are called.

California’s new “Honest Pricing Law,” SB 478, cracks down on hidden fees, requiring businesses to advertise and list a price that includes all mandatory charges. This applies to most goods and services, but a new bill, SB 1524, proposes an exception for restaurants.

SB 478: Transparent Pricing and the End of Junk Fees

SB 478, taking effect July 1, 2024, prohibits businesses from advertising a misleadingly low price and then tacking on hidden mandatory fees at checkout. This includes service charges, resort fees, and other surprise surcharges. Consumers have long complained about these “junk fees,” and SB 478 aims to create price transparency. California’s Civil Code Section 1770(a)(29), amended by SB 478, prohibits unfair business practices like misrepresenting product qualities. Importantly, it requires businesses to advertise prices that include all mandatory fees, excluding only government taxes and reasonable shipping costs. This transparency aims to protect consumers from unexpected charges. Certain industries, like those complying with FCC regulations for internet access or those already subject to federal and state disclosure laws for financial services, are exempt from this specific provision.

SB 1524: A Special Exception for Restaurants?

Introduced on June 6, 2024, SB 1524 would allow restaurants to continue adding mandatory service charges, gratuities, and other fees on top of their advertised prices, as long as these fees are clearly disclosed on menus or advertisements. The proposed amendment to Civil Code 1770, would add a new subsection 29(D) to exempt restaurants from the transparent pricing mandate of in that section by adding this language:

(D)  For purposes of this paragraph, “advertising, displaying,  or offering a price for a good or service” does not include advertising or displaying the price of individual food or beverage items sold by a restaurant, bar, or other food service provider, or sold pursuant to a contract for banquet or catering services, provided that any service charge, mandatory gratuity, or other mandatory fee or charge is clearly and conspicuously displayed on the advertisement, menu, or other display.

The Debate: Transparency vs. Industry Flexibility

This exemption has raised concerns about consumer protection and a level playing field for businesses. SB 1524’s proponents, including the restaurant industry and the labor union UNITE HERE, argue that it allows restaurants flexibility in covering costs like employee benefits. Opponents argue that this exemption undermines the core purpose of SB 478 – price transparency for consumers. They question why restaurants should be treated differently from other businesses and point out the Federal Trade Commission’s stance that hidden fees are deceptive practices. CONTINUE READING →

Published on:

24 May 2024
See how JMBM’s Global Hospitality Group® can help you.

JMBM’s Global Hospitality Group®  hosted the 31st edition of Meet the Money® national hotel conference on May 6-8, 2024. Alongside exciting networking opportunities and insightful discussion panels, the conference featured several special presentations interpreting the latest data and industry sector highlights. In the third and final part of this blog series, we highlight the special presentations given by Troy Flanagan, Ariela Kiradjian, Jackie Collins and Paul Single.

AHLA Update 2024

Troy Flanagan, Executive Vice President of External Government Affairs and Industry Relations for the American Hotel & Lodging Association, kicked off the final day of presentations by sharing AHLA’s report on the state of the industry for 2024.

Troy discussed the results from this year’s report and what it means for the year ahead for hotels. He also provided an update on key issues impacting hotels and hotel investors being considered by the government at the federal, state and local levels.

The full presentation can be downloaded here.

IMG_4030-scaled

Boutique Hotel Transaction Patterns

Ariela Kiradjian, Co-Founder, Partner & COO of the Boutique Lifestyle Leaders Association, continued the day of special presentations by exploring the dynamic investment landscape of independent boutique hotels. CONTINUE READING →

Published on:

22 May 2024
See how JMBM’s Global Hospitality Group® can help you.

JMBM’s Global Hospitality Group®  hosted the 31st edition of Meet the Money® national hotel conference on May 6-8, 2024. Alongside exciting networking opportunities and insightful discussion panels, the conference featured several special presentations interpreting the latest data and industry sector highlights. In Part 2 of this blog series, we highlight the special presentations given by Daniel Lesser and Michael Cahill.

U.S. Lodging Industry H1 2024

Daniel H. Lesser, Co-Founder, President, & CEO of LW Hospitality Advisors, continued the first day of presentations by examining the strengths, weaknesses, opportunities and threats for the U.S. Hotel Industry in 2024.

Daniel explained that robust revenues, limited new supply, and significant capital inflows continue to fuel the U.S. hotel industry’s extraordinary performance in the post-COVID era. However, cracks may be beginning to emerge with March 2024 RevPAR declining on a year-over year basis for the first time since February 2021. Group business demand, which was a laggard to rebound, is now healthy, while corporate individual travel maintains modest positive momentum.  While leisure demand continues to thrive, the segment is challenged with many Americans traveling abroad coupled with a slow return of inbound overseas visitors particularly from Asia. During the near-term, moderate U.S. RevPAR growth is expected while operating expenses are projected to rise at a rate greater than inflation.

Fundamentals of select urban markets including Boston and New York rival pre-pandemic levels while other downtown cores including Chicago and San Francisco have runway to recovery. Finally, numerous hotels including many that are physically and/or functionally obsolete are being acquired for conversion and/or redevelopment to affordable, migrant, student, or supportive housing which represent a reduction in supply. Assets with deferred brand mandated property improvement plans (PIP) are under pressure to complete them in a costly environment. Combined with $195 billion in hotel loans maturing during the next three years, and/or rising technical defaults resulting from failing to meet debt service coverage ratios, property owners will be compelled to inject fresh capital which may require deal restructuring or an outright asset sale. During the latter half of this year, price discovery and value clarity will gain traction, transaction activity will increase, and hotels will remain a darling asset class, particularly during a sticky inflation environment.

The full presentation can be downloaded here.

CONTINUE READING →

Published on:

20 May 2024
See how JMBM’s Global Hospitality Group® can help you.

JMBM’s Global Hospitality Group® recently hosted the 31st edition of Meet the Money® national hotel conference. Alongside exciting networking opportunities and insightful discussion panels, the conference featured several special presentations interpreting the latest data and industry sector highlights.

Rising Above Rates: Successful Deal Strategies in a Cash Constrained Market

Jonathan Falik of JF Capital Advisors and Guy Maisnik, Vice Chair of JMBM’s Global Hospitality Group, kicked things off by moderating a panel of industry experts discussing innovative approaches for hotel developers and investors to make deals happen.

The “Rising Above Rates” bootcamp at Meet the Money took a deep dive into the current interest rate, transaction, and financing environment and the challenges faced by owners, borrowers and lenders. The panel and the session addressed way to capitalize deals and make them happen in a challenging environment including the use of CPACE, debt fund financing, and ground lease structures. A spirited presentation amongst 5 experienced industry professionals surfaced a lot of useful ideas and insights into making deals happen today.

The full presentation can be downloaded here.

MGM-Panel-scaled

Lodging Performance Outlook 2024

Luigi Major, MAI, a Managing Director of HVS Americas, led Tuesday’s special presentations with an update on hotel performance, valuation metrics and construction costs for 2024.

Luigi explained that nationwide hotel RevPAR performance remains relatively steady in 2024. Hotel values decreased 16% from 2021 peak amidst higher cost of debt and lower transaction volume, and construction costs remain elevated resulting in a slowdown in new hotel supply.

The full presentation can be downloaded here. CONTINUE READING →

Published on:

17 May 2024
Click here for the latest articles on Resort Fee Litigation.

Note: If you are a consumer with a Junk Fee issue, please do NOT contact us!  We do not represent consumers against hotels, restaurants, or other business owners. We are part of the fabric of the hospitality industry and are committed to informing, educating, and assisting the industry. We represent business owners, helping them to understand and comply with applicable laws and defending them from consumer charges.

Consumers hate drip pricing and junk fees

Consumers and politicians have complained about drip pricing and junk fees for more than 20 years. There’s a close connection between the two, but they are not exactly the same thing.

  • Junk fees: These are generally any unexpected, often mandatory fees added to the advertised price of a good or service. They can be hidden or poorly explained, making it difficult for consumers to anticipate the true cost. Examples include service fees on concert tickets, credit card processing fees, or resort fees at hotels.
  • Drip pricing: This is a specific tactic used to introduce junk fees. It involves advertising a lower headline price initially and then revealing additional mandatory fees later in the purchasing process, often in small print or during checkout. This creates a misleading impression of the actual cost and makes it harder for consumers to compare prices accurately.

So, all drip pricing involves junk fees, but not all junk fees involve drip pricing. For instance, a credit card with an “electronic service fee” added – even if clearly advertised — would not be considered drip pricing, even though it is a type of a junk fee.

Here’s an analogy: Drip pricing is like revealing all the ingredients in a recipe one by one, after having already taken a bite. Junk fees are like the unexpected or ill-defined ingredients that might not have been listed at all.

The first reports of  hotels charging resort fees (or similar charges) can be traced back to the year 2000. We are not sure if hotels invented the practice or were just amongst the early innovators. But in any event, the various mandatory fees with various labels soon became widespread throughout the hospitality industry and other industries including hotels, restaurants, food delivery services, live-event ticket sales, transportation such as car rentals and airlines, and many others.

FTC concern about drip pricing, junk fees, and deceptive practices

On November 9, 2023, the Federal Trade Commission (FTC) issued notice of a proposed rule on “Unfair or Deceptive Fees.” This development is discussed in the Blog below by my partner, Mark S. Adams.

FTC Cracks Down on Hidden Fees:
Upfront Pricing Is Coming

by

Mark S. Adams
Hotel Dispute Lawyer, Partner & Senior Member
JMBM’s Global Hospitality Group

Federal Trade Commission (FTC) is proposing a new weapon in the fight against hidden fees, surprise charges that inflate the cost of everything from hotel rooms and restaurant charges to concert tickets and college tuition. This proposed rule addresses prevalent fee practices that are unlawful under Section 5 of the FTC Act, 15 U.S.C. 45, and declares them to be unfair or deceptive to consumers. This “junk fee” crackdown would impact a wide range of industries, aiming to bring transparency to how businesses disclose their true costs.  Generally, the proposed rule makes two changes: Upfront Pricing and Deceptive Fees. CONTINUE READING →

Published on:

13 May 2024

See how JMBM’s Global Hospitality Group® can help you.

In the article below, Partner Michael H. Strub, Jr., analyzes the complexities surrounding non-compete agreements and the FTC’s recent decision to ban them. With the enforceability of the FTC’s rule facing legal scrutiny, he discusses the likelihood of a cohesive federal approach and its implications for employers nationwide.

Navigating Non-Competes

by

Michael H. Strub, Jr., JMBM’s Litigation Group

The Federal Trade Commission’s rule that would ban non-competition faced legal challenges from the day it was issued. What are the obstacles the rule faces, and what is the likelihood that some form of federal rule will be created?

Before analyzing these questions, it should be noted that state laws on the enforceability of non-competes are, literally, all over the map. In his article, Fifty Ways to Leave Your Employer: Relative Enforcement of Covenants Not to Compete, 13 U. Pa. J. Bus. L., 751, 786 (2011), Norman Bishara ranked the states from 1 to 50 based on their willingness to enforce non-competes and had a separate ranking for each one. Based on his analysis, Florida is the state that has been the friendliest for enforcement, while California is the most hostile.

As Robert McAvoy notes in his article, How Can Federal Actors Compete on Noncompetes?, 126 Dick. L. Rev. 651 (2022), this panoply of laws is complicated by the employer’s efforts to use choice of law provisions to select the law of a friendly state even if the employee is employed in a state where non-competition clauses are invalid. In Stone Surgical, LLC v. Stryker Corp., 858 F.3d 383, 391 (6th Cir. 2017), for example, the court enforced a non-competition clause under Michigan law against a terminated employee even though the employee worked exclusively in Louisiana, whose law would have prohibited the agreement. CONTINUE READING →

Published on:

10 May 2024
Click here for the latest articles on Resort Fee Litigation.

Note: If you are a consumer with a Junk Fee issue, please do NOT contact us! We do not represent consumers against hotels, restaurants, or other business owners. We are part of the fabric of the hospitality industry and are committed to informing, educating, and assisting the industry. We represent business owners, helping them to understand and comply with applicable laws and defending them from consumer charges.

Consumers and politicians have complained about junk fees for more than 20 years. The first reports of hotels charging resort fees (or similar charges) can be traced back to the year 2000. We are not sure if hotels invented the practice or were just amongst the early innovators. But in any event, the various mandatory fees with various labels soon became widespread throughout the hospitality industry and other industries, including hotels, restaurants, food delivery services, live-event ticket sales, transportation such as car rentals and airlines, and many others.

In the hotel industry, these hidden fees have different names, such as resort fees, destination fees, or surcharges. Other industries have used labels such as service fees, delivery fees, installation fees, and administrative fees, just to name a few. But they are all “junk fees”—mandatory hidden fees that are not fully disclosed at initial customer contact but only revealed later in the sales process.

As of July 1, 2024, California will implement a high-profile law to ban such junk fees unless they are specifically exempted. Here are the details.

Junk Fees are banned in California as of July 1, 2024!
What does the California Junk Fee Law (SB 478) mean?

by

Mark S. Adams
Hotel Dispute Lawyer, Partner & Senior Member
JMBM’s Global Hospitality Group

California businesses brace for Senate Bill 478‘s impact. SB 478 was signed by Governor Newsom in October 2023 and became effective July 1, 2024. It cracks down on hidden fees, often referred to as “junk fees” and “drip pricing” (because the full cost is only disclosed drip by drip). It will likely change how businesses approach pricing strategies. Many say it is part of a nationwide response to President Joe Biden’s call to eliminate Junk Fees.

What’s in a name? SB 478 or California Junk Fee Law?

The confusion starts with how to reference the new law. Many refer to it by the Senate Bill number assigned when it was first introduced in the California Senate, and the SB 478 moniker continues to be popular with many, even after signed into law.

We also like to call it the California Junk Fee Law because SB 478 does not describe the focus of the legislation. It is really a collection of amendments to the various sections of the California Civil Code, Government Code, and Vehicle Code, as described in more detail below.

Many consumer groups and plaintiffs’ lawyers seem to refer to it as amendments to the California Consumers Legal Remedies Act, or the CRLA. Their focus is on enforcing the law and the remedies given to the government and consumers to bring private legal actions.

Still, others refer to it by the underlying prohibited practices, calling it the California law on drip pricing, hidden fees, bait-and-switch, unfair competition, unfair business practices, consumer fraud, and the like. These advocates generally include California plaintiffs’ lawyers and state and local prosecutors who largely rely on the California Unfair Competition Law (UCL) and the Consumers Legal Remedies Act (CELA) The new California Junk Fee Law is expected to facilitate new claims against businesses under these laws.

We may use all these terms interchangeably, but we tend to prefer the California Junk Fee Law. CONTINUE READING →

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