Just Economy Conference – May 14, 2021
Households and communities with low incomes, and particularly communities of color, have long been targets of unfair, deceptive and predatory business practices. Largely unregulated products and services such as debt collection, paid tax preparation and alternative lending are pervasive – regularly resulting in cycles of increasing debt and greater financial instability around the country. Similarly, local services like towing and booting, employment agencies and home contractors operating with limited oversight frequently take advantage of vulnerable consumers, many of whom do not have access to any sort of recourse. While there are active consumer protection efforts at the federal- and state-levels, they tend to focus on pursuing high-impact prosecutions and rarely address individual or more local concerns. However, local governments have an original mandate to promote public welfare and have inherent police power to protect residents. With inspiration from the work of New York City’s Department of Consumer Affairs, the Cities for Financial Empowerment (CFE) Fund has partnered with nine local governments and their community stakeholders over the past three years to identify and begin implementing infrastructure that addresses key local consumer protection concerns.
This session will demonstrate the significant role that municipal and county governments can play in directly addressing predatory business practices and provide a pathway to justice for consumers through complaint mediation, regulation and enforcement authority. It will also highlight the critical importance and process of engaging local community stakeholders in the process of defining and implementing an effective strategy.
Speakers:
- Kant Desai, principal of CFE Fund
- Karen Meyers, CFPI Director, City of Albuquerque
- Jay Salas, OFEP Director, City of Denver
- Muneer Karcher-Ramos, OFE Director, City of St. Paul
Transcript
NCRC video transcripts are produced by a third-party transcription service and may contain errors. They are lightly edited for style and clarity.
Desai, 00:02
Welcome everybody to the local consumer financial protection panel, we’re very excited to have you. And I also want to thank NCRC for having us and giving us this opportunity to share about this work and then also to the entire planning team to help put this together in Aaron, our digital lead. So just a quick overview of the agenda for the panel, I’m going to start by talking through kind of the consumer financial or consumer financial protection initiative. And just give an overview of what we have been working on. And then we’re gonna jump right in and meet, meet our panelists, our great panelists today, and then talk, do a discussion about what the work they’ve been working on, and in particular, how they’ve been working with community on the ground. And then we’ll end with some q&a. So let’s jump right in. So I want to start by just talking about why why local, local consumer protection matters to us and why we’ve been engaging in this work. And it starts with, you know, we’ve seen we’ve all seen low income, households and communities of color have really been targets of fraudulent and predatory financial products and services. We can name all of them. And so we feel like it’s an important thing that we pay attention to. The second big reason is local governments. You know, we all know local governments have a mandate to provide services at scale to protect and enhance the lives of our residents that were you know, that we’re responsible for and Along with that, we we find that helping residents predict their hard earned assets is the flip side of all the work that we’re doing on in terms of positive financial impairment, programming, helping people build assets, is important. So it’s also important to protect help people protect their assets safer. And, and then the bit, the other two are really important. Because local governments have a unique role that they can play as a policy implementer and a regulator that, you know, no, not necessarily nonprofit can play. And so we really think that that’s important for local governments to be able to utilize those powers that if they have them. And lastly, at a high level, we think this is a real great opportunity to increase access to justice for for low income and, and marginalized communities. You know, these communities don’t have the necessarily the benefit of a lawyer, they can just call to help them deal with an issue. And so if there’s an opportunity for local government to play a role there, we think that’s super important. And you’ll see that some of our city partners have really stepped up to, to, to work on that so quickly about local consumer protection in terms of function. Our goal is to help cities build consumer protection capabilities and infrastructure, and that that includes just the ability to identify problem industries and businesses, the ability to empower to regulate business activity, to promulgate legislation when they identify an issue that’s Of particular importance, and then also the ability to enforce and inspect and enforced regulations that have been passed. And then finally, the due process side of settling and adjudicating violations if they’re assessed. And then lastly, local, local governments have a real power to engage in large scale outreach and communication to really make people aware of issues that are happening across their their city or county. And so these are, these are the capabilities that we’re working with all of our city partners to focus on. So we started this work in 2017 within it, with an initial cohort of four cities Denver, Salt Lake City, Austin, Austin, and Nashville. And then then, soon after, we also added Albuquerque, which I forgot to put in here for some reason. And then last year, we added a new cohort of cities Detroit, St. Paul, Philadelphia’s Chattanooga, and Shelby County, who began the planning process to really look at how we can build these capabilities in their locations. And excitingly, we just learned that in May, we will be launching a new cohort, we’ll be putting out an RFP for for cities and counties who are interested in this work. So if you are all interested in this work, please reach out to me because we will be having a new grant planning grant opportunity to work on this work. And at the end, this is the kind of stuff that we want headlines of local governments making a difference in their communities, where they’re working on legislation around like things like debt collection and other strategies that can make a difference in your residents lives and really using the local powers that that local governments can have like to affect payday lenders and deal with price gouging and debt collectors and things like that. And so this is the the external goals that we have is for people to see that difference can be made by local government. And so with that, I want to now move into introducing our three great panelists. From the city of Albuquerque, we have the Consumer Financial Protection initiative director, Karen Meyers. And from Denver, we have the Office of their Office of Financial Empowerment and protection director Jay Salas. And lastly, the Office of Financial Empowerment, Director of city St. Paul Muneer Karcher- Ramos. And so I’m just going to stop my screen share. And I’m going to start by wanting to ask each of you to just really briefly introduce yourself and your departments and sort of at a very high level what you do, what you guys do, and a little bit about why you got into it why you were excited about consumer protection. So I will start with Karen.
Meyers, 6:57
Well, hello, I don’t know if it’s morning or afternoon when this is going to be shown. So, um, I am the head of the Albuquerque consumer financial protection initiative. I have a long history of working in consumer financial protection at the attorney general’s office and also at the federal level at the CFPB. And when the city of Albuquerque decided to work with CFE on setting up a municipal based initiative, I was very interested in participating, because I think it’s really important to bring those issues to the local community level. And that’s why I ended up getting involved. And we’ve been for two years, and I, the focus has been setting up the office and moving forward and creating initiatives and developing strategies, which we’ll probably talk about. And the result has been some very positive work, some good feedback from the community, and also the establishment of an office that’s now going to transition from grant funded to city funded.
Desai, 8:12
Great. Thank you, Jay. How are you going next?
Sallas, 8:17
Okay, good day, my name is Jay Salas. I’m the Director of the Office of Financial Empowerment and protection city and county of Denver. And so we got into this work back in 2013. When we we received a grant from Bloomberg and cities for financial empowerment to launch the Financial Empowerment Center program. Fast forward to 2000, December of 2015, we actually pulled together the, the mayor announced the creation of the Office of Financial Empowerment. And so we started the work of not only the the Senator from the Financial Empowerment centers, but we also took on our bank on Denver program, and, and a couple other programs within the city. And then during that time, while we were working with the Financial Empowerment centers, and with bank on, we saw that we were getting a lot of calls, even outside of just our coaching clients, our financial coaching clients around consumer protections, fraud, scams, things like that, that were impacting our residents, they would call us and say, Hey, you know, I was frauded out of money, or I didn’t get paid my wages, or it was a, you know, elder financial abuse, which impacted their lives. And oftentimes, we would have to try to figure out ways to subsidize, you know, like their, you know, their rent or their mortgage payments, so that we it didn’t become a bigger problem, and they would become homeless. And so a few years back, we had an interesting conversation with Jonathan Manson. They had announced that they were going to do consumer financial protection, in in launch an opportunity to apply for a grant, which was just perfect timing for us. And so that’s when we changed our name to the Office of Financial Empowerment and protection. And so we’ve we’ve been super excited about this work working on the policy level. We’ve also worked on the, of course, the the outreach, developing infrastructure, like Karen had talked about working with all of our enforcement partners, you know, everyone from, you know, the DHS office, our State Attorney General’s office, the Consumer Financial Protection Bureau, Bureau, which were very helpful when we started in even today, and in our auditor’s office and a number of police department, number of other partners. And so our office really is we strive to achieve economic mobility, build generational wealth, and address the financial equity gap for Denver residents and small businesses. And so, you know, even during COVID, it really did shine the spotlight on a lot, a lot of scams that were already out there, and a lot of new ones that popped up. And it really, it really showed this with a lot of us in this this line of work already knew is that there was a huge equity gap. And and we were trying to close this equity gap while there were people out there that were taking people’s money illegally. So this work has been is is very, very important, if not more important today than it even was last year.
Desai, 11:29
Great. Thank you, Jay. And Muneer. Why is why did St. Paul get involved in this?
Karcher-Ramos, 11:35
Yeah, so first, a little bit about the office financial empowerment. And again, moodier director last Friday in department city of St. Paul. So Mayor Carter, mayor’s Mayor St. Paul. He has three pillars of which one is economic justice. And that’s sort of some of the guiding principles, you know, of our work. So really the office Financial Empowerment we’re looking at how do we advance economic democracy that shares prosperity with all St. Paul residents, and what we know is sort of the the financial system and the economy isn’t necessarily working for everyone. And there’s lots of different pieces of that. And for us, we’re really looking at it from, you know, household financial security sort of perspective, and what are the things that we could be doing. And it’s not only about the household financial security, it’s also about sort of the wealth and asset building, believe that needs to happen, as well as preventing, you know, some of the asset stripping, that happens, you know, in our communities. So, some of the things that we do in the Office of Financial Empowerment, we have a college savings account program called college bound St. Paul, we also launched, the first sort of ran within the municipal government guaranteed income program called the people’s prosperity pilot. So it’s an 18 month program, $500 a month for participants enrolled in that program, unconditional cash, you know, use it as you will, and Mayor Carter is a co chair of mirrors for guaranteed income. So real huge advocates, both on that at the local state and national level to advance a guaranteed income. And then other things we work on, are connected to finds a few justice reforms, we work a lot with our police departments, city attorney, a number of other departments working on a debt, the debt based license suspension reforms sort of at the state level right now, as well. And really the reason to sort of on this last point of why local consumer financial protection, we really get into one of our strategies is how do we prevent sort of the stripping, you know, of income assets, you know, from, you know, from our city’s residents, and, like Jay said, you know, like, our cohort of, you know, started, you know, really in COVID. Right, and going into that we sort of saw, you know, price gouging, you know, happening sort of in the early days of COVID. And you’re looking at what, what can we do at a local level to be a part of the response, right? You’re looking at different types of predatory practices, scams, frauds, you know, that sort of thing. And, as we’ll talk about a little bit later, is we really actually began to really focus on immigrant and refugee communities, and the different types of impacts different types of predatory practices and said, Well, what does it look like for us to put in some consumer financial protection, the key point there is financial protection, we do other consumer protection, you know, in our office around, you know, fair housing, you know, rata rights, that sort of thing. But, you know, really looking at, what can we do today, that’s gonna, you know, put our immigrant refugee communities on the best foot forward. And after Chicago, in the Midwest, St. Paul is the most second densely populated, you know, city, you know, with refugees and immigrants. And again, we’ll talk more about that. But there’s no more important time than now to really embark on this work, expand this work and for local municipalities in particular, to take on this work in partnership, obviously, with our regional state and federal partners. Yeah.
Desai, 15:10
Great. No, that’s a great introduction for all of you guys that I’m, you know, what a dive right into kind of the big, the topic that we really wanted to touch on today, which is about engaging with community on the ground, and how each of you approached some of that. So, Jay, I’ll start with you of what was Denver’s approach to kind of connecting with different community groups, or interested stakeholders around Denver.
Salas, 15:42
Yeah, thank you, Kant, this is a that’s a real it’s a really good question. I think it’s one of the most important foundational pieces that we could have done it moving forward. Because I know early on when we had met with with all of you guys at the CFE fund, and there were people from CFPB and just, you know, talking, you know, with other folks across the country that were engaging in this type of work or similar work, you know, we were expected to be hit with a lot of obstacles, roadblocks, even even territorialism if you will among, you know, amongst different, you know, government groups or agencies and things like that. So we thought that this is a really good way to get out there and bring everybody in. And I think, you know, our mantra that I said from day one, when we started engaging in community is that consumer financial protection isn’t my responsibility or the Office of Financial Empowerment, responsibility. It’s all of our responsibility. It is a big network of folks that really needs to work together to have collective impact. Because, you know, oftentimes what we saw as we started engaging, folks, is that there were already instead You know, we’re kind of reinventing the wheel, there were already enforcement agencies doing maybe similar type of work. And if we just if they already had infrastructure built, and if we just expanded their purview, it would allow for us to not have to build that that infrastructure, but really kind of just add, you know, maybe a menu item to what they were already doing and out there. And so, you know, to your question, I think, you know, you would come out here early on when we were when we received our grant from CFE and you were part of one of the the initial working groups, and so we kind of did this big casting call, if you will, and, and you were very helpful with with actually helping us to facilitate that, that work. And so we reached out to, you know, government agencies, both both, you know, at all levels, not just municipal, and nonprofit partners, even just community residents, you know, even folks that were not that are that were just community helpers, that were not formally working in the community, but were those community helpers, and, and, of course, other city agencies. And, and talked about this work and said, Well, you know, what do we what do we want to see? Where do we see those gaps in in right away, people just started talking and, and so what that led to was about a year and a half long, working groups. And so I think initially, when we had asked, What are those topics that are most important to the residents, and most important to? What are we seeing where are there gaps? And where are we seeing all of the, you know, the predatory and the scams and things like that. And I think we had a list of well over 30 different topics. And so, you know, we there’s no way we could address all of those at one point in one at one time. So we, we started forming these working groups to then pare it down. And so we came up with about six topics that we said, we’re going to start with these six topics, and probably then prioritize them. And so, you know, through that, about year and a half, long working group, we broke out into separate working groups to work on each one of those topics. And sometimes there were regulators or enforcement folks that kind of had purview in a few of those, those those different topic areas. And then there were also, you know, so there were some people that were in multiple working groups, and then there were others that were unique to that specific topic. And so then we started pulling together, you know, our, you know, the work and making sure that we also heard from residents, oftentimes, in those working groups, we would bring in folks that were victims, or, you know, had fallen prey to to predatory practices. And we would hear firsthand from them what their experiences were, and what an oftentimes it was, you know, we asked, Well, what recourse Did you have, and oftentimes, there was nothing. So it really helped to inform one what it is that that the residents needed and what other folks were, we could fill these gaps. And then two, it really brought us together to work as a as a collective, you know, state in, you know, one of the things I think that even spawned off of that is, is that, you know, there’s a Senate bill right now in the state of Colorado to replicate what the city of Denver’s done our office to create an Office of Financial Empowerment protection statewide at the state level. And so I think that, you know, it really helped to weave into the fabric of what we do, not only as a city, but as a state around financial empowerment and consumer financial protection, which is super, super helpful, because now we we have, you know, everyone working together, there’s no territorialism both at the city, the state, you know, county levels, and people actually call us to say, Can we jump in and be a part of this work from from not only around our state, but even across the country? So it was really helpful for us to do that outreach and continue to do that outreach.
Desai, 20:44
Right, yeah Karen, when we when we came to visit, you’re in the midst of doing your community engagement strategy. And I really liked you too. Could you share a little bit about the approach that you took in terms of how you engaged the community about what this was and what you were trying to what we were trying to accomplish?
Meyers, 21:05
Well, we followed a similar model to Denver, but ours was much more streamlined. And part of that is we had fewer resources. Albuquerque is a smaller city. We had a halftime person that’s me working on this, we didn’t have other staff to necessarily jump in and be participating in this. So when we started, we were very cognizant of resource allocations and what we could do, we didn’t want to promise more than we could deliver. Because we wanted to create an establish a trusting relationship with the community. So we started by having a series of roundtables to talk about and hear from was really a listening session, I guess, to hear from the community about what were the most prevalent problems. And we know that there’s probably 12 or 13 different markets that you could talk about when you talk about consumer financial protection and even broader when you think about consumer protection generally. And we identified what all those markets were. And then we asked for people to tell us what they knew about what was the biggest and most egregious problems in our community. And from that, we also then met with city stakeholders to find out what services were being provided and where they thought the gaps were. We also met with consumer advocates and lawyers who represent consumers to determine what they saw. And we put that all together into sort of a master analysis. And then for each one we looked at, we did you know, sort of which ones were most important for each of those groups. So we had a sort of a list of, you know, in order of most problematic to least problematic, perhaps, or most repeated or evident. And from that, we then had to ask the question, well, what strategies apply? So for example, one of the issues that a lot of people raised was I class lending, you know, predatory lending? Well, under our state law, the the state law prohibits the city or the municipality from doing anything related to the conditions or terms of those, those contracts, including interest rates. So we determined that that was not something that the city could take on at this point. And we went through each of the categories and asked that question, what resources would it take? What is what are the strategies that are available and the strategies we considered are the ones that you put up con around whether there’s regulatory approaches, whether it’s an outreach and education issue, and as a result of that, we started to hone in on some critical issues and topics and started to create projects. In essence, for each one, what we were going to do about tax services and tax preparers who are taking advantage of consumers on our community. What are we going to do about solar marketing problems with our community, which is a big problem? What are we going to do about scams, and for each of those, we developed a plan for how we were going to address it. And then we started implementing it, one of the two key guiding notions that I followed what that was that we needed to also bring a lens about consumer protection to the city. So that there were so many things that the city does, and so many services, but they don’t, they don’t have the background around consumer financial protection. And so they don’t link it to that. So when seniors are receiving services at a senior center, and this is pre COVID, obviously, or had home in home health care providers going to help them or had meal delivery, the people who are doing that are providing a critical service, but they don’t they’re not trained to say, oh, why did you get that phone call from the guy who’s asking you to give them money? You know, they’re not trained to know what to do in response. And so we started to build a relationship across the city, to train other service providers in the city, to be aware of consumer financial protection issues so that they then became a resource. And that, as a result has changed the notion of how the city provides services in a very significant way. Because now they actually call me and say, Well, isn’t it something that maybe we should be working with you about? Because it looks like it’s linked to consumer financial protection? And so we’ve done that. And we’ve also looked at what I call pathways, which is where are people getting services? Because that’s where we want to, as you talk in bank on issues, integrate the notion of consumer financial protection into those existing services like seniors or community health clinics, or wherever people are going that that’s their trusted relationship? How do we integrate that with a message services, information, whatever with consumer financial protection, and so that’s what we’ve been doing.
Desai, 26:35
Great, Karen, and to your point, and I want to ask Muneer about this, the importance of the voice of, you know, residents and communities into shaping what happens in in the government and then having the government understand or local government services, understand All the various factors and where that are playing in, you know, with however, they’re reaching people, and then knowing that, you know, there, they were there, I’m just going there for meal delivery service, I might see something else and to the fact that I might, if I see something else I know now I now know where to go, that I can say, oh, by the way, this is also happening. And that you can help people in multiple, multiple ways. And so when we, when I, when we came out to St. Paul, and this is before he started, when you’re, you know, we started to see some of that, just like the vision of how Mayor Carter wanted the local government to intersect with the community and have it really be sort of a more seen, I guess, seamless relationship and sunset. So I would love to hear a little bit more about how that that sort of relationship, kind of define what you guys are doing in the consumer protection work.
Karcher-Ramos, 27:51
Yeah, and before I get there, maybe I’ll sort of take it in two parts. One, how do we get to focus on and we’re getting refugees, and then what it actually look to connect with those organizations and sort of folks within the community. So first, how did we get there was, we were giving, you know, our Department of Commerce, which does a lot of the consumer protection work, the attorney general’s office, we talked with FTC. Um, you know, some nonprofits like the Better Business Bureau, AARP, you know, and just ask kind of two questions. One is, you know, which populations, aren’t you reaching that you wish you were, and then to, um, what do you see as a unique role that a local municipality, like a city could play in consumer financial protection, and every group we actually talked to kept saying, we have really, really hard time reaching, you know, immigrants and refugees. And we don’t see a lot of reports coming from there, we hear occasionally about some frauds and scams that, you know, are happening, but you know, us, you know, the state and federal level, in particular, we aren’t at the street level, that really understand or have the different types of relationships that, you know, cities could play. So, after sort of doing that first round of conversations with some nonprofits in the space and government agencies, you know, we just said, Alright, let’s begin to focus actually, on the population. Right. So that’s when we began then to reach out to community based organizations, Somali organization, Latino organizations, Korean, Cambodian, mon organizations, and we have a lot of different immigrant refugee groups, you know, in in St. Paul. And, at the time, frankly, you know, what we had heard, I know, I’ve shared this with UConn. And john over time was, there’s a big actual year that, particularly under the Trump administration, with public charge, and with, you know, deportations, and no, all that was, there was a fear to actually begin to build some sort of government apparatus, even at the local level, you know, that could really look at, you know, protecting, you know, immigrants and refugees. So we began to really kind of dig in with the community on, you know, well, what, what does that look like? What could that look like? What should be happening? What shouldn’t be happening? Right? And they’re very intentional about us, like, Alright, well, we trust you at the city level. But, you know, let’s not quite bring in sort of the state and federal partners yet. So that was sort of taking the community’s lead to understand, you know, and that back channeling saying, you know, hey, Attorney General’s office, hey, you know, Department of Congress at the CFPB, like, we’ll come back to you when, you know, we’re sort of clear on what the community know, wants and needs, and, you know, that sort of thing. And we have ideas sort of the right issue that I think a turning point began to happen, you know, with, you know, the Biden administration sort of taking place, hearing more about some immigration reforms, and then folks began to actually see different kinds of scattered scams or fraud, you know, types of messaging coming up saying, you know, decisions have been made. And, you know, like, every time a proposal got kind of put out by either the Biden administration or Congress, you know, we’ll be hearing about all these sorts of promises and comfort filing paperwork, and, you know, that sort of thing, you know, to, you know, file for different immigration statuses bring, you know, families from overseas, and those things aren’t yet in place, right. So it really created a new window for us to engage, you know, really over the past four months, you know, on really looking at your, like notario fraud and material fraud, you know, is within the Latino community, but, you know, it also shows up, you know, in the Hmong community in the Somali community and other communities a very parallel sort of fraudulent immigration types. services. So that’s really where we began to go. And we had circumstance, we had relationship, and us just sort of taking the lead of a community to really understand what’s what’s best. Moving forward.
Desai, 32:06
Great, great. Um, so I want to follow up on the piece. And I think Karen kind of you articulate a little bit about marrying the issue with the, the tool that you have available, and, and then trying to figure out how to put it in practice. So I wonder if each of you can kind of talk a little bit about an example of where you sort of put the pieces together and you develop, you know, what the strategy is that maybe you can start with a little bit about the wage step towards that you guys are sort of focused on, which is not necessarily traditional consumer protection, financial protection issue, but nevertheless, kind of bubbled up a lot in your conversations.
Salas, 32:49
Absolutely. And maybe I’ll kind of talk just overall, how we did it with all of the issues, and then I’ll kind of focus in on on that one. So, as we’re going through that, you know, year to year and a half process, what we did is we took those, you know, six issues that we had, and we broke it out amongst different categories, and we basically color coded them, you know, green, meaning that it was, you know, kind of fully fully baked. Blue means that there was some work that needs to be done. And then yellow was that there really wasn’t a whole lot going on. And that was an area to, to work on. But so we took the issue area, and we looked at political we’ll do we have the political will both at the at the local level, municipal level, state level, that type of thing, then we then we, you know, we would color code that for each issue, and then prevention, education and outreach. So we looked at is there prevention, education outreach being done currently, by you know, nonprofit government, who whomever we so we took that inventory, and we did this with with these working groups? And so we looked at that, and then we said, well, is it being done or, you know, in sometimes it was being done, it’s just that the bandwidth wasn’t broad enough to reach all of our residents, especially when we’re talking about, you know, our office, you know, that bridging that equity gap, there, there, there were, you know, oftentimes outreach, but it wasn’t done in Spanish or, you know, like, now we’re putting together our, our, you know, most of our work in 13 different languages. And just in our office alone, I think we speak six or seven languages, just within our with our staff capacity. And then we looked at policy review and development looking, are there policies in place already legislation, you know, ordinances, things like that, in con, you know, you were very helpful with this, when we looked at even our state you DEP was relatively weak compared to other states across the country. So even at that first initial look at our state, you doubt it was it was very, it was it was weak in many ways. Then we looked at complaint resolution, like what what does that look like? How could we build complaint resolution where their complaint resolution, you know, databases are ways that you know, hotlines and things that were out there to try to get people to resolution? Then we looked at monitoring who was actually monitoring these things, because oftentimes, we would see there’s there there would be an ordinance that was super dusty, and we would blow off the dust, because no one was monitoring, enforcing it. I mean, there was there was great, you know, intent behind it. But without the monitoring enforcement, it was, you know, kind of for nothing. So we looked at who was monitoring who was supposed to be enforcing those things, or who had the purview or could potentially enforce the those, you know, those or new ordinances or legislation or policies that need to be put in place. So enforcement was another one. And then supportive services. I think that’s where we we are, we really pride ourselves in wrapping supportive services around that. And so in the case of wage theft, you know, we started getting a lot of calls on wage stuff. And then when when we started moving into COVID, even more so and they were targeting our, you know, immigrant and refugee populations, predominantly, it was mostly in the construction industry, but we still also saw it in the service industry. And in they were really and it wasn’t just that I hired an employee and I didn’t pay them. It was a very sophisticated scheme where some of these big contractors were, were setting up these LLCs as a bit as as a they knew what the laws were in the end, what they would do is they’d set up these LLC that would go out and hire and in hire folks and even bring people in and it verged on human trafficking, labor trafficking, that was taking place they promised them you know, a place to live just a number of different things and then they would miss classify them as as, as, as a as a contract employee, not not a W two employee because they knew that the law currently read our Our current law says states employed but employed did not encompass folks that were misclassified as a contractor. So then they wouldn’t pay him and they would stringing them along, stringing him along. And if they tried, if many of these folks would try to complain about it, they would, they would be threatened with all call ice on you will turn you in, things like that. And so, you know, wage theft really, really became. And then also with subcontractors there, there, there was also like these big schemes happening with subcontractors where our laws only protected employees didn’t protect like subs. And so, you know, they’re, you know, these large companies would create these middle middle companies these these kind of temporary lol, lol C’s, if you will. And so it you know, it wasn’t traditional wage theft, as we thought because we thought well wage that that would be the CDL er, Colorado Department of Labor, labor and employment. And so we partnered on them, and there was a huge gap. And then also with the attorney general’s office, when we would send folks their way, if it didn’t rise to a certain number of complaints, $1 threshold for the same bad actor, then it would go into this black hole, and they may not hear back from them for, you know, a year or at all, because it just didn’t reach that threshold. So that was an area that really came up quickly for us was waste that because what we saw was that folks were then coming to us to say we need rental assistance, it was really putting pressure on our social services programs that especially when COVID, you know, came around, we were having to do more with less it because everybody was was in line for these these services. And so we’re seeing people are taking stealing from from these residents not paying them and now it’s putting even more pressure. So it really forced our hand to really focus in on on that area. And then you know, when someone calls in a complaint, we were really blessed to have got it like a $600,000 complaint management website or system built for us, free of charge by our IT department, but it wraps supportive services around them. So if they call in, they hadn’t, you know, been paid for a month or two months, or whatever it is, or their company hadn’t been paid, you know, it has an impact, they can’t pay rent. And so we’re able to provide financial navigation to get them to our other services so that we can make sure that they don’t get evicted, that we get rental assistance to them energy assistance, you know, address food insecurity, things like that. So I think that that’s really where we’re really excited and happy about the way that we kind of built our system out and kind of how we looked at those different issues. But but then operationalizing it making sure that we wrapped around those those supportive services. Tell
Desai, 39:46
Tell you what, sorry, I just mentioned briefly, the work you’re doing on the legislative side of that.
Salas, 39:51
Yeah, absolutely. And so when we talk about policy, we’re currently working on a huge gap, we’re in draft number two or three, it’s it’s been, it’s been a heavy lift, because during we started this right before COVID, and then during COVID, you know, we had to, you know, kind of put that on pause a bit, because we were addressing some critical immediate issues and needs. But now we’re back working on the you’d app to really close those gaps, both at the state level, and at this with municipal regulation. And then, you know, also just making sure that, you know, we’re addressing preemption. So that’s the other thing is making sure that everybody’s on the same page. So but yeah, we’re super excited about that, as well. We’re, we have some really good taskforce working on the gap policy and, and some other types of wage theft policies that that are kind of add ons to, to our, to our youth out.
Desai, 40:50
And I’ll just clarify for the audience that for those that don’t know you, DEP is a unfair and deceptive and abusive Trade Practices type law. So it gives the power to local or in this case, local government to sort of address general unfair and deceptive practices activities. And so Karen, do you want to you want to share a little bit about the couple things that you guys have been working on the issues that bubbled up that you then sort of targeted for some strategy?
Meyers, 41:21
Um, well, we’ve worked on a number of issues, but let me give two examples because they, they sort of float out in a very different way. One of the issues that people raised in our initial roundtables was tax preparation services. And in New Mexico, those folks are largely unregulated. So we, we created a working group and got further input input and began and drafted an ordinance that would be primarily a disclosure. ordinance to start with and creating consumer rights. And we ultimately that was presented to our city council and passed and became effective in February of this year. It has some very strong affirmative requirements around fee disclosures, accountability, the information that has to be provided to consumers when they go to a tax preparation service provider. It’s very broad in that it covers both the Enrolled Agents as well as just the sort of tax professionals who provide these services. And we intend over the we understand there will be some pickup time in terms of getting people aware and in compliance. And so we’re planning a an effective way of in increasing its visibility, we sent out a letter to every single Tax Service preparer in the city, advising them of their new obligations, they have to file a compliance by the end of the year, and then we’ll we’ll start the oversight and enforcement process. After we’ve given them some time to come into compliance and understand their obligations. That approach is very different than what we did with evictions, evictions was not housing is on our list of priorities. But evictions in terms of tenant relations was not really considered initially until COVID hit and then we got input from from people in the community that says, Why is mortgages Why are mortgages considered consumer financial protection, but not leases. And in our interpretation had been well, there’s a separate law, etc, etc. And we said, you know, you’re right, we’re wrong, we need to change that. And so we the CFP, IR consumer financial protection initiative, got very involved in issues around eviction prevention, tenant rights rental assistance. And that involvement was very different than the other work we had done. We started participating in coalition with the advocacy groups, the homeless, the coalition to fight to end homelessness, the groups that do eviction prevention issues that are the community basis, we reached down and started participating with our access to depth commission that was also looking at this issue, we worked to create a cross department ongoing collaboration at the city level between our Office of Equity and Inclusion or cspi. And our family and community services that administers the rental assistance we’ve worked to, in collaboration with our mortgage finance authority. With the state based rental assistance, we’ve done a lot of outreach, we’ve done trainings for people who are providing services to families who then find themselves in an eviction situation, we went to our local court to encourage them to create a mediation program at our, at our Munich, our county level, which they did. Unfortunately, it has not been as effective for a lot of different factors, some of which have to do with money. But we saw this, we we took this on as a very broad based emergency issue and tried to look at all the various ways that it impacted on the community, and to become a resource for all those different entities. And it really resulted in a lot of people understanding the link to consumer financial protection that they had not understood before, and why when you’re providing city services for rental assistance, you need to understand what the court system is and how it works. That became evident when we talked to the state based Rental Assistance Program, about how the system how the court system works. And they hadn’t even thought about that in terms of timing in terms of providing information to the courts about pending cases that are waiting to be processed in the rental assistance program, etc. And the interplay between the time that you have to go to the hearing, and the time it takes which is much longer to get rental assistance approved and paid. So all of those pieces, we’ve taken a very visible leadership role on pushing those issues and the relationship between those systems to try and get people to see that and it’s been, you know, it’s been very effective. I think it’s had an impact on A lot of what’s happened in New Mexico and what is happening, we’re still struggling with that, as are most cities and states. And, but we’ve raised the visibility. And the last thing we did was divert work as I served as an expert for state legislation that would have modernized our housing law, which unfortunately failed, but we provided that expertise upon request from the sponsors.
Desai, 47:24
Thank you, Karen. And what I like about what both you and Jay kind of talked about is, it’s really highlights the the role that the city can play in taking a leadership role and translating what residents and committee members are seeing on the ground into some, you know, effective action, you know, obviously, we know how government works, it’s, it’s a, it’s a mix of successes and failures and barriers, and, you know, fits it and things moving in fits and starts, but it’s a, it’s a really great example. And, and many writers, when, lastly, with you, you’re you’re obviously a little bit, you know, you’re only nine months into this. And so, kind of just maybe share a couple of things about things that you’re working on are focused on as you’re moving forward into the future as we wrap up.
Karcher-Ramos, 48:11
So the city, St. Paul, we’re really focused on actually partnering with our immigrant and refugee program, which is housed out of actually our city attorney’s office. So what we’re moving forward with is digital fraud, sort of awareness campaign, around notario frauds around fraudulent sort of immigration services, when there will be a multilingual campaign, Spanish, Hmong, and Somali will be the three languages that we’ll be doing that that campaign in. And we’re actually also partnering with regional partners. So the City of Minneapolis also has a immigrant refugee program, Legal Aid, you know, service providers, that sort of thing. And we know that, you know, the Twin Cities as the Twin Cities, right, the there’s two big cities, you know, sitting at the center, and what happens here, also happens there. And so we need to make sure that really this education and awareness, you know, these happen around what, what is sort of where are the federal policies that particularly and then what would fraudulent? You know, types of immigration services look like? What should be some of the signs? And then where should you actually go, you know, to get connected to, you know, aboveboard immigration, you know, services, and what’s the ramifications, if you don’t? Right, so sort of a broad sort of education, you know, campaign, you know, that’s rolling out here. And then, at the same time, then add moonbot, who’s in our city attorney’s office running that immigration and refugee program knows working on some of the enforcement considerations, you know, what’s the complaint? How do you feel the complaints? And then what does enforcement actually look like? And who are we partnering with, first, what’s just our city attorney’s office doing? So, as you said, we’re, in the early emerging stages of this work, and this is sort of our first project to work on. And, you know, for folks who are interested to get in this space, I think it is about, you know, staging what you want to do, and starting with something concrete, and, you know, really looking at how does that how’s that a building block, you know, not feel like you got to have everything, you know, a big office in place, and all your, you know, enforcement staff and all that, but what can you start with today, use that some proof points and really begin, you know, as a building block for this, because what we know is that our, our communities, you know, need this needs this consumer financial protection, and we to start to build sort of that energy within, you know, our institutions, you know, and build those proof points in partnership, you know, with with community to really make that vision come true.
Desai, 50:52
Yeah, and the other thing I’m excited about St. Paul, is you have a you have a an unfair and deceptive Trade Practices law on the books already that we just need to dust off, which is right.
Karcher-Ramos, 51:03
Jay, Jay, for that on, what’s the best way to desktop? So yeah.
Desai, 51:11
Well, thank you all for
Salas, 51:13
Can I just make a quick comment? I yeah. I know, Karen, you know, had mentioned around their their housing and you know, eviction, you know, the work around foreclosures and evictions. And, and even with, I think your comment around wage theft not being traditionally looked at as consumer financial protection, and I think that that’s an important point is because, you know, I think even through COVID and even really listening to the community and what what’s really happening, it really has maybe expanded what at least the initial definition or what people kind of thought of the what the Consumer Financial Protection look like. So I think it’s super important because I think it’s a testament to the work that we’re doing with the community, and being a being very nimble, even as government to address those issues quickly, because the same thing you know, Ron, who’s our Director of our Consumer Financial Protection Unit, is now you know, overseeing it. He’s coordinating our citywide evictions work as well. And Alvin, in our office also is is coordinating on the foreclosure front. But it really does, it really has taken us into areas that were, I think, traditionally not looked at as consumer financial protection, but were able to step up and address it, because it does have ramifications, as Muneer said, around stripping away, you know, assets or, or even barriers to to wealth generation for our most vulnerable populations.
Desai, 52:39
That’s a great point, Jay. Thank you. And with that, we’ll, we’ll end this great panel discussion, and then we’ll leave time for q&a, which will happen later. Thank you all again for for this.
Desai, 53:07
All right. Welcome back. And let us know if you have questions, follow up questions for our great panelists. See if there’s in the right place. Oh, okay. So far, we, I think apparently you guys did such a great job in your in your panel and explanation that nobody had any had any follow up questions. But hopefully, I do want to reiterate that we have just launched the RFP for a new crop of cities. So if any of your cities who have not gotten involved in consumer protection, but you think really should please go to CFE fund. org, and you’ll see the opportunity to, to join this consumer protection family. And one great thing that I love about this is it’s a growing family and that you can always, we love to connect people, like new grantees, with people like Jay, Muneer, and Karen and other in some of our other places to really learn from each other. Because this is this how we’re going to really build a great movement of local consumer protection to see and our NCRC person, just a Maggie, let us know that there’ll be a recording of this session will be available for you to see in the future. If you want to come back and look at it. Keith asked the question, is that Shelby County, Tennessee? Yes. So Shelby County, Tennessee is part of our group. And we are happy to connect you with Molly, who’s our who’s leading the effort in Shelby County. Any other last minute questions? Okay. Well, I think if that’s it, we can wrap up. Thank you guys again. Thanks. And thanks, again, Karen, linear j for doing this. But looking forward to seeing what more more work that’s happening in each of your cities.
Salas, 56:21
Thank you for all the support and thank you minear and Karen. Thanks.
Desai, 56:30
Take care.
