Updated State Regulations: Who requires what

CALIFORNIA
Registration or licensing:yes
Registration or licenses for individuals:no
Fees paid to state:yes
Bonding:as one alternative to trust account
Trust account:yes
Restitution fund:yes
Errors and omissions insurance:no
Extends to out-of-state sellers:yes
References independent contractors:yes
Cancellation/refund rights:yes
Disclosure regulations:yes
Rules for display of registration number:yes
Other advertising regulations:no
Numbers registered:more than 6,000; about 4,000 confirmed as California-based
Other:restitution fund; references travel certificates

California requires all the state's sellers of travel, whether wholesale or retail, to maintain a trust account if the travel they sell involves air- or sea-only or includes that transportation with other travel components. It does not cover sellers of land programs only. Agencies can substitute a bond for the trust account, in an amount equal to what would be held in the trust account.

The state targets out-of-staters, too, if they advertise and sell in the state; Web sites are viewed like national advertising, and agencies can avoid a registration requirement by declining to accept business from Californians.

Registered out-of-staters are required to maintain a trust account, too, for funds collected from California clients, but they are not contributors to a restitution fund supported by in-state agencies for purposes of reimbursing California consumers due to "bankruptcy, insolvency, cessation of operations or material failure" of an in-state properly registered travel seller to provide travel services as purchased. Fund must be maintained at a minimum of $1.6 million (and currently has $2.9 million).

Independent contractors do not have to register if they sell under contract exclusively for one or more registered sellers and do not handle client money or receive service fees from consumers.

Another batch of rules require registered agencies to disclose the following in writing: total trip cost, payment schedule, names of suppliers, departure details, all terms and conditions including cancellation conditions, the client's refund rights, plus a statement about the agency's trust account, its contributions to the restitution fund and/or any alternative provisions it makes to protect client funds and details of clients' right to make claims on these. And in circumstances when a client cannot make a claim on the fund, agencies must disclose that orally and in writing.

Agencies are required to display the registration certificates where they are easily accessible to the public, at each location, and to display the registration numbers "conspicuously" on all advertising and promotional materials delivered in any manner, which covers the Web.

FLORIDA
Registration or licensing:yes, with exceptions for certain ARC agencies
Registration or licenses for individuals:no, but a list of all employees and contractors is required
Fees paid to state:yes
Bonding:yes, with exceptions for most ARC agencies and others
Trust account:no
Restitution fund:no
Errors and omissions insurance:no
Extends to out-of-state sellers:yes
References independent contractors:yes
Cancellation/refund rights:yes, with regard to travel certificates
Disclosure regulations:yes, with regard to travel certificates
Rules for display of registration number:yes
Other advertising regulations:yes, with regard to travel certificates
Numbers registered:5,076 total; includes 3,002 independents, 285 from out of state, 30 exempted from bond
Other:references travel clubs

Florida requires sellers of travel to register and obtain a bond of up to $25,000 (or up to $50,000 if selling travel certificates) or provide alternative surety. ARC agencies are exempt from registering and bonding if they have had the same owners for three years (or five years if selling travel certificates). In addition, the state can, and does, waive the bond rule for any seller with five years or more as a seller of travel in Florida in good standing. Common carriers and accommodations providers are exempted.

When registering, agencies must provide a list of all authorized independent agents, who are defined in the law as persons who have written contracts with a host that is in compliance, do not receive fees from purchasers and do not have blank stock or documents or ability to issue documents. These independent agents also must file an affidavit each year listing the sellers he or she represents.

The state expects firms to register whether selling wholesale or retail, "directly or indirectly." and out-of-staters if they are selling to Floridians.

Proof of registration must be prominently displayed at primary place of business, and the registration number must appear on each contract of sale and on each advertisement.

HAWAII
Registration or licensing:yes
Registration or licenses for individuals:no
Fees paid to state:yes
Bonding:yes, for charter tour operators
Trust account:yes
Restitution fund:no
Errors and omissions insurance:no
Extends to out-of-state sellers:no
References independent contractors:no
Cancellation/refund rights:yes
Disclosure regulations:yes
Rules for display of registration number:no
Other advertising regulations:no
Numbers registered:1,584 agency sites; 2 charter tour operators
Other:regulates charter tour operators

Travel agencies must register and maintain trust accounts; charter tour operators also have to maintain bonds.

Hawaii also states agencies must provide written disclosure regarding trips as follows: prices and payment-due dates, trip details, names of suppliers, cancellation and other terms, details on the agency's trust account and information on consumer rights outlined in the law. Supplemental regulations say the agencies must get approval for their consumers rights disclosure form.

If some travel services were not provided, the consumer has the right to a refund within 14 days of request, minus cancellation fees and amounts held by suppliers.

ILLINOIS
Registration or licensing:no
Registration or licenses for individuals:no
Fees paid to state:no
Bonding:alternative to trust account
Trust account:yes, with exceptions, including ARC approval
Restitution fund:no
Errors and omissions insurance:alternative to trust account
References independent contractors:no
Cancellation/refund rights:yes
Disclosure regulations:yes
Rules for display of registration number:not applicable
Numbers registered:not applicable
Other advertising regulations:yes

Illinois imposes rules on so-called travel promoters, defined as companies that do not have ARC approval or do not have $1 million in errors and omission insurance plus a $100,000 bond. The travel promoters protect client funds with a trust account.

However, no travel seller in the state is required to register.

The law also imposes on promoters a series of disclosure requirements including the following: pricing, name of supplier of transportation and other specifics, cancellation terms, location "and number" of the trust account and details of the clients' right to a refund if transportation is canceled through no fault of the customer.

The promoter cannot advertise air or sea transportation unless it has contracted for that transportation.

IOWA
Registration or licensing:yes
Registration or licenses for individuals:no, but list of all employees is required
Fees paid to state:yes
Bonding:yes, with an ARC exemption
Trust account:no
Restitution fund:no
Errors and omissions insurance:as one alternative to bonding
Extends to out-of-state sellers:yes
References independent contractors:no
Cancellation/refund rights:no
Disclosure regulations:no
Rules for display of registration number:no
Other advertising regulations:no
Numbers registered:130 ARC agencies, 226 non-ARC, including 88 from out of state
Other:references telemarketing

All travel agencies must register, but non-ARC outlets have to post a $10,000 or provide an alternative surety. Iowa also presses for registration by out-of-state firms that "do business" with travelers in Iowa. Independent contractors are not mentioned, but each agency is required to list all employees.

The law permits e-mail and other unsolicited promotions (via phone or mail) if directed to individuals to whom the agency has previously sold travel.

MASSACHUSETTS
Registration or licensing:no
Registration or licenses for individuals:no
Fees paid to state:no
Bonding:no
Trust account:no
Restitution fund:no
Errors and omissions insurance:no
Extends to out-of-state sellers:no
References independent contractors:no
Cancellation/refund rights:yes
Disclosure regulations:yes
Advertising regulations:no
Rules for display of registration number:not applicable
Other advertising regulations:no
Numbers registered:not applicable
Other:references travel certificates, travel clubs

The Massachusetts seller of travel law is largely a disclosure law. Affected sellers include travel agents, tour operators, "ocean cruise companies," charter companies, sellers of travel certificates and travel club operators, but the rules do not pertain to services provided to business travelers.

The seller must disclose -- usually orally and in writing -- details on each supplier, price, payment-due dates, trip details. terms of any substitution policy, terms of any cancellation or refund policy and terms of any cancellation insurance, including its limitations.

Further, the agent is expected to disclose facts that might influence a consumer not to enter into a transaction; once a sale has occurred, the retailer must advise when and how each payment will be made to suppliers and provide a written confirmation within five days after each payment was made, plus provide written confirmation within two days after any reservation has been made for a customer.

If the agency violates the rules, the client can cancel and must receive a refund in 30 days.

A number of additional rules dictate timing for document delivery.

Also, if a seller acting as a tour operator fails to provide what is promised, it must give the customer the option of a refund or substitute services, and refund the difference if the new service is of lower standard.

NEVADA
Registration or licensing:yes
Registration or licenses for individuals:no
Fees paid to state:yes
Bonding:no
Trust account:yes
Restitution fund:yes
Errors and omissions insurance:no
Extends to out-of-state sellers:the probable intent
References independent contractors:yes
Cancellation/refund rights:no
Disclosure regulations:yes
Rules for display of registration number:yes
Other advertising regulations:no
Numbers registered:Total: 246 agencies, including 30 non-ARC, 40 from out of state; 547 individual salaried and outside agents
Other:references travel certificates and travel clubs

Effective Oct. 1, 2003, Nevada requires all agencies to register, to maintain trust accounts and to support a consumer recover fund. Tour operators and tour brokers have to register, as well, but not contribute to the recovery fund.

Individual agency staff and their comissioned contractors do not have to register with the state, but this exemption applies only if trip payments are made directly to the registered agency and the staffer or contractor is paid only by the registered firm.

Registered agencies have to display at the place of business and at Web sites a statement spelling out customer rights to recover from the fund, and registered sellers have to include their registration numbers in advertising.

Regulations remain to be written.

OHIO (repealed 2003)
Registration or licensing:yes
Registration or licenses for individuals:no
Fees paid to state:yes
Bonding:yes, with exceptions including ARC or Iatan approval
Trust account:no
Restitution fund:no
Errors and omissions insurance:no
Extends to out-of-state sellers:no
References independent contractors:no
Cancellation/refund rights:no
Disclosure regulations:no
Rules for display of registration number:yes
Other advertising regulations:no
Numbers registered:555 travel agencies, 214 tour promoters

Ohio requires registratin of travel agencies and tour promoters (meaning sellers without ARC or Iatan approval)to maintain a $50,000 bond. The bond amount is $20,000 for those selling only intrastate travel.

Registered firms must use registration number and the words "registered Ohio travel agency" or "registered Ohio tour promoter" in all advertising in the state.

RHODE ISLAND
Registration or licensing:yes
Registration or licenses for individuals:yes
Fees paid to state:yes
Bonding:yes
Trust account:no
Restitution fund:no
Errors and omissions insurance:no
Extends to out-of-state sellers:no
References independent contractors:no
Cancellation/refund rights:yes
Disclosure regulations:yes
Rules for display of licensing number:yes
Other advertising regulations:yes
Numbers licensed:about 80, plus more than 700 managers and counselors
Other:requires exams for managers and staff

Targeting in-state agencies specifically, Rhode Island requires all agencies to obtain licenses and post $10,000 bonds. It also licenses and tests agency managers and counselors. In addition, agencies must file lists of all their employees.

The state, in the law and supplemental regulations, requires that agents disclose a range of things including the following: pricing details, name of carrier and transportation specifics, conditions of sale including cancellation terms and all parties' rights and obligations depending on the reason for cancellation. Also, agents are required to advise of changes to any travel paid for and specifically instructed to advise of changes in accommodations and to refund an appropriate difference if the quality is lower than what was purchased.

If the agency breaches its "duty of care," it must refund the client's payments within 45 days.

Agencies and agents must post their licenses "conspicuously" in the place of business, and the agency's number must appear in all advertising.

The regulations also say ads must show prices for promoted products and tell which components are included in stated prices. Other ad rules are: Indicate with a promoted air fare is only one-way, and advise what kind of role any tour guide will play.

WASHINGTON
Registration or licensing:yes
Registration or licenses for individuals:no, but a list of all employees and contractors is required
Fees paid to state:yes
Bonding:alternative to trust account
Trust account:yes, with exceptions including USTOA or NTA membership
Restitution fund:no
Errors and omissions insurance:no
Extends to out-of-state sellers:yes
References independent contractors:yes
Cancellation/refund rights:yes
Disclosure regulations:yes
Rules for display of registration number:yes
Other advertising regulations:yes
Numbers registered:945 including 91 from out of state; 96 pending
Other:references travel certificates and travel clubs

Travel agencies are required to register and maintain trust accounts or provide an alternative surety which could be a bond of $10,000 to $50,000 depending on volume. Staff don't have to register, but agencies are required to provide lists of all employees and any outside agents selling on their behalf. The trust account rule does not apply to ARC funds, and other funds can be exempt if agency officials swear they never hold client money more than five days.

Independent agents don't have to register if they sell in the name of a host and all money is processed by the host.

Washington solicits registrations from out-of-staters that do business with residents, but advertising in national media or in electronic media does not constitute transacting business; selling only wholesale also does not count as doing business in the state.

Agencies are required to disclose, in eight-point boldface type, such things as: amount paid and payment-due dates, name of suppliers, all known trip details (with full details to be provided with final documents), advisory on penalties for canceling and registration number of the seller.

The law provides a schedule for refunding money due the client after a cancellation by any party, allowing for cancellation penalties and recovering funds from suppliers.

The registration numbers must be posted "conspicuously" in the place of business and must appear in advertising that includes products with prices or dates.

Also, agencies are forbidden to advertise products unless they know they are available when the ad was placed. And, the seller of travel is expected to "keep written or printed documentation of the steps taken to verify that the advertised offer was available at the time the advertising was placed" and to keep those records for a year.

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