California Gift Cards After SB 22: Class Action Exposure and Compliance Strategies
Christina Tusan is a nationally recognized trial attorney and the Founding Partner of Tusan Law, P.C., where she has devoted her career to protecting consumers, whistleblowers, and vulnerable communities from fraud, deception, and abuse. With more than 27 years of experience litigating complex consumer protection, privacy, and unfair competition cases, Christina has secured over $1 billion in judgments and settlements on behalf of the public. Before founding Tusan Law, she served in high-level public enforcement roles at the Federal Trade Commission, the California Attorney General's Office, and the Los Angeles City Attorney's Office.
Joan Rossman is an Associate at Bailey Cavalieri LLC in the firm's Columbus, Ohio office. She is a member of the Corporate & Transactional Business Practice Group, the Unclaimed Property Practice Group, and the Representations & Warranties Practice Group.
1.5 hour CLE
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Program Summary
California's SB 22—the 2025 amendments to Civil Code § 1749.5, operative April 1, 2026—has reset nearly two decades of tester-investigator exposure under the state's gift card statute. The cash-back trigger moved from $10 to $15, electronic and app-based gift cards are now within the statute for the first time, and the staff retraining and POS reconfiguration deadlines have already passed. A prior settlement at the old threshold offers no shield against a fresh complaint at the new one. Any retailer issuing or accepting gift cards in California—including multi-state programs—is now operating under a live statute that touches POS configuration, employee training, consumer-facing terms, and the open interaction with FinCEN's 2016 de minimis guidance. The program maps § 1749.5(b)(2) litigation, dual-track government enforcement, repeat litigation against previously settled defendants, and concrete POS, training, and documentation workflows under the amendments. Attendees will be able to audit exposure, remediate gaps, and document a defensible record before the next tester complaint lands.
What Will You Learn
Learn the SB 22 amendments to California Civil Code § 1749.5, the litigation history under § 1749.5(b)(2), and the operational steps retailers must take under the live statute.
What Will You Gain
Gain a concrete compliance roadmap for POS configuration, employee training, defensive documentation, consumer-facing terms, and the interaction between the new $15 threshold and FinCEN's 2016 de minimis guidance.
Key topics to be discussed:
- Statutory framework
Apply California Civil Code § 1749.5 and SB 22 amendments. - Class action exposure
Anticipate litigation under § 1749.5(b)(2) against retailers. - Repeat litigation
Manage exposure even after prior settlements at lower thresholds. - POS audit
Reconfigure POS systems for the new $15 threshold. - Employee training
Retrain staff on cash-back rules before April 1, 2026. - FinCEN guidance
Address SB 22 impact on FinCEN's 2016 de minimis opinion.
This course is co-sponsored with myLawCLE.
Date / Time: June 25, 2026
- 1:00 pm – 2:40 pm Eastern
- 12:00 pm – 1:40 pm Central
- 11:00 am – 12:40 pm Mountain
- 10:00 am – 11:40 am Pacific
Closed-captioning available
Speakers
Christina Tusan, Founding Partner | Tusan Law, PC
Christina Tusan is a nationally recognized trial attorney and the Founding Partner of Tusan Law, P.C., where she has devoted her career to protecting consumers, whistleblowers, and vulnerable communities from fraud, deception, and abuse. With more than 27 years of experience litigating complex consumer protection, privacy, and unfair competition cases, Christina has secured over $1 billion in judgments and settlements on behalf of the public. Before founding Tusan Law, she served in high-level public enforcement roles at the Federal Trade Commission, the California Attorney General’s Office, and the Los Angeles City Attorney’s Office.
- Education & Credentials
Christina earned her J.D. from USC Law School, where she served on the Law Review, and her B.A. in Political Science from Stanford University. She is a Certified Information Privacy Professional (CIPP/US) and is admitted to the State Bar of California, the Washington State Bar, the U.S. Court of Appeals for the Ninth Circuit, and the U.S. District Courts for all four districts of California.
- Recognition & Leadership
Christina has received the FTC’s Janet D. Steiger Award, the California Attorney General’s Award for Excellence, the California Lawyers’ Association’s Consumer and Unfair Competition Law Award (2024), the National Health Care Anti-Fraud Association SIRIS Award (2023), and recognition for securing one of the Top 10 Bench Verdicts in California (2023).
- Professional Involvement
Christina serves on the California Lawyers Antitrust and Unfair Competition Executive Committee. She authored “New Programs and Rulings May Impact Whistleblowers’ Willingness and Ability to Stop Fraudulent Practices” in the Daily Journal (2024) and “Courts Are Increasingly Wary of Feel-Good Green Marketing Claims” in the Daily Journal (2023), and has spoken at FTC Common Ground Conferences, the Beverly Hills Bar Association, and AARP Town Halls on data breaches.
- Experience
Christina led the FTC’s $100 million settlement with DeVry University, secured a $478 million judgment in a major “get rich quick” scheme enforcement, and co-led a student loan fraud case against Premier Student Loan Center that won $280 million in relief. She is currently co-lead counsel in a federal privacy class action against BetterHelp and previously led privacy litigation against TaxAct over improper data sharing with Meta and Google.
Joan Rossman, Associate | Bailey Cavalieri
Joan Rossman is an Associate at Bailey Cavalieri LLC in the firm’s Columbus, Ohio office. She is a member of the Corporate & Transactional Business Practice Group, the Unclaimed Property Practice Group, and the Representations & Warranties Practice Group. Her experience enables her to provide creative solutions to various corporate matters, such as entity formation, corporate governance, regulatory compliance, mergers and acquisitions, due diligence, and contract drafting. In addition to her corporate and business practice, Joan also has experience in unclaimed property matters, including compliance, negotiation, audit defense, and gift card program structuring.
- Education & Credentials
Joan earned her J.D. from The Ohio State University Moritz College of Law in 2022 and her B.A. in International Political Economy from Fordham University in 2019. She is admitted to practice in Ohio.
- Recognition & Leadership
Joan has been named an Ohio Super Lawyer Rising Star (2024–2025), a Columbus CEO Top Lawyer (2025), and received the CALI Excellence for the Future Award in Business of Law (2022). As a Managing Editor of the Ohio State Business Law Journal, she honed her writing and analytical skills.
- Professional Involvement
Joan is a member of the Ohio State Bar Association, the Columbus Bar Association, Women Lawyers of Franklin County, and the Unclaimed Property Professionals Organization. She has authored client alerts on gift card matters including “Gift Card Update: ‘Granny Scam’ Legislation,” coverage of the New York Division of Consumer Protection model gift card scam notice, and the Rhode Island gift card scam notice legislation.
- Experience
Joan’s experience in unclaimed property includes compliance, negotiation, audit defense, and gift card program structuring. Her corporate and transactional practice covers entity formation, corporate governance, regulatory compliance, mergers and acquisitions, due diligence, and contract drafting.
Agenda
SESSION 1 – California Gift Card Law After SB 22 | 1:00pm – 2:00pm
Overview the California gift card framework under Civil Code § 1749.5 and the SB 22 amendments, then examine litigation under § 1749.5(b)(2), settlement structures, government enforcement, dual-track liability, and repeat litigation against previously settled defendants.
BREAK | 2:00pm – 2:10pm
SESSION 2 – SB 22 Compliance Roadmap and Multi-State Gift Card Program Risks | 2:10pm – 2:40pm
Provide a compliance roadmap for retailers under SB 22, including employee training, POS audits, electronic gift card workflows, defensive documentation, consumer-facing terms, and the impact of the new $15 threshold on FinCEN’s 2016 de minimis guidance.
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