BILL ANALYSIS                                                                                                                                                                                                    






                           SENATE JUDICIARY COMMITTEE
                        Senator Ellen M. Corbett, Chair
                           2009-2010 Regular Session


          AB 260                                                 
          Assemblymember Lieu                                    
          As Introduced                                          
          Hearing Date: July 14, 2009                            
          Various Codes                                          
          BCP:jd                                                 
                                                                 


                                     SUBJECT
                                         
                                    Lending

                                   DESCRIPTION  

          This bill would enact various provisions with respect to  
          higher-priced mortgage loans, as defined, that are  
          originated on or after July 1, 2010.  Specifically, this  
          bill would, among other things:
           provide that a licensed person shall not make any false,  
            deceptive, or misleading statement or representation;
           require a mortgage broker to receive the same  
            compensation for providing mortgage brokerage services  
            whether paid by a lender, borrower, or a third party; and
           prohibit a mortgage broker from steering a borrower to  
            accept a loan at higher cost, as specified.

          The bill would also, for higher-priced mortgage loans  
          originated on or after July 1, 2010, prohibit a licensed  
          person from making a higher-priced mortgage loan that  
          contains a provision for negative amortization, and limit  
          prepayment penalties to two percent the first year and one  
          percent the second year.  

          This bill would also, as of January 1, 2010:
           codify the fiduciary duty of a mortgage broker to a  
            borrower with respect to residential mortgage loans; and
           provide that a licensee's violation of specified federal  
            acts and regulations is a violation of the licensee's  
            respective licensing law.
                                                                 
          (more)



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          (This analysis reflects author's amendments to be offered  
          in committee.)


                                    BACKGROUND 

          California, as well as the nation, is facing an  
          unprecedented threat to the economy and housing market due  
          to increasing numbers of foreclosures caused by mortgage  
          payment defaults.  Although the crisis is the result of a  
          culmination of various factors (including inflated property  
          values and investor pressure for the sale of certain loan  
          products) there has been an increased focus on instances of  
          fraud and predatory practices that likely contributed to  
          the crisis.  With respect to the role of mortgage brokers,  
          the Wall Street Journal, on May 30, 2007, reported:

            Brokers, most of whom are lightly regulated by state  
            agencies, are involved in originating around 60% of all  
            home loans, according to Wholesale Access, a research  
            firm in Columbia, Md.  The industry is under scrutiny  
            in Washington and state capitols because rogue brokers  
            have been accused of contributing to the spike in  
            mortgage defaults and foreclosures by encouraging  
            borrowers to take risky loans and by charging excessive  
            fees. . . .

            Often the broker's incentives run counter to the  
            borrower's interests. Lenders pay [a yield spread  
            premium (YSP)] to the broker when the borrower is  
            paying a higher interest rate than the best he or she  
            could qualify for, which makes the loan more profitable  
            for the lender.  The higher the rate, the higher the  
            payment to the broker. (Some lenders put a ceiling on  
            YSP.)  Lenders may also pay brokers a bonus for loans  
            with prepayment penalties, which make it expensive for  
            borrowers to refinance within the first few years.

          This bill, based upon a North Carolina statute enacted in  
          2007, seeks to provide increased restrictions on mortgage  
          brokers, regulate certain loan products, provide increased  
          regulatory oversight, and specifically codify the fiduciary  
          duty of mortgage brokers.  This bill is substantially  
          similar to AB 1830 (Lieu, 2008), which was approved by this  
                                                                       




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          committee on August 18, 2008 and vetoed by the Governor.

          This bill was approved by the Senate Committee on Banking,  
          Finance and Insurance on July 9, 2009.

                             CHANGES TO EXISTING LAW
           
          1.    Existing federal law  provides for a number of laws  
            that govern the rules under which mortgage lending,  
            brokering, and servicing may be conducted. These federal  
            laws include the Home Ownership and Equity Protection Act  
            (HOEPA), Real Estate Settlement Procedures Act  (RESPA),  
            Truth in Lending Act (TILA), Home Mortgage Disclosure Act  
            (HMDA), and regulations that interpret those acts (most  
            notably Federal Reserve Board Regulation C, which  
            interprets HMDA, Federal Reserve Board Regulation Z,  
            which interprets TILA, and U.S. Department of Housing and  
            Urban Development (HUD) Regulation X, which interprets  
            RESPA).  

             Existing state law  authorizes residential mortgage  
            lending, brokering, and servicing under five different  
            laws, including the Banking Law, Credit Union Law,  
            California Finance Lenders Law (CFLL), California  
            Residential Mortgage Lending Act (CRMLA), and Real Estate  
            Law, and the regulations that interpret those laws.   
            Existing state law generally regulates the entities that  
            engage in mortgage lending, brokering, and servicing  
            under three different departments, including the  
            Department of Financial Institutions (DFI), Department of  
            Corporations (DOC), and the Department of Real Estate  
            (DRE).

             Existing state law  , the Covered Loan Law, imposes  
            prohibitions on persons who make or arrange a covered  
            loan, and provides for administrative and civil penalties  
            and civil damages for failure to comply with the Covered  
            Loan Law. (Fin. Code Sec. 4970 et seq.)

             This bill  would enact various restrictions with respect  
            to higher-priced mortgage loans, including preventing  
            licensed persons from:
                 making or causing to be made any false, deceptive,  
               or misleading statement or representation;
                 recommending or encouraging default on an existing  
                                                                       




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               loan or other debt prior to and in connection with the  
               closing or planned closing of a higher-priced mortgage  
               loan, as specified; and 
                 making a higher-priced mortgage loan that contains  
               a provision for negative amortization.

             This bill  would provide that a mortgage broker, as  
            specified:
                 shall not steer, counsel, or direct any borrower to  
               accept a loan at a higher cost than that for which the  
               borrower could qualify based upon the loans offered by  
               the persons with whom the broker regularly does  
               business; 
                 shall not receive compensation, including a yield  
               spread premium (YSP), fee, commission, or any other  
               compensation, for arranging a higher-priced mortgage  
               loan with a prepayment penalty that exceeds the  
               compensation that the mortgage broker would otherwise  
               receive for arranging that higher-priced mortgage loan  
               without a prepayment penalty;
                 shall receive the same compensation for providing  
               mortgage brokerage services whether paid by the  
               lender, borrower, or a third party; and
                 must disclose if they only arrange higher-priced  
               mortgage loans. 

             This bill  would apply the provisions of the bill to any  
            licensed person who in bad faith attempts to avoid its  
            application by dividing any loan transaction into  
            separate parts, as specified, or any other subterfuge. 

             This bill  would provide that a licensed person who makes  
            a higher-priced mortgage loan and who, when acting in  
            good faith, fails to comply with the above provisions,  
            shall not be liable if the licensed person took specified  
            steps either (1) within 90 days of the loan closing and  
            prior to an action, or (2) within 120 days after the  
            receipt of a complaint or discovery of a compliance  
            failure that was unintentional and the result of a bona  
            fide error.  Those steps require the licensed person to:  
            (a) notify the borrower of the compliance failure; (b)  
            tender appropriate restitution; and (c) offer, at the  
            borrower's option, to either make the higher-priced loan  
            comply with the above requirements or change the terms of  
            the loan so that the loan is no longer a higher priced  
                                                                       




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            loan, as specified.

          2.    Existing federal law  , under the Federal Reserve  
            Board's Regulation Z effective October 1, 2009, will  
            prohibit prepayment penalties on higher-priced mortgage  
            loans and HOEPA loans if loan payments can change during  
            the first four years of the loan.  For all other  
            higher-priced loans and HOEPA loans whose payments do not  
            change for the first four years, existing federal law  
            will limit the prepayment penalty period to two years  
            after loan consummation and require that a prepayment  
            penalty may not be imposed if the same creditor or its  
            affiliate refinances the loan. (12 CFR 226.32(d)(6)-(7);  
            226.35(b)(2).)

             This bill  would provide that the maximum amount of a  
            prepayment penalty that may be imposed in connection with  
            a higher-priced mortgage loan shall not exceed 2 percent  
            of the principal balance during the first 12 months or 1  
            percent of that balance during the second 12 months  
            following loan consummation. 

          3.    Existing federal law  , the Truth in Lending Act,  
            generally prohibits unfair, abusive, or deceptive  
            mortgage lending practices and requires certain  
            disclosures.  Existing state law prohibits several  
            specific acts by persons licensed under the Real Estate  
            Law, and allows the commissioner to suspend or revoke the  
            license of any person who is found guilty of various  
            acts. (Bus. & Prof. Code Secs. 10176, 10177.)  

             This bill  would provide that any licensed person who  
            violates any provision of the division shall be deemed to  
            have violated that person's licensing law. The licensing  
            agency may also prohibit licensees from engaging in acts  
            or practices that are unfair, deceptive, or designed to  
            evade the laws of this state.
             
            This bill  would provide that a violation of Section  
            2923.1 of the Civil Code (codifying common law fiduciary  
            duty), or a violation of the provisions in Regulation Z  
            relating to prepayment penalties, in connection with a  
            higher-priced mortgage loan, is a violation of this  
            division.  This bill would provide that a prepayment  
            penalty or yield spread premium provision of a  
                                                                       




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            higher-priced mortgage loan that violates the division  
            shall be unenforceable.

             This bill  would state that the provisions of the division  
            may be enforced only by the Attorney General or the  
            licensed person's licensing agency.  Any licensed person  
            who willfully and knowingly violates any provision of the  
            division shall be liable for a civil penalty of $10,000  
            per violation.  
             
            This bill  would define "higher-priced mortgage loan" to  
            have the same meaning set forth in the Federal Reserve  
            Board's Regulation Z.  That definition, which takes  
            effect October 1, 2009, provides that a "higher-priced  
            mortgage loan" is a consumer credit transaction secured  
            by the consumer's principal dwelling with an annual  
            percentage rate that exceeds the average prime offer rate  
            for a comparable transaction as of the date the interest  
            rate is set by 1.5 or more percentage points for loans  
            secured by a first lien on a dwelling, or by 3.5 or more  
            percentage points for loans secured by a subordinate lien  
            on a dwelling.  The definition specifically excludes  
            loans for initial home construction, temporary or  
            "bridge" loans, reverse mortgages, and home equity lines  
            of credit, as specified. 
             
            This bill  would also define licensed person, mortgage  
            broker, and mortgage brokerage services.

             This bill  would provide that the provisions described in  
            1 - 3 apply to higher-priced mortgage loans originated on  
            or after July 1, 2010.  

          4.    Existing case law  generally provides that a mortgage  
            loan broker owes a fiduciary duty of the highest good  
            faith toward his or her principal and is charged with the  
            duty of fullest disclosure of all material facts  
            concerning the transaction that might affect the  
            principal's decision.  (Barry v. Raskov (1991) 232  
            Cal.App.3d 447, 455; Wyatt v. Union Mortgage Co. (1979)  
            24 Cal.3d 773, 782.)  Existing law, the Residential  
            Mortgage Lending Act, requires a loan brokerage agreement  
            to contain an explicit statement that, when acting as an  
            agent for the borrower, the licensee owes that borrower a  
            fiduciary duty of utmost care, honesty, and loyalty in  
                                                                       




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            the transaction, including the duty of full disclosure of  
            all material facts. (Fin. Code Sec. 50701.)  Existing  
            law, the Covered Loan Law, additionally codifies the duty  
            of a mortgage broker. (Fin. Code Sec. 4979.5.) 

             This bill  would state that a mortgage broker providing  
            mortgage brokerage services to a borrower is the  
            fiduciary of the borrower, and any violation of the  
            broker's fiduciary duties shall be a violation of the  
            mortgage broker's license law.  That fiduciary duty  
            includes a requirement that the mortgage broker place the  
            economic best interest of the borrower ahead of his or  
            her own economic interest, and is owed to a borrower  
            regardless of whether the broker is acting as an agent  
            for any other party in the transaction.

             This bill  would, for purposes of that section, define  
            licensed person, mortgage broker, mortgage brokerage  
            service, and residential mortgage loan.  Those  
            definitions would limit application of the fiduciary duty  
            provision to loans secured by residential real property  
            that is improved by one to four units, and where the  
            broker is the agent of the borrower or dual agent for the  
            borrower and lender.

          5.    Existing law  , generally regulates the entities that  
            engage in mortgage lending, brokering, and servicing  
            under DFI, DOC, and DRE.

             This bill  would provide that a licensee's violation of  
            any of the following federal acts or regulations is a  
            violation of the licensee's licensing law:
                 The Real Estate Settlement Procedures Act (RESPA);
                 The Truth in Lending Act, as amended (TILA);
                 The Home Ownership Equity Protection Act (HOEPA);  
               or
                 Any regulation promulgated under the above acts.

                                     COMMENT
           
          1.    Stated need for the bill  

          According to the author,

            Briefly, the past few years have shown the consequences  
                                                                       




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            of a lending system that failed to effectively regulate  
            and reign in the out of control subprime mortgage  
            industry.  The problem has, and continues to be,  
            particularly acute in California, which accounts for  
            one-third of the nations foreclosures.  Lenders filed a  
            record number of mortgage default notices against  
            California homeowners during the first three months of  
            the year.  Most of these default notices are the result  
            of bad loans that were made in 2005 and 2006.  AB 260  
            directly addresses the poor lending practices that  
            caused, and continue to cause, a record number of  
            foreclosures in California.

          Committee staff additionally notes that the recent increase  
          in foreclosure activity is due to the increasing number of  
          defaults on Alt-A loans where bad loan practices also  
          played a role.  The proposed reforms could also alleviate  
          some of the abuses in that area as well.

          2.    Restrictions on activities of mortgage brokers and  
          other licensed persons  
           
           Many of the allegations of broker fraud include concerns  
          about improper incentives created by the use of  
          yield-spread premiums (YSP), actions contrary to the best  
          interest of borrowers, and claims of steering "prime"  
          borrowers into "subprime" loans.  This bill includes  
          numerous provisions that attempt to directly address those  
          concerns with respect to higher-priced mortgage loans.

             a)    Prohibition on making any false, deceptive, or  
               misleading statement or representation in connection  
               with a higher-priced mortgage loan  

            Although false, deceptive, or misleading statements may  
            already subject a licensee to discipline under their  
            respective licensing laws, this bill would specifically  
            prohibit those statements.  Provided that borrowers  
            recognize that a false, deceptive, or misleading  
            statement was made, this provision alone would provide  
            borrowers with a tool to combat a vast majority of the  
            reported abuses that led to the current mortgage crisis.

            For example, if a mortgage broker sells a borrower a  
            risky adjustable rate mortgage but is misleading in their  
                                                                       




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            description of the product and its associated risks, the  
            broker could be subject to liability under this  
            provision.  Other potential situations covered by this  
            language could be the steering into a higher-priced  
            mortgage loan through deceptive statements, or the  
            intentional concealment of a kickback from a lender as a  
            result of placing a borrower in a higher-priced loan.  

             b)   Restriction on mortgage broker compensation,  
               including payment of a yield spread premium

             This bill would require a mortgage broker to receive the  
            same compensation for providing brokerage services  
            whether paid by the lender, borrower, or a third party.   
            Staff notes this provision intends to address the reports  
            of brokers receiving greater compensation for steering  
            borrowers into riskier loan products.  This provision  
            would address any prior incentive to direct borrowers  
            into those products by preventing a broker from receiving  
            greater compensation from a lender than the borrower  
            would pay to the broker in up-front costs.  Consistent  
            with the fiduciary duty and anti-steering provision, the  
            removal of that financial incentive further ensures that  
            brokers are acting in the borrower's best interest.

            Also related to broker compensation, this bill would  
            provide that a broker shall not receive greater  
            compensation for including a prepayment penalty in a  
            higher-priced mortgage loan.  Similar to the use of a  
            YSP, connecting broker compensation to the inclusion of a  
            prepayment penalty financially compensates a broker for  
            placing a borrower in an arguably costlier product.
            c)    Remaining mortgage broker provisions include a  
            prohibition on steering  

            The bill would also prohibit a broker from steering a  
            borrower into a loan of higher cost than that for which  
            they could qualify, as specified, and require a broker to  
            disclose if they only originate higher-priced mortgage  
            loans.  

          3.    Codification of a mortgage broker's fiduciary duty  
            with respect to residential mortgage loans, including  
            those that are not higher-priced  

                                                                       




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          California is one of several states in which mortgage  
          brokers have a fiduciary duty to borrowers when acting as  
          their agent in a loan transaction.  In Wyatt v. Union  
          Mortg. Co. (1979) 24 Cal.3d 773, the California Supreme  
          Court held:

            In the context of insurance policies, this court has  
            recognized that a fiduciary's duty may extend beyond  
            bare written disclosure of the terms of a transaction  
            to duties of oral disclosure and counseling. . . The  
            reasoning of these cases applies to transactions with  
            mortgage loan brokers as well. . . . Against such a  
            backdrop, the broker's failure to disclose orally the  
            true rate of interest, the penalty for late payments or  
            the swollen size of the balloon payment clearly  
            constituted breach of the broker's fiduciary  
            obligations.  (Id. at 783-84.)

          Although established in case law, this bill would  
          specifically codify the fiduciary duty owed by a mortgage  
          broker when providing mortgage brokerage services to a  
          borrower.  The fiduciary duty would expressly require the  
          broker to place the economic interest of the borrower ahead  
          of his or her own economic interest, and clarify that the  
          broker owes the fiduciary duty to the borrower regardless  
          of whether the mortgage broker is acting as an agent for  
          any other party in connection with the residential mortgage  
          loan transaction.  

          This codified duty would apply to residential mortgage  
          loans secured by four or fewer residential units where the  
          mortgage broker is the exclusive agent of the borrower or  
          dual agent of the borrower and lender.  As case law does  
          not explicitly define the outer boundaries of fiduciary  
          duty, the bill contains a savings clause that states that  
          the duties in the section shall not be construed to limit  
          or narrow any other fiduciary duty of a mortgage broker.   
          Staff further notes that the intent of this provision is to  
          codify fiduciary duty and not to imply a fiduciary  
          relationship that may not otherwise exist.

          4.    Restrictions on licensed persons include restrictions  
            on the use of prepayment penalties and prohibition on  
            loans that provide for negative amortization  

                                                                       




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          In addition to the above specific prohibitions that apply  
          to mortgage brokers, the bill places further restrictions  
          on the activities of specified persons licensed under the  
          Real Estate Law, Finance Lenders Law, Residential Mortgage  
          Lending Act, Banking Law, Savings Associations Law, and  
                                                                Credit Union Law. 

          Most notably, the bill states that the maximum amount of a  
          prepayment penalty that may be imposed by a licensed person  
          in connection with a higher-priced mortgage loan shall not  
          exceed two percent of the principal balance during the  
          first 12 months or one percent of that balance during the  
          second 12 months.  Staff notes that this provision is  
          intended to overlay with the changes to Regulation Z that  
          will go into effect on October 1, 2009.  Those changes  
          prohibit prepayment penalties on higher-priced loans if  
          loan payments can change during the first four years of the  
          loan, and limit prepayment penalties to two years in length  
          on loans whose payments are constant during the first four  
          years of the loan.  To complement those additional  
          restrictions, this bill, as of July 1, 2010, would restrict  
          prepayment penalties as described above.   

          The bill would also prohibit a licensed person from making  
          a higher-priced mortgage loan that contains a provision for  
          negative amortization (loan payments for a period such that  
          the payment is less than the interest charged over that  
          period resulting in an increase in the outstanding  
          balance).  It should be noted that that prohibition would  
          not preclude a subsequent agreement to capitalize payments  
          as a means of curing or preventing default.  

          5.    Remedies for violation  

          The bill would provide for enforcement by the Attorney  
          General or the licensed person's licensing agency, include  
          a civil penalty of $10,000 for a willful and knowing  
          violation of the bill's provisions, and specifically allow  
          a licensing agency to prohibit licensees from engaging in  
          acts that are unfair, deceptive, or designed to evade the  
          laws of this state.  The bill would also provide that a  
          prepayment penalty or yield spread premium provision in  
          violation of the added division is unenforceable and state  
          that a licensed person who violates any provision of the  
          division shall be deemed to have violated that person's  
                                                                       




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          licensing law. 

          It should be noted that the author's amendments in Comment  
          10 would strike the private right of action and attorney  
          fee provisions from this bill.  Those amendments would  
          appear to address some of the prior concerns raised about  
          this bill (and its predecessor, AB 1830).  Provided that it  
          is not inconsistent with the author's commitment in the  
          Senate Banking, Finance, and Insurance Committee, the  
          following savings clause is suggested to ensure that the  
          striking of that language is not construed to limit the  
          remedies otherwise available to aggrieved borrowers:



             Suggested amendment:  

            On page 11, between lines 36 and 37, insert:

            4995.6. Nothing in this division shall be construed to  
            affect any other rights or remedies otherwise available  
            at law. 

          The bill also contains a right to cure that applies if a  
          licensed person, in good faith, fails to comply with  
          certain requirements of the bill.  The licensed person can  
          invoke the right to cure either: (1) within 90 days of the  
          loan closing and prior to the institution of any action  
          against the licensed person; or (2) within 120 days after  
          receipt of a complaint of discovery of a compliance failure  
          if the failure was not intentional and resulted from a bona  
          fide error, as specified.  In both instances, the licensed  
          person must notify the borrower of the compliance failure,  
          tender appropriate restitution, offer (at the borrower's  
          option) either to make the loan comply with the bill's  
          requirements or change the loan terms so that it is not a  
          higher-priced mortgage loan, and take appropriate action  
          within a reasonable period of time.  

          From a policy standpoint, a right to cure is usually not  
          included in consumer statutes out of concerns that  
          individuals will not comply until their violation is  
          actually discovered.  In this case the right to cure  
          provision, as with other provisions of the bill, is from a  
          recently enacted North Carolina statute, and its inclusion  
                                                                       




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          should not be construed as endorsing the insertion of a  
          right to cure provision into other consumer statutes.   
          Furthermore, the right to cure is narrowly crafted to give  
          the borrower an early remedy as a means of avoiding costly  
          protracted litigation that could jeopardize the borrower's  
          ability to remain in the home.  It should also be noted  
          that the right to cure only applies when the licensed  
          person acts in good faith, and that once an action is  
          filed, the provision only applies to bona fide errors  
          (defined as including clerical, calculation, computer  
          malfunction and programming, and printing errors).  

          6.    Expanded regulatory authority for violations of  
            federal statutes and regulations
           
          This bill would also give DFI, DOC, and DRE express  
          authority to enforce TILA, HOEPA, and RESPA, as if  
          violations of these federal laws and their implementing  
          regulations were violations of state licensing laws.  This  
          language would provide consistency in the application of  
          laws and regulations across licensees by giving  
          California's three mortgage licensing departments express  
          authority to address violations. 




          7.    Application to federally chartered financial  
            institutions  

          Federal banking statutes and regulations do contain  
          preemption clauses that restrict the ability of the state  
          to regulate the activities of federally chartered financial  
          institutions.  

          As an example, 12 C.F.R. 34.4(a), which implements the  
          National Bank Act, preempts "state laws that obstruct,  
          impair, or condition a national bank's ability to fully  
          exercise its Federally authorized real estate lending  
          powers."  
          Although the language of this bill refers only to  
          individuals licensed under California law, certain  
          provisions (such as the prepayment penalty language) may  
          act to restrict the loan products that a federally  
          chartered financial institution may offer through a  
                                                                       




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          California licensed mortgage broker.  Despite that  
          potential restriction, it can be argued that the activities  
          of mortgage brokers are within the purview of the  
          individual states and that the provisions of this bill are  
          permissible restrictions on state licensees in response to  
          prior bad acts by those licensees.  

          It should be noted that if any provision of the division on  
          Higher-Priced Mortgage Loans is found to be preempted, the  
          included severability clause would ensure that the  
          invalidity shall not affect other provisions or  
          applications that can be given effect without the invalid  
          provision or application.

          8.    Opposition's arguments  

          The California Association of Mortgage Brokers (CAMB), in  
          opposition, applauds the intent of AB 260 but expresses  
          concern that its flaws will nullify the bill's positive  
          components.  CAMB contends that: (1) the proposed statutory  
          fiduciary duty's economic interest test is vague; (2) the  
          anti-steering clause fails to provide guidance on the  
          definition of "high cost;" and (3) the safe harbor  
          provision cannot be utilized because it requires a broker  
          to change loan terms after a loan has been funded.

          The California Association of Realtors (CAR), in  
          opposition, contends that AB 260 is "obsolete before it can  
          become effective" because federal law requires California  
          to separately license, register, or regulate "all mortgage  
          loan originators."   

          The Civil Justice Association of California (CJAC) further  
          opposes the bill due to concerns that it would create a  
          statutory fiduciary duty where the obligation is already  
          required under case law, and out of concern that the other  
          provisions of the bill would encourage lawsuits.

          The Department of Finance, Department of Corporations, and  
          Department of Real Estate all oppose for the same reasons  
          as stated in the Governor's veto message for AB 1830 (Lieu,  
          2008).

          9.   Veto of AB 1830 (Lieu, 2008)  

                                                                       




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          With the exception of enactment dates, this bill is  
          identical to AB 1830 (Lieu, 2008), which was vetoed by the  
          Governor.  The Governor's veto message stated:

            The goals of this bill are to be lauded and the work  
            and effort that went into the bill commended.  However,  
            I believe the approach of the bill to address the  
            subprime crisis overreaches and may have unintended  
            consequences.

            First, its provisions will only apply to state  
            regulated entities, as federally regulated entities  
            will be exempt.  This will create an uneven playing  
            field, putting state regulated entities at a  
            competitive disadvantage and consumers will have  
            unequal protections under the law.  Secondly, this bill  
            allows for a private right of action and allows a  
            plaintiff to recover attorney fees if he or she  
            prevails.  The bill does not allow a defendant to  
            recover costs if he or she prevails. This provision  
            will likely lead to increased litigation based on de  
            minimis violations as plaintiffs attorneys will have  
            much to gain and little to lose.

            Many changes have already occurred to curb some of the  
            past lending and brokering abuses.  Last year, I signed  
            SB 385 strengthening underwriting criteria to ensure  
            that borrowers can afford loans.  The Federal Reserve  
            Board has implemented amendments to the Truth in  
            Lending Act (Regulation Z) to regulate advertising  
            practices and provide additional protections to the  
            lending marketplace.  I recently signed SB 1137 to  
            provide homeowners with additional protections against  
            foreclosure and to expand the rights of tenants.   
            Finally, the President recently signed the Housing and  
            Economic Recovery Act, which imposes new oversight  
            requirements on loan originators and contains many  
            other provisions to assist in economic recovery.  All  
            of these changes need time to take effect.  As a  
            result, further legislation is unnecessary until we can  
            evaluate the effect of the reforms that have already  
            been enacted.

          10.   Author's amendments  

                                                                       




          AB 260 (Lieu)
          Page 16 of ?



          The following amendment to remove the private right of  
          action was accepted by the author in the Senate Committee  
          on Banking, Finance and Insurance, but is to be taken in  
          this committee due to procedural timing requirements.

            On page 11, strike out lines 26 through 30, inclusive.
           Support:   California Federation of Teachers; California  
          Conference Board of the Amalgamated Transit Union; United  
          Food and Commercial Workers Union, Western States Council;  
          Engineers and Scientists of California; UNITE HERE!;  
          California Conference of Machinists; Professional &  
          Technical Engineers, Local 21; Strategic Committee of  
          Public Employees, Laborers' International Union of North  
          America; California Teamsters Public Affairs Council;  
          California Labor Federation, AFL-CIO; California State  
          Employees Association (CSEA); American Federation of State,  
          County and Municipal Employees (AFSCME), AFL-CIO

           Opposition:   Department of Real Estate; Department of  
          Corporations; Department of Finance; California Mortgage  
          Association; California Association of Mortgage Brokers;  
          California Association of Realtors; Civil Justice  
          Association of California

                                     HISTORY
           
           Source:   California Labor Federation; California ACORN;  
          CALPIRG

           Related Pending Legislation:  None Known

           Prior Legislation: 
           
          SB 1137 (Perata, Chapter 69, Statutes of 2008), enacted a  
          comprehensive foreclosure reform package.

          SBX2 7 (Corbett, Chapter 4, Statutes of 2009), provided  
          that a servicer of residential mortgage loans may not  
          proceed with foreclosure proceedings for 90 days under  
          specified conditions, unless the servicer has a  
          comprehensive loan modification program.

          AB 1830 (Lieu, 2008).  See Comment 9.

           Prior Vote:
                                                                       




          AB 260 (Lieu)
          Page 17 of ?



           
          Assembly Banking and Finance Committee (Ayes 7, Noes 3)
          Assembly Judiciary Committee (Ayes 7, Noes 3)
          Assembly Appropriations Committee (Ayes 12, Noes 5)
          Assembly Floor (Ayes 50, Noes 28)
          Senate Banking, Finance, and Insurance Committee (Ayes 7,  
          Noes 3)

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