BILL ANALYSIS
SB 392
Page 1
Date of Hearing: June 15, 2010
ASSEMBLY COMMITTEE ON JUDICIARY
Mike Feuer, Chair
SB 392 (Florez) - As Amended: March 25, 2010
As Proposed to be Amended
SENATE VOTE : 36-0
SUBJECT : Limited Liability Companies: Licensed Contractors
KEY ISSUE : SHOULD LIMITED LIABILITY COMPANIES (LLCs), WHICH ARE
FREQUENTLY ATTRACTIVE TO BUSINESS OWNERS BECAUSE LLCs PAY LITTLE
OR NO TAXES COMPARED TO CORPORATIONS AND OTHER FORMS OF
BUSINESS, BE ADDED TO THE LIST OF BUSINESS ORGANIZATIONS THAT
ARE ELIGIBLE TO OBTAIN A CONSTRUCTION CONTRACTORS LICENSE?
FISCAL EFFECT : As currently in print this bill is keyed fiscal.
SYNOPSIS
This bill is back for rehearing after being held as a two-year
measure when it was initially presented to the Committee last
July. In the interim, the author has taken amendments that have
removed all opposition by the building trades and other labor
groups.
The bill is sponsored by large construction contractors in order
to allow any qualified business organized as a limited liability
company (LLC) to obtain a construction contractors license. A
LLC is a hybrid form of business that protects its owners from
any personal liability, like a corporation, while allowing the
business to avoid taxation by passing profits directly to the
owners, like a partnership. LLCs also allow owners to allocate
rights and responsibilities in any way they wish, so that some
members of the LLC can have management and control while others
do not. Historically, LLCs have not been permitted to engage in
licensed professional services under the Beverly-Killea Limited
Liability Company (LLC Act) in light of the fact that LLCs
immunize the owners of the business from personal liability.
This bill would make construction contractors the first to
obtain an exception from this rule. Supporters state that the
existing prohibition against awarding contractors licenses to
LLCs is archaic, and an impediment to attracting established
SB 392
Page 2
national companies to do business in the state. They argue that
the LLC form has useful flexibility for distribution of profits
and losses that make it a more desirable arrangement.
Labor groups have removed their opposition in light of
amendments that require an LLC to post a wage bond in the amount
of $100,000 for the benefit of workers employed by these
entities because of concerns that the limited liability of LLCs
could potentially leave workers without recourse if wages go
unpaid.
SUMMARY : Notwithstanding the prohibition under the LLC Act
against a limited liability company providing licensed services,
authorizes the State Contractors License Board to issue a
contractors license to a limited liability company if the LLC
meets other requirements such as bonding, solvency, and
liability insurance. Specifically, this bill :
1)Includes LLC within the definition of "person" for the
purposes of the Contractors State License Law (Contractors
Law).
2)Defines "qualifying person," "qualifying individual," or
"qualifier" as an individual who qualifies for a contractor's
license.
3)Authorizes the issuance of a contractor's license to a LLC,
and adds license requirements that mirror those of a
corporation.
4)Requires a LLC to provide security for claims by obtaining
liability insurance with a total aggregate limit of $1 million
for a limited liability company that employs five or fewer
licensed persons, and an additional $100,000 of insurance for
each additional person up to $5 million dollars in any one
designated period for a LLC that employs more than five
licensees rendering professional services on behalf of the
company. Defines "designated period" to mean a policy year or
period less than 12 months. A certification of coverage shall
be submitted to the commissioner by the licensee or applicant,
and signed by an authorized agent or employee of the insurer.
5)Requires that if a LLC license is suspended, each person
within the company identified shall be personally liable up to
$1 million for damages against third parties in connection
SB 392
Page 3
with the company's performance during the period of
suspension, for any act or contract where a license is
required.
6)Requires that as a condition precedent to the issuance or
valid use of a LLC license the applicant or licensee file or
have on file a surety bond in the sum of $100,000 for the
benefit of any employee damaged by his or her employer's
failure to pay wages, interest on wages, or fringe benefits as
an additional safeguard for workers employed by or contracted
to work for a limited liability company. If the LLC is a
party to a collective bargaining agreement, this bond shall
also cover welfare fund contributions, pension fund
contributions and apprentice program contributions.
7)Requires that if a LLC's contractor license has been suspended
or revoked as a result of disciplinary action, or a person who
was a qualifying individual for a licensee at any time during
which cause for disciplinary action occurred resulting in
suspension or revocation of the licensee's license, the CSLB
shall require as a condition precedent to the issuance,
reissuance, renewal, or restoration of a license to the
applicant, or to the approval of an application to change
officers of a corporation or a limited liability company, or
removal of suspension, or to the continued valid use of a
license which has been suspended or revoked, but which
suspension or revocation has been stayed, that the applicant
or licensee file or have on file a contractor's bond in a sum
to be fixed by the registrar based upon the seriousness of the
violation, but which sum shall not be less than fifteen
thousand dollars ($15,000) nor more than 10 times the amount
required by Section 7071.6.
8)Requires that the qualifying individual for a LLC shall not be
required to file or have on file a qualifying individual's
bond if he or she owns at least a 10% interest in the LLC and
certifies this fact on a form prescribed by the registrar.
9)Requires a LLC to include information of the liability
insurance or security it maintains at a financial institution
for change orders and service and repair contracts.
10)Provides that with respect to administrative proceedings or
hearings to suspend or revoke a contractor's license of a LLC
or any other type of licensee the CSLB shall have the burden
SB 392
Page 4
of proof to establish by clear and convincing evidence that he
or she is entitled to the relief sought in the petition.
11)Provides that the CSLB shall begin processing applications
for licensure from limited liability companies no later than
January 1, 2012.
EXISTING LAW :
1)Pursuant to the Beverly-Killea Limited Liability Company (LLC)
Act of 1994, prohibits domestic and foreign limited liability
companies from rendering professional services in California.
(Corp. Code Sec. 17375.)
2)Defines "professional services" as "any type of professional
services which may be lawfully rendered only pursuant to a
license, certification, or registration authorized by the
Business and Professions Code, the Chiropractic Act, or the
Osteopathic Act." (Corp. Code Sec. 13401(a).)
3)Provides for the licensure and regulation of contractors by
the Contractors State License Board (CSLB). (Bus. & Prof.
Code section 7025 et seq.)
4)Defines "person" for the purpose of the Contractors Law to
include an individual, a firm, co-partnership, corporation,
association or other organization, and prohibits any
unlicensed person from engaging in business or acting as a
contractor. (Id.)
COMMENTS : The author states that this bill is needed for the
following reasons:
The existing contractors' license law is archaic as most
states allow an LLC to hold a contractor's license -
California law is an impediment to established nationwide
businesses doing business in the state. The LLC form of
business has needed flexibility for distribution of profits
and losses separate from control and ownership which
benefits commerce with no foreseeable detriment.
Fourteen years after passage of the LLC Act, LLCs comprise
an indelible part of the business landscape in California
and throughout the United States. This bill is necessary so
that LLCs may be utilized in the construction industry just
SB 392
Page 5
as they are in countless other industries throughout
California. Notably, this is already the case in other
States. Of the 29 States that license or regulate
contractors, only California imposes a complete ban on
operating as an LLC.
LLCs are a desired entity for construction companies, as
they are with many other industries, primarily because LLCs
provide the flexibility to distribute profits and losses to
owners without double taxation, in a manner similar to
corporations electing "S" status under the Internal Revenue
Code, but without the limited shareholder qualifications,
i.e. "S" corporation shareholders must be individuals with
very limited exceptions and the number of shareholders is
limited to 100. This flexibility as to the identity of
shareholders is coveted for achieving estate planning
objectives. Similarly, an "S" corporation's largest
shareholders receive the largest share of profits. The LLC
for of business allows the owners to dictate how the
profits are split and taxed without dictation by the
percentage ownership.
This improved estate planning and profit sharing
flexibility will have no negative impact on consumers of
construction services in California. An LLC provides
liability protection for the personal assets of owners
equivalent to, but not more than, that afforded
corporations.
Limited Liability Companies Are Believed To Offer Larger
Businesses Significantly More Desirable Tax And Nontax Benefits
Compared To Other Forms, With Unknown Revenue Implications For
The State. Generally, a LLC is a legal entity formed under the
Beverly-Killea Limited Liability Company Act, which allows one
or more owners to conduct a business without any owner having
personal liability for the obligations of the business. The
owners of an LLC may be individuals, or they may be corporations
or other business entities. That is, a group of corporations,
partnerships or individuals may combine to form and conduct an
LLC. It is expected that many existing corporations may
re-organize as LLCs to take advantage of lower taxes, and that
partnerships may do so to limit their liability.
The salient non-tax characteristics of a LLC are limited
liability for its owners (as in a corporation) and freedom to
SB 392
Page 6
structure management rights and financial interests in the
entity in virtually any configuration the parties wish (as in a
partnership). Unlike a corporation, an LLC can have different
classes of ownership and may allocate income, gains, losses, and
other items disproportionately among owners without affecting
the LLC's pass-through tax treatment.
There are also important tax consequences. In regular
corporations, both the entity and the shareholders are taxed on
profits, and on the increased value of the property when the
property is sold or the corporation is liquidated. LLCs avoid
taxation of the entity. In addition, because the LLC usually
elects to be treated as a partnership for income tax purposes,
the income, gains, losses, deductions, and credits of the LLC
generally will flow through to its members for reporting on
their individual tax returns, with the distribution of that
income depending on the terms of the LLC agreement, not
necessarily the ownership interest of the individual members.
There appears to be no necessary relationship between allocation
of management rights and profits among the owners of an LLC. A
large owner may have little or no control over the company,
while profits could be apportioned to LLC members who have the
least tax exposure.
Combined with the ability of LLCs to allocate income, gains,
losses, and other items disproportionately among owners, LLCs
may be arranged in such a way as to create significantly more
desirable tax treatment than corporations or other forms of
business organization.
According to the sponsor, because of taxation and other
considerations formation of a new business, or conversion of an
existing business, as a LLC under this bill is expected to be
attractive primarily to large companies. This calculation is
shared by the Landscape Contractors Association which has
withdrawn its prior support of the bill (it is now neutral)
because the bill is predicted to be of value mostly for big
companies.
Naturally, more favorable tax consequences for the owners may
translate into less tax revenue for the state. The Revenue and
Taxation Committee advises that, to deal with these revenue
consequences, existing law requires California LLCs to file tax
returns and pay a relatively modest $800 annual LLC tax, similar
to the minimum tax paid by "S" corporations. In addition to the
SB 392
Page 7
LLC tax, California LLCs must also pay an LLC fee between $900
and $11,790 based on its total income from all sources derived
or attributable to this state. These fees appear to be not as
progressive as the corporate or personal tax rates. It is not
clear whether these minimum taxes and fees apply to both
domestic and foreign LLCs, both of which would be eligible to
obtain a contractor's license under the bill.
According to the CSLB, there are currently over 70,000 corporate
licensees. It is not known what proportion of them would
restructure as LLCs under this bill, although the sponsors
indicate that it is the largest companies that will be most
likely to do so. Because the bill has not been referred to the
Revenue and Taxation Committee it is unknown whether the LLC
fees these entities would pay in lieu of taxes would be a net
loss or gain for state revenues. However, the bill will be
referred to the Appropriations Committee which may be able to
assess these issues.
Until LLCs were first authorized in 1994, the limited
partnership and the subchapter S corporation were the primary
forms of business entity used to achieve the tax status and
limited liability features now offered by the LLC. A limited
partnership allows pass-through tax treatment, flexibility in
financial structuring, and limited liability for the partners
(as long as they do not take part in the control of the
business), but requires one person (the general partner) to be
fully liable for the obligations of the business. Unlike a
limited partnership, no LLC member need be personally liable for
the company's obligations, and yet each member is permitted to
manage the company and to take part in the control of the
business without losing the member's limited liability. (Corp.
Code Secs. 17101, 17150.)
Although an S corporation allows pass-through tax treatment and
limited liability for all owners, S corporation status limits
the parties' flexibility in structuring their financial
arrangements because of the requirements that the corporation
have no more than one class of stock and that items of income,
gain, loss, deduction, or credit be distributed among
shareholders on a pro rata basis. Furthermore, only
individuals, estates, certain types of trusts, and certain
tax-exempt organizations are permitted to be S corporation
shareholders, and an S corporation will lose its pass-through
tax treatment if an ineligible entity becomes a shareholder.
SB 392
Page 8
Any person, as well as corporations, can be a member of an LLC
(thus sidestepping the restrictions on shareholders in the case
of an S corporation).
Liability Limits Balanced By New Wage Bond For Workers. The
limited liability and more desirable tax treatment of LLCs, and
the ease by which LLCs can be created, caused some labor groups
concerns that a large number of construction companies will
convert to LLC status, which could create new obstacles to
recovery of wages and benefits. The author has responded to
these concerns by amending the bill to require that each LLC
that obtains a license must obtain a bond in the amount of
$100,000 for the benefit of any employee damaged by his or her
employer's failure to pay wages, interest on wages, or fringe
benefits as an additional safeguard for workers employed by or
contracted to work for a limited liability company. If the LLC
is a party to a collective bargaining agreement, this bond must
also cover welfare fund contributions, pension fund
contributions and apprentice program contributions.
It may be asked whether the adoption of a uniform bond
requirement for all LLCs, rather than a scaled amount based on
size, is appropriate in light of the variation in size among
construction licensees who may organize as LLCs, ranging from
individuals who are now employed as sole proprietors engaged in
a few small projects, to large corporations with hundreds of
workers in multiple large public works projects. Setting the
bond at one amount for all these varying companies has some
precedent - e.g., last year's successful SB 43 (Alquist)
provided that specified design-build contracts may be required
to provide a payment bond of not less than one-half of the
contract price or three hundred million dollars ($300,000,000),
whichever is less. Supporters of this bill believe that a
$100,000 bond requirement is not overly burdensome because only
large companies are likely to take advantage of the bill in any
event.
All other potential claimants seeking losses or damages against
the company, including homeowners and persons injured by an LLC
contractor's wrongdoing, would be limited to seeking relief
under the existing contractor's bond. Under existing law, all
licensees are required to maintain a contractor's bond in the
sum of $12,500, at least $7,500 of which is dedicated for the
benefit of a person whose family home is damaged as the result
of a violation under a homeowner improvement contract. The
SB 392
Page 9
aggregate liability of a surety on a claim for wages and fringe
benefits brought against either bond may not exceed $4,000. If
any such bond is insufficient to pay all claims in full, the sum
of the bond shall be distributed to all claimants in proportion
to the amount of their respective claims. Under this bill,
individual qualifying members of an LLC would be relieved of
this bond requirements if the individual owns 10% or more of the
LLC.
General Prohibition Against Engaging In Licensed Activities As
An LLC. While LLCs may generally engage in any lawful business
activity (except banking, insurance, or trust company
operations), the Beverly-Killea Limited Liability Company Act
prohibits a foreign or domestic LLC from rendering professional
services in this state unless expressly authorized under
applicable provisions of law. "Professional services" are those
services for which a license, certification, or registration is
required under the Business and Professions Code, the
Chiropractic Act, or the Osteopathic Act. (Corp. Code Sec.
17375.)
The rationale for the Beverly-Killea LLC Act's exclusion of
professional services from the business that an LLC may
undertake has been that service providers who harm others by
their misconduct, incompetence, or negligence should not be able
to limit their liability by operating as an LLC and thus
potentially become judgment proof.
In 2004, the Attorney General (AG) issued an opinion, in
response to a request from the Secretary of State, on the
question of whether a business that provides services requiring
a license, certification, or registration pursuant to the
Business and Professions Code may conduct its business as a
limited liability company. The AG opinion concluded that "a
business that provides services requiring a license,
certification, or registration pursuant to the Business and
Professions Code may conduct its activities as a limited
liability company if the services rendered require only a
nonprofessional, occupational license." (Op. No. 04-103, 87
Ops. Cal. Atty. Gen. 109 (July 23, 2004).)
The AG opinion is clear that an LLC is not permitted to render
professional services, while an LLC would be permitted to
perform "nonprofessional occupational services" without
violating the Beverly-Killea LLC Act. However, the opinion also
SB 392
Page 10
recognized that for some purposes, the term "professional
services" has been broadly construed to include more than the
traditionally considered "learned" professions such as medicine,
law, or engineering, but includes such skilled services such as
plumbing. (Amex Assurance Co. v. Allstate Ins. Co. (2003) 112
Cal.App.4th 1246, 1252; Hollingsworth v. Commercial Union Ins.
Co. (1989) 208 Cal.App.3d 800, 806.)
This bill would make construction contactors the first exception
to the rule. If the bill becomes law it should be anticipated
that other licensees will come forward with similar requests.
However, each exception should be examined independently.
In 1995, SB 513 (Calderon, Ch. 679, Stats. 1995) authorized the
establishment of limited liability partnerships (LLPs) for
licensed attorneys and licensed accountants, provided the LLP
purchased a liability insurance policy or maintained bank
deposits of at least $100,000 per limited liability partner (or
an aggregate of not less than $500,000 for fewer than five
partners and not more than $5 million for all others). Only
partnerships with a net worth of $10 million or more were
allowed to become LLPs. In 1998, the statute allowing
professional LLPs (Bus. & Prof. Code Sec. 16956) was extended to
architects, under the same conditions as accountants and
attorneys, for a trial period of ten years (AB 469, Cardoza, Ch.
504, Stats. 1998). In 2006, the repeal date for architects was
extended to 2012 and the liability coverage requirement was
increased to $1,000,000 for partnerships of five or fewer
licensees, and an additional $100,000 per additional licensee up
to a maximum of $5,000,000. (AB 2914, Leno, Ch. 426, Stats.
2006.) In 2007, SB 414 (Corbett, Ch. 80, Stats. 2007) updated
the liability coverage requirement for accountants and attorneys
to that applicable to architects. To date, only attorneys,
accountants, and architects are permitted to operate as LLPs
under the conditions specified for liability coverage.
Prior Unsuccessful Legislative Proposals To Authorize LLCs To
Engage In Licensed Activities. This bill would authorize the
Contractors State License Board to issue a license to provide
construction services to an LLC that meets requirements provided
in the bill. In 2008 SB 1337 (Correa) would have done the same,
but without requiring the LLC to provide any additional
liability coverage in the event of damages to a consumer. That
bill died in the Senate Judiciary Committee.
SB 392
Page 11
According to the author, there was at least one prior effort
like SB 392. In the 1995-1996 session AB 2401 (Miller), sought
to allow contractors to operate as limited liability companies.
That bill was later broadened to include several other
industries and ultimately died in the Senate Judiciary
Committee.
Last session, SB 1225 (Harman, Ch. 114, Stats. 2008) allowed a
private cemetery that is an LLC to operate as a licensed
cemetery authority to own the cemetery and to provide services
by professionals licensed under the Business & Professions Code.
SB 1225, however, prohibited licensees of professional services
rendered in connection with the operations of a cemetery
authority from having any ownership interest in the LLC.
If SB 392 is enacted, contractors would be the first of 54
professional and semi-professional licensee groups that, until
now, could not be a LLC providing those services.
Liability Insurance Required Based On Number of LLC Members,
Rather Than Size of Company. This bill requires a LLC to
provide security for claims by obtaining liability insurance
with a total aggregate limit of $1 million for a limited
liability company that employs five or fewer licensed persons,
and an additional $100,000 of insurance for each additional
person up to $5 million dollars in any one designated period for
a LLC that employs more than five licensees rendering
professional services on behalf of the company. A "designated
period" means a policy year or period less than 12 months.
It might be noted that the number of LLC members is a highly
imprecise measure for assessing potential liability exposure
because a large construction company organized as an LLC may
have only a few owners. Unlike lawyers and accountants whose
capacity to injure others is related to the number of practicing
members, it would appear that the number of LLC members may be
largely unrelated to the scope of potential injury a
construction LLC may cause.
Net Worth Requirement. The bill does not propose to change the
existing rule that individuals seeking a contractor's license
show evidence of minimal solvency - i.e., operating capital of
greater than $2,500. By contrast, where other entities where
individuals are shielded from personal liability are permitted
to engage in licensed activities, net worth requirements are
SB 392
Page 12
substantially higher. Supporters of this bill believe that the
bond required by this bill will ensure that any licensed LLC
will have substantial assets.
The practice with respect to corporations generally is based on
transparency - publicly traded companies must make certain
filing statements that contain basic information about corporate
assets to which a consumer or employee could obtain access
before transacting business or agreeing to perform labor. There
are no such transparency or access obligations with respect to
LLCs.
For businesses other than corporations, there are minimum net
worth requirements in many cases where the business is engaged
in a licensed activity. Thus, current law authorizes attorneys,
accountants, and architects to organize themselves as LLPs and
to provide professional services, so long as the LLP maintains a
net worth of at least $10 million, and obtains liability
insurance coverage or maintains bank deposits of $1 million for
partnerships of five or fewer licensees and an additional
$100,000 for each additional licensee up to a maximum of $5
million for all others. These figures were updated last year by
SB 414 (Corbett). Limited liability partnerships are required
to register with the Secretary of State, and LLP partners are
only personally liable for those torts in which they personally
participated and are not jointly and severally liable for any
other torts or debts of the partnership.
Similarly, under the Financial Code an escrow agent shall
maintain at all times a tangible net worth of fifty thousand
dollars ($50,000), including liquid assets of at least
twenty-five thousand dollars ($25,000) in excess of current
liabilities; licensed finance lenders and brokers must maintain
a net worth of at least twenty-five thousand dollars ($25,000);
to obtain a license to make deferred deposit transactions, an
applicant must have a net worth of at least twenty-five thousand
dollars ($25,000); residential mortgage lenders shall maintain a
minimum tangible net worth at all times of two hundred fifty
thousand dollars ($250,000). Business and industrial
development corporations moreover must demonstrate net worth of
at least $1.5 million to obtain a license from the Commissioner
of Financial Institutions. Under the Insurance Code, each
broker-agent of fire and casualty insurance shall have a net
worth of at least five million dollars ($5,000,000).
SB 392
Page 13
Potential To Pierce Veil Of LLCs As With Corporations. Under
the Beverly-Killea LLC Act, no person who is a manager or
officer or both a manager and officer of an LLC is personally
liable for any debts, judgments, or obligations of the LLC. A
manager may however agree to be personally liable if this is set
out in the LLC's articles of organization or other writing.
(Corp. Code Sec. 17158.) As to the personal liability of other
members of the LLC, the LLC Act is silent. Thus, it is not
clear that it would be easy to reach assets of LLC owners, who
benefit from the tax advantages as well as the shield provided
to their personal assets in the course of managing their
business with much less formalities than a corporation, to
remedy wrongs done to consumers or others. SB 392 would remove
this uncertainty by noting that it is the intent of the
Legislature that this doctrine should apply to LLCs, and by
specifying that when the LLC's license has been suspended
members are liable for up to $1,000,000 in damages during that
period.
This measure states the Legislature's intention that an
aggrieved person may recover against the members of an LLC as
they now can against a corporation under the doctrine known as
"piercing the corporate veil." Cases involving LLC
veil-piercing have just recently reached the higher courts of
other states that have had LLC statutes longer than California.
These cases hold that veil-piercing liability may be the same
for members of LLC's as for shareholders in a corporation (See,
e.g., Kaycee Land and Livestock v. Flahive, 2002 WY 73
(Wyo.2002)) especially if there was an inadequate capitalization
and representations that other entities would be responsible for
the LLC's debt. Because there is not yet comparable case
authority under California law, the bill provides an added
precaution in the form of a $100,000 wage bond for the benefit
of workers who might otherwise be without sufficient protection.
Author's Technical Amendments. In order to correct drafting
errors, the author appropriately proposes to amend the bill as
follows:
Amend Section 1 so that it reads as follows:
(d) Construction contractors have been allowed to be licensed
operate as corporations, and to be designated as an "S" or "C"
corporation for many years, with well-established case law
regarding the ability to pierce the corporate veil. It is the
SB 392
Page 14
intent of the Legislature that this doctrine shall also apply to
limited liability companies. Because there is not yet case law
establishing this principle in California, the (e) An additional
one-hundred-thousand-dollar ($100,000) bond requirement for the
benefit of paying wages and fringe benefits will ensure that
workers are protected despite in the absence of case law dealing
with limited liability corporations , specifically on the issue
of piercing the corporate veil.
Replace the current language of section 43 with the following:
The Contractors State License Board shall begin processing
applications for licensure from limited liability companies,
pursuant to Chapter 9 of Division 3 of the Business and
Professions Code as amended by this act, no later than January
1, 2012.
The author and sponsors acknowledge that the current version of
the bill contains additional drafting errors, including
ambiguous and inconsistent usage of the undefined term
"responsible managing manager." The sponsor indicates that the
term is intended to cover "responsible managing employees," an
existing defined term in the contractors licensing statute.
However, the terms are not used consistently, and there appear
to be various omissions. The author and sponsor have committed
to work with the Committee to address these and other issues as
the bill moves forward.
REGISTERED SUPPORT / OPPOSITION :
Support
Associated General Contractors of California (co-sponsor)
Associated General Contractors of San Diego (co-sponsor)
Associated Builders and Contractors
California Fence Contractors Association
California Landscape Contractors Association
Engineering and Utility Contractors Association
Engineering Contractors Association
Flasher/Barricade Association
Golden State Builders Exchanges
Marin Builders Association
State Building & Construction Trades Council
SB 392
Page 15
Opposition (as amended)
None on file
Analysis Prepared by : Kevin G. Baker / JUD. / (916) 319-2334