BILL ANALYSIS                                                                                                                                                                                                    



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          Date of Hearing:   July 9, 2009

                           ASSEMBLY COMMITTEE ON JUDICIARY
                                  Mike Feuer, Chair
                       SB 660 (Wolk) - As Amended: July 8, 2009

                              As Proposed to Be Amended

           SENATE VOTE  :   23-15
           
          SUBJECT  :   Reverse Mortgages

           KEY ISSUES  :

          1)Should a person or entity that sells reverse mortgages owe to  
            the prospective borrower a duty of honesty, good faith, and  
            fair dealing?

          2)Should, AS IS ALSO REQUIRED IN ab 329 (fEUER), a person who  
            seeks a reverse mortgage be provided with a checklist  
            highlighting certain subjects that the borrower should discuss  
            with an HUD-certified reverse mortgage counseling agency? 

           FISCAL EFFECT  :  As currently in print this bill is keyed  
          non-fiscal. 

                                      SYNOPSIS 

          Consistent with AB 329 (Feuer), this bill seeks to give greater  
          consumer protections to senior citizens considering a reverse  
          mortgage.  Reverse mortgages give persons of retirement age and  
          with limited income the opportunity to stay in their homes while  
          converting home equity into tax-free income or lump some  
          payments.  Unlike a conventional "forward" mortgage where the  
          borrower makes payments to the lender to bring down debt and  
          increase equity, in a reverse mortgage the lender makes payments  
          to the borrower so that debt increases and equity decreases.   
          While this is a valuable option for many seniors, reverse  
          mortgages are not for everyone.  Many seniors reportedly obtain  
          mortgages that they may not need, and both consumer advocates  
          and senior groups agree that such mortgages are risky when  
          combined with annuities and other insurance products.  As a  
          result, the author contends, seniors are losing equity in their  
          homes.  This bill seeks to address this problem in two ways.   
          First, it imposes on any person who sells reverse mortgages "a  








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          duty of honesty, good faith, and fair dealing."  Second, it  
          would require enhanced disclosures to prospective borrowers,  
          including a requirement that borrowers and counselors consider  
          and sign a prescribed checklist highlighting the risks of  
          reverse mortgages and alternative means of meeting financial  
          needs. The bill is sponsored by senior and consumer advocates.   
          It is opposed by organizations representing lending  
          institutions, primarily on the grounds that the "duty" created  
          by this bill is not clearly enough defined to provide guidance  
          to lenders and will likely lead to increased litigation.  The  
          prior Committee amended the "duty" provision to specify that  
          compliance with all statutory requirements pertaining to reverse  
          mortgages may be cited as evidence of meeting of the duty of  
          honesty, good faith, and fair dealing.  It does not appear,  
          however, this amendment will remove the opposition.   

           SUMMARY  :  Provides that a person or entity that sells reverse  
          mortgages owes to the prospective borrower a duty of honesty,  
          good faith and fair dealing, and prohibits a lender from  
          accepting a reverse mortgage application unless the borrower and  
          counselor complete a prescribed checklist relating to the risks  
          of, and alternatives to, reverse mortgages.  Specifically,  this  
          bill  :   

          1)Provides that a lender, broker, person, or entity who  
            recommends the purchase of a reverse mortgage in anticipation  
            of financial gain owes to the prospective borrower a duty of  
            honesty, good faith and fair dealing.  Specifies that the  
            codification of this duty in this bill does not limit or  
            narrow any other legal duty.  Specifies further that  
            compliance with the provisions of the reverse mortgage statute  
            and all other applicable law may be cited as evidence in  
            support of compliance with the duty. 
          
          2)Specifies that a lender, broker, person, or entity shall not  
            be deemed to have breached the duty set forth above based  
            solely on the acts or omissions of the counseling agency. 

          3)Provides that no reverse mortgage loan shall be taken by a  
            lender unless the loan applicant, prior to receiving  
            counseling, has received from the lender a prescribed form  
            advising the borrower about the need to obtain counseling and  
            stating that a reverse mortgage is a complex, legally binding  
            transaction with important implications for the borrower's  
            estate. 








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          4)Requires, in addition to the notice required above, that the  
            prospective borrower receive, prior to counseling, a written  
            checklist that conspicuously alerts the prospective borrower  
            to all of the following:

             a)   How unexpected medical and other events that cause the  
               borrower to move out of the home earlier than expected will  
               impact the cost of the loan.
             b)   The extent to which the prospective borrower's financial  
               needs would be better met by options other than a reverse  
               mortgage, including, but not limited to, less costly home  
               equity lines of credit, property tax deferral programs, or  
               governmental aid programs. 
             c)   Whether the prospective borrower intends to use the  
               proceeds of the reverse mortgage to purchase an annuity or  
               other insurance products and the consequences of doing so. 
             d)   The effect of the loan on residents who are not  
               borrowers after all borrowers have died or permanently left  
               the home. 
             e)   The prospective borrower's ability to finance routine or  
               catastrophic home repairs, especially if maintenance is a  
               factor that determines when the mortgage becomes due. 
             f)   The impact that the reverse mortgage may have on the  
               prospective borrower's tax obligations, eligibility for  
               government assistance programs, and the effect that losing  
               equity in the home will have on the borrower's estate and  
               heirs. 
             g)   The ability of the borrower to finance alternative  
               living accommodations such as assisted living or long-term  
               care nursing home residency, after the borrower's equity is  
               depleted. 

          5)Provides that the checklist required above be signed by the  
            agency counselor and by the prospective borrower and returned  
            along with a required counseling certification, as specified.   
            Provides that the loan shall not be completed until the signed  
            checklist is provided to the lender.  Specifies that a copy of  
            the checklist shall also be provided to the borrower. 

           EXISTING FEDERAL LAW  : 

          1)Establishes, within the United States Department of Housing  
            and Urban Development (HUD), the Home Equity Conversion  
            Mortgage (HECM) program to provide federal insurance for  








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            reverse mortgages that meet HUD requirements.  Makes the HECM  
            loan available to persons 62 years of age and older and  
            provides that the loans, made against home equity, shall not  
            come due until the borrower(s) dies, moves out of the home  
            permanently, or sells the home.  Provides, however, that loan  
            may become due earlier if the borrower(s) fails to pay  
            property taxes or to maintain the home, as specified in the  
            loan agreement.  Provides that at the time the loan comes due,  
            the property shall be sold to retire the loan amount with any  
            residue returning to the estate or heirs of the borrower.   
            Requires any prospective heir to satisfy the lender's lien  
            before taking title to the property.  (12 USC Section 1715z-20  
            et seq.; 12 CFR Section 226.33.) 

          2)Requires that all applicants for an insured HECM loan receive  
            adequate counseling from an independent third party that is  
            not, either directly or indirectly, associated with or  
            compensated by the lender, loan originator, or loan servicer,  
            or by any party associated with the sale of annuities,  
            investments, long-term care insurance, or any other type of  
            financial or insurance product.  Requires the lender, at the  
            time of initial contact, to provide the borrower with a list  
            of approved HUD counseling agencies.  (12 USC Section 1715z-20  
            (d) (2); 24 CFR 206.41.)  

          3)Requires all HECM loan counselors to be approved by HUD and  
            meet HUD standards, as specified.  Further requires the HUD  
            Secretary to develop uniform counseling protocols by July 30,  
            2009.  Protocols shall require a qualified counselor to  
            discuss, generally, financial options other than a reverse  
            mortgage, the financial implications of reverse mortgages,  
            including any tax consequences, or the affect of the loan on  
            eligibility for government assistance programs.  (12 USC  
            1715z-20 (f) (1)-(5); 24 CFR Section 214.103.) 

          4)Prohibits the lender or any person involved in the origination  
            of the HECM from participating in, being associated with, or  
            employing any party that participates in the sale of other  
            financial or insurance products, unless the lender or  
            originator maintains firewalls and other safeguards designed  
            to ensure that individuals participating in the origination of  
            the HECM loan shall have no involvement with, or incentive to  
            provide the borrower with, any other financial or insurance  
            product.  Specifies that a prospective borrower shall never be  
            required to purchase any other financial or insurance product  








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            as a condition of obtaining a reverse mortgage.  (12 USC  
            1715z-20 (n)-(o).) 

           EXISTING STATE LAW  :   

          1)Defines "reverse mortgage" as a non-recourse loan secured by  
            real property that meets all of the following criteria:

             a)   The loan provides cash advances to a borrower based on  
               the equity or value in a borrower's owner-occupied  
               principal residence.
             b)   The loan requires no payment of principal or interest  
               until the entire loan becomes due and payable.
             c)   The loan is made by a lender licensed or chartered  
               pursuant to the laws of this state or the United States.   
               (Civil Code Section 1923.) 

          2)Establishes, consistent with federal HECM requirements, but  
            applicable to both HECM and non-HECM loans, certain  
            requirements for reverse mortgage loans, including a  
            prohibition on prepayment penalties and interest rate  
            disclosure requirements.  (Civil Code Section 1923.2.)

          3)Prohibits a lender from requiring the prospective borrower  
            from requiring the purchase of an annuity as a condition of  
            obtaining a reverse mortgage.  Provides further that a lender  
            or broker arranging a reverse mortgage loan shall not (a)  
            offer an annuity to the borrower prior to the closing of a  
            reverse mortgage or any right of rescission or (b) refer the  
            borrower to anyone for the purchase of an annuity prior to the  
            closing of the reverse mortgage.  (Civil Code Section 1923.2  
            (i).) 

          4)Requires the lender to refer the prospective borrower, prior  
            to accepting a final and complete application for a reverse  
            mortgage, to a HUD-approved counseling agency.  Further  
            requires the lender to provide the prospective borrower with a  
            list of at least five HUD-approved counseling agencies, at  
            least two of which provide counseling by telephone.  Further  
            provides that the lender shall not accept a final application  
            or assess any fees upon the borrower without first obtaining a  
            certification that the prospective borrower has received  
            counseling from a HUD-approved counselor, and that the  
            certification is signed by both the borrower and the  
            counselor, as specified.  (Civil Code Section 1923.2 (j).) 








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          5)Requires, consistent with Civil Code Section 1632, that if the  
            reverse mortgage is negotiated primarily in Spanish, Chinese,  
            Tagalog, Vietnamese, or Korean, that the lender must provide a  
            written translation of the agreement in the language in which  
            the contract or agreement was negotiated, as specified.   
            (Civil Code Sections 1923.2 (l) and 1632(b).) 

          6)Requires the lender to provide an applicant for the reverse  
            mortgage with a plain language statement in conspicuous  
            16-point font type or larger notifying the applicant that a  
            reverse mortgage is a complex financial transaction that uses  
            the acquired equity in the home and informs the borrower of  
            the independent counseling requirement.  (Civil Code Section  
            1923.5.) 

          7)Provides, to the extent consistent with federal law, that  
            reverse mortgage loan payments shall be treated as proceeds  
            from a loan and not as income for the purpose of determining  
            eligibility and benefits under means-tested programs of aid to  
            individuals.  (Civil Code Section 1923.9.)  

          8)Provides that all insurers, brokers, agents, and others  
            engaged in the transaction of insurance owe a prospective  
            borrower insured who is 65 years of age or older, a duty of  
            honesty, good faith, and fair dealing.  Specifies that this  
            duty is in addition to any other duty, whether express or  
            implied, that may exist.  (Insurance Code Section 785.) 

           COMMENTS  :  The last decade has seen an explosion in the reverse  
          mortgage market.  Reverse mortgages allow persons 62 years of  
          age of older to convert home equity into tax-free monthly income  
          or a lump sum cash payment to spend as they wish.  In a  
          conventional "forward" mortgage, the borrower makes payments to  
          the lender so that debt decreases and equity increases.  In a  
          "reverse" mortgage, the lender makes payments to the borrower so  
          that debt increases and equity decreases.  The borrower  
          generally does not repay the loan until the last borrower dies,  
          sells the home, or moves out.  However, a lender may demand  
          repayment if the borrower fails to pay property taxes or allows  
          the home to fall into disrepair.  Most reverse mortgages are  
          insured by the Federal Housing Administration (FHA) through the  
          Home Equity Conversion Mortgage (HECM) program administered by  
          the U.S. Department of Housing & Urban Development (HUD).  These  
          federally-backed loans must meet certain requirements, including  








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          independent third party counseling by a HUD-approved housing  
          agency.  Though fewer in number, so-called "proprietary" reverse  
          mortgages are not federally insured and are not subject to the  
          same restrictions and requirements as the HECM loans. Yet, for  
          the most part, they operate the same way: the borrower receives  
          payments against the home equity, and the loan generally does  
          not become due until the borrower dies, moves out, or sells the  
          home. 

          For many "cash poor, equity rich" seniors, a reverse mortgage  
          often appears to make good economic sense.  But reverse  
          mortgages can also be very costly.  In addition to  
          higher-than-usual origination fees, closing costs, compound  
          interest, and servicing fees, the borrower is also required to  
          pay an insurance premium (worth about 2% of the loan) that  
          protects the lender in case the value of the property falls  
          below the amount owed on the loan.  The total annual cost of a  
          reverse mortgage is generally much greater the shorter the loan  
          period.  For example, the hoped-for advantages of a reverse  
          mortgage backfires if a senior becomes ill or takes a fall and  
          is forced to move out of the home early.  Leaving the home makes  
          the loan come due, and the senior must repay the high up-front  
          costs and compounded interest while having received little or no  
          benefit.  

          Often, according to groups like AARP and Consumers' Union,  
          senior citizens are unaware that their financial needs may be  
          better met by alternative and less costly means.  For example,  
          for smaller and immediate needs, the borrower can obtain a home  
          equity line of credit.  If the senior is obtaining a reverse  
          mortgage in order to pay property taxes, they may not be aware  
          of local and state property tax deferral programs available to  
          seniors with fixed incomes.  Finally, where a senior lacks funds  
          to pay for increased medical costs, they may be eligible for  
          other forms of government aid, including Medi-Cal.  While  
          reverse mortgages often provide a valuable tool for some senior  
          citizens, there are often more appropriate alternatives.  AARP,  
          for example, while generally praising the benefits of reverse  
          mortgages in appropriate situations, generally recommends  
          exploring all other options before obtaining mortgages that may  
          not be needed and will eventually deplete home equity.   
          Moreover, AARP advises that using reverse mortgage proceeds to  
          buy annuities or invest in other products is almost never a good  
          idea.  Even some lending institutions are reportedly in  
          agreement that reverse mortgage proceeds should not be used to  








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          invest in other financial products; yet the practice continues,  
          as numerous reports and law suits attest.

           The Growth of the Reverse Mortgage Market and Previous  
          Legislative Responses  :  Although proprietary reverse mortgages  
          in some form or another have been around since at least the  
          1960s, it was not until the development of the federal HECM  
          reverse mortgages in the late 1980s and early 1990s that they  
          became well known.  However, the federal program remained  
          relatively small and stagnant until 2003, when the number of  
          reverse mortgages suddenly sky-rocketed and became the fasting  
          growing sector of the mortgage lending industry.  The reason for  
          this rapid growth is not entirely clear, though most reports  
          point to more aggressive marketing; rising home values; the  
          aging of the population; and the collapse of the sub-prime  
          lending crisis pushing brokers, lenders, and loan originators  
          into the reverse mortgage market.  (See e.g. "Demand for Reverse  
          Mortgages Climbs," Wall Street Journal, January 22, 2009; "Shady  
          Subprime Lenders Creeping into Federal Mortgage Program,"  
          Financial Week, January 12, 2009; "Reverse Mortgages: Bad Rap or  
          Bad Idea?, San Francisco Chronicle, August 1, 2008.)  While this  
          growth may be subject to fluctuations, overall growth is  
          expected to continue as the population ages. 

          The first response to this growth in California came with the  
          enactment of AB 456 (Chapter 797, Stats. of 1997), which defined  
          "reverse mortgage" and set out minimum requirements that more or  
          less mirrored then-prevailing federal requirements.  (Civil Code  
          Section 1923 et seq.)  While the federal requirements applied  
          only to the HECM loans, the California provisions apply to both  
          federally-backed and so-called proprietary loans that are not  
          subject to HECM requirements.  More recently AB 1609 (Chapter  
          202, Stats. of 2006) added counseling requirements and  
          restrictions concerning bundling reverse mortgages and annuities  
          (at least until after the closing and any right of rescission),  
          that again mirrored federal regulations but applied to HECM and  
          proprietary loans.

          This bill seeks to further advance state regulation of the  
          reverse mortgage market in two ways: First, it states that any  
          lender, broker, or person who sells reverse mortgages owes to  
          the prospective borrower "a duty of honesty, good faith, and  
          fair dealing."  Second, as is the case with AB 329 (Feuer), it  
          enhances existing notice requirements in state law and requires  
          that prospective borrowers must be provided with a "checklist"  








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          that alerts them to the risks of and alternatives to reverse  
          mortgages.  The borrower is instructed to go over this list with  
          a certified counselor, and the checklist must be signed by both  
          the borrower and the counselor before the reverse mortgage loan  
          application can be completed.  Because the checklist provision  
          of this bill is substantially similar to AB 329, which was  
          already heard by the Committee, the remainder of this analysis  
          will focus on the "duty" issue. 

           What is a Duty of Honesty, Good Faith, and Fair Dealing?   The  
          "duty" language in this bill is closely modeled on Insurance  
          Code Section 785, which imposed upon persons who sold insurance  
          products to persons 65 years of age or older "a duty of honesty,  
          good faith, and fair dealing."  The logical connection between  
          that provision and this bill seems fairly obvious: both seek to  
          create a heightened duty among persons who sell complex  
          financial products to elderly persons.  Other places in  
          California law make the assumption that people who engage in  
          commercial and financial transactions with elderly persons are  
          held to a higher ethical standard, as is implicit in the state  
          Financial Elder Abuse statute and in Insurance Code Section 786,  
          which gives persons over 65 years of age 30 days to rescind an  
          insurance policy.  These laws do not necessarily reflect a  
          paternalistic assumption that senior citizens inevitably have  
          difficulty understanding complex financial transactions; it is  
          simply a frank acknowledgment that some elderly persons  
          experience cognitive changes, as well as changed living  
          situations, which make them more vulnerable to certain marketing  
          techniques.  Existing law clearly recognizes that senior  
          citizens deserve something more protective than caveat emptor  
          and the unrestrained selfishness of the marketplace. 

          As noted below, opponents allege that "honesty, good faith, and  
          fair dealing" are such vague and ill-defined terms that they  
          provide no guidance to persons who must comply with the law and  
          will provide an open invitation for litigation.  However, terms  
          like "good faith" and "fair dealing" have been used for  
          centuries in both common law and statute.  All contracts, for  
          example, presume a "covenant of good faith and fair dealing,"  
          yet this does not inhibit people from making contracts nor  
          prevent courts from determining whether a party to a contract  
          has breached the implied covenant of good faith and fair  
          dealing.  But perhaps even more telling, the Insurance Code has  
          imposed a duty of honesty, good faith, and fair dealing on  
                                              persons selling insurance to the elderly for nearly 20 years and  








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          there is no evidence that this has led to a litigation  
          explosion.  Nor is there any evidence that the duty in the  
          Insurance Code has had any chilling effect on the selling of  
          insurance to persons 65 years of age or older.  

          Opponents are correct that the bill does not provide any  
          examples of what specific kinds of actions on the part of a  
          lender might constitute a breach of the duty of honesty, good  
          faith, and fair dealing.  However, this is not the first time  
          that a statute has codified accepted common law terminology, and  
          statutes by their very nature tend to be general, since  
          legislation cannot possibly anticipate every possible instance  
          that would constitute a violation.  In codifying a common law  
          rule, a legislature does not prescribe or prohibit specific  
          kinds of conduct so much as it sets forth general principles by  
          which parties are expected to conduct themselves.  Insurance  
          Code Section 785, after which the duty provision in this bill is  
          modeled, implies that persons who sell financial products owe a  
          higher duty of care to senior citizens than they do to other  
          customers; otherwise, there would have been no reason for adding  
          this language into the Insurance Code.  Even if the provision  
          was simply an attempt to codify the existing common law covenant  
          that already applies to all contracts, there would be no reason  
          to apply it only to contracts involving senior citizens.  It is  
          a standard principle of statutory interpretation that words are  
          not meant to be superfluous, but are added for a reason.  The  
          duty created by this statute, like the similar duty in the  
          Insurance Code, would seem to mean that, at a minimum, a person  
          selling financial products to senior citizens should not take  
          undue advantage of the buyer's age.  It would seem to mean, at a  
          minimum, that the seller not try to push a product on a senior  
          citizen without having some reasonable belief that the senior  
          citizen will derive a benefit.  No doubt the vast majority of  
          the lenders represented by the opponents conduct themselves in a  
          manner that meets this modest duty, but one can find facts in  
          news reports and trial court pleadings to suggest that not all  
          lenders do so.  (See e.g. Assembly Judiciary Committee, Analysis  
          of AB 329.  April 21, 2009.) 

          There is nothing new about imposing heightened duties on those  
          who sell financial products, including mortgages.  For example,  
          in 1979 the California Supreme Court held that, even in the  
          absence of a statute, mortgage loans brokers are expected to  
          fully and accurately disclose all terms to borrowers and "to act  
          always in the utmost good faith toward their principals."   








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          (Wyatt v. Union Mortgage Company (1979) 24 Cal. 3d 773.)  This  
          bill appears to recognize that these other kinds of duties  
          exists, which is presumably why the bill states that the duty it  
          sets forth does not limit "any other duty" that a lender or  
          broker may have.  That is, brokers who sell reverse mortgages,  
          under the Wyatt holding, may already have a higher, fiduciary  
          duty to borrowers that goes beyond a "duty of honesty, good  
          faith, and fair dealing."  

           Contract and Tort Remedies For Breach of Covenant of Good Faith  
          and Fair Dealing  :  At common law, every contract imposes upon  
          each party an "implied covenant of good faith and fair dealing."  
           (Restatement 2d Contracts, Section 205.)  This bill apparently  
          seeks to codify this duty with respect to the sale of reverse  
          mortgages, albeit with the added requirement of "honesty."  In  
          contract law, the breach of the covenant of good faith and fair  
          dealing would generally void the contract and entitle the  
          non-breaching party to compensatory damages or restitution.  As  
          a matter of contract law, damages would be "determined by the  
          nature of the breach and standard contract principles."  (Foley  
          v. Interactive Data Corp. (1988) 47 Cal. 3d 654, 683-84.)  In  
          the case of a reverse mortgage, this could possibly mean  
          rescission of the contract and return of loan fees, as a court  
          deemed appropriate given the nature of the breach.  In the  
          Banking & Finance Committee, however, opponents claimed that the  
          duty provision in this bill might also entitle a prevailing  
          plaintiff to damages in tort, which might include damages for  
          "pain and suffering" and possibly punitive damages as well. 

          While it is true that tort damages are generally more expansive  
          than contract damages, it is not clear that a court would award  
          tort damages under the duty created by this bill.  As the  
          California Supreme Court has noted, damages for breach of the  
          covenant of good faith and fair dealing are generally determined  
          by contract principles,  except  "in the context of insurance  
          contracts."  (Id. at 684.)  The exception for insurance  
          contracts in large measure reflects the "special" or "fiduciary"  
          nature of the insurer-insured relationship.  (See e.g. Id. at  
          684-685; Gruenberg v. Aetna Ins. Co. (1973) 9 cal 3d 566, 575;  
          and Direct Buying Service v. Standard Oil (1984) 36 Cal. 3d 752,  
          768-769 (stating that the propriety of a tort action for breach  
          of the implied covenant was rooted in the "special relationship"  
          of insurer and insured.)  However, the court has been reluctant  
          to extend this reasoning beyond the insurance context.  Indeed,  
          in Foley v. Interactive Data Corp (1988), the majority affirmed  








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          a lower court dismissal of a claim for tort damages for breach  
          of the covenant in an employment contract.  In doing so, the  
          court expressly rejected the reasoning of a handful of appellate  
          court opinions that permitted tort damages in breach of  
          employment contract cases.  The court reasoned that the  
          application to the insurance context was already a "major  
          departure from traditional principles of contract law," and that  
          the court should "consider with great care" claims seeking to  
          extend that exceptional approach to other contexts.  (Foley,  
          supra at 690; see also Cates Construction v. Talbot Partners  
          (1999) 21 Cal 4th 28, 44 (refusing to extend remedy for tortuous  
          breach to performance bonds for reasons similar to those  
          articulated in Foley.)  Indeed, more recently the California  
          Supreme Court has even refused to apply tort remedies to some  
          insurance contracts if the nature of the breach did not warrant  
          it. (Jonathan Neil & Associates v. Jones (2004) 33 Cal. 4th 917,  
          refusing to apply tort remedies when the insurance company's  
          breach involved premium overcharges rather than denial of  
          coverage.) 

          In short, it appears that a court would only permit the  
          additional damages available in an action in tort under the duty  
          codified in this bill if it construes the relationship between  
          the lender and borrower as a "special relationship" akin to the  
          fiduciary relationship between insurer and insured.  Thus far,  
          as opponents themselves have noted, the courts have not  
          construed the lender-borrower relationship as a fiduciary  
          relationship. 
           
          How does the duty created by this bill compare to a "fiduciary  
          duty"  ?  The Assembly Banking & Finance Committee analysis raised  
          a concern that the duty created in this bill might effectively  
          become a fiduciary duty, even without using that precise term.   
          However, the duty of "good faith" or "fair dealing," as used in  
          existing law, has never been assumed to rise to the level of a  
          fiduciary duty.  Although a fiduciary duty certainly presumes  
          honesty, good faith, and fair dealing as a baseline requirement,  
          the fiduciary duty also implies much more than this.  A  
          fiduciary is expected to consider the best interest of the  
          person to whom the duty is owed and, when conflicting, to put  
          the interest of that person ahead of the fiduciary's own  
          interests.  According to the Wyatt rule, noted above, a licensed  
          "broker," who acts as the agent of his or her client, owes that  
          client a fiduciary duty.  However, licensed brokers are not  
          always involved in reverse mortgages transactions.  Thus one  








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          apparent purpose of this bill is to ensure that all "persons"  
          who sell reverse mortgages, whether "brokers" or not, owe a  
          heightened duty to prospective borrowers, though clearly not a  
          fiduciary duty.  A court would likely conclude that if the  
          Legislature had intended to create a fiduciary duty, it could  
          have said so.  (Indeed, that an earlier version of the bill did  
          say so demonstrates that the subsequent rejection of a fiduciary  
          duty was self-conscious and purposeful.) 

           Recent Amendments to Duty Provision  :  This bill was originally  
          scheduled to be heard on June 29th in the Assembly Banking &  
          Finance Committee and on June 30th in this Committee.  However,  
          the prior Committee put the bill over an additional week to  
          consider amendments to the duty provision.  Opponents originally  
          requested an amendment that would have stated that compliance  
          with the reverse mortgage statute would create a "rebuttable  
          presumption" that a person has met the duty of honesty, good  
          faith, and fair dealing.  However, the author believed that such  
          an amendment would at best negate the duty provision and, at  
          worst, would have permitted bad faith compliance.  The proposed  
          amendment, in other words, ignored the possibility that a person  
          could comply with the technical requirements of the statute  
          while still acting without honesty, good faith, or fair dealing.  
           

          As a compromise effort, the author agreed to an amendment that  
          would allow a lender to cite compliance as evidence of meeting  
          the duty of honesty, good faith, and fair dealing.  That is, the  
          "rebuttable presumption" favored by the opponents would have  
          created a presumption that compliance automatically sufficed to  
          meet the duty, unless the person alleging the breach of the duty  
          could show evidence to rebut.  The author's proposed amendment,  
          however, would allow a person offering a reverse mortgage to  
          cite compliance with the statute as  evidence  of meeting the duty  
          without necessarily creating a conclusive presumption that the  
          duty had been met.  Specifically, the recent amendment reads as  
          follows:

             1923.1. (a) Any lender, broker, person, or entity who  
             recommends the purchase of a reverse mortgage in  
             anticipation of financial gain owes the prospective  
             borrower a duty of honesty, good faith, and fair dealing.  
             The duties set forth in this subdivision shall not be  
             construed to limit or narrow any other duty of a lender,  
             broker, person, or entity.  Compliance with this chapter  








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             and all other applicable law may be cited as evidence  
             demonstrating compliance with the duties of this  
             subdivision. 

          Does the Author Wish To Retain the Amendment Taken in the  
          Banking & Finance Committee?  One could argue that the above  
          amendment taken in the Banking & Finance Committee does not add  
          anything to existing law.  That is, a lender or broker would  
          presumably be free under existing law to introduce any evidence  
          that it thought would bolster its defense, including evidence  
          that it had complied with all statutory requirements applicable  
          to the sale of reverse mortgages.  Given that the author only  
          took this amendment in an effort to assuage the opposition - and  
          it has apparently failed to do so - the author and Committee may  
          wish to consider whether the amendment is in fact necessary.  On  
          the other hand, the amendment is surely preferable to having  
          compliance create a "rebuttable presumption" of meeting the duty  
          which, as noted above, arguably renders the duty meaningless as  
          an additional requirement.  The amendment above, which the  
          author agreed to after consultation with the staff of both the  
          Judiciary and Banking and Finance Committees, makes it clear at  
          least that compliance is a prerequisite of the duty, but not the  
          totality of the duty.  The author, it would appear, adopted this  
          amendment because she believes that mere compliance with the  
          letter of the law must be done with honesty, good faith, and  
          fair dealing.  

           Proposed Author Amendment  :  In order to clarify that a lender  
          cannot be liable solely for the acts or omissions of a  
          counseling agency, the author wishes to make the following  
          amendment to proposed subdivision (b) of proposed Section  
          1923.1:

             (b) A lender, broker, person, or entity shall not be deemed  
             to have breeched the duty set forth in subdivision (a)  
             based  solely  on the actions or omissions of the counseling  
             agency pursuant to this chapter.  

          ARGUMENTS IN SUPPORT  :  According to the sponsor, California  
          Advocates for Nursing Home Reform (CANHR), heightened duties for  
          sellers of reverse mortgages are necessary "because reverse  
          mortgages are very complex and expensive loans and, when  
          unsuitable, can devastate a senior's estate plan."  CANHR points  
          out that reverse mortgages are risky, especially when  
          unanticipated, but not uncommon, events occur.  For example,  








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          CANHR, points out that although a reverse mortgage holds out the  
          promise that the senior can stay in the home for the rest of his  
          or her life, without having to make any mortgage payments, a  
          number of unanticipated events can make the mortgage come due.   
          For example, an illness or injury that required long-term  
          nursing care might make the loan come due long before the senior  
          has derived any benefit.  In addition, CANHR claims, many  
          seniors are unaware that the lending institutions can demand  
          payment if the senior citizen fails to adequately keep the home  
          in good repair.  For all of these reasons and more, a senior  
          citizen should consider all possible consequences and less  
          costly alternatives, which the checklist, which must be signed  
          by the counselor and borrower, will force the senior to do.  In  
          addition, the duty provision in this bill will force the lender  
          to give good faith consideration to whether a loan is  
          appropriate in light of the senior's circumstances. 

          Aging Services of California, an association of non-profit  
          providers of senior housing and residential care, argues that  
          the recent sub-prime mortgage crisis and the fact that senior  
          citizens nationwide hold about $4 trillion in home equity should  
          alert us to potential problems that may lie ahead in the reverse  
          mortgage market.  Aging Services suggest that many of the same  
          players that sold the irresponsible mortgages that fueled the  
          sub-prime crisis are moving into the reverse mortgage market.   
          Aging Services stresses, however, that the purpose of this bill  
          is not to prohibit the sale of reverse mortgages.  Instead, this  
          bill offers modest protections, sets forth a minimum standard  
          for sellers and lenders, and creates a useful checklist that  
          will force borrowers to give more consideration to risks and  
          alternatives when discussing their situation with a counselor.   
          "Without such protections," Aging Services concludes, "thousands  
          of seniors will be sold reverse mortgages that radically affect  
          established estate plans, retirement destinations, and even care  
          for dependent children."  Finally, Aging Services writes that  
          its members have encountered many seniors who find that they  
          cannot enter a senior living facility as planned because they  
          have used up the equity in their home through a reverse  
          mortgage.  Without home equity to pay for medical care, seniors  
          "will find themselves on Medi-Cal at taxpayers' expense, an  
          expense that the state cannot afford."  

           ARGUMENTS IN OPPOSITION  :  As noted above, the financial  
          institutions that oppose this bill focus almost exclusively on  
          the bill's "duty of honesty, good faith, and fair dealing."   








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          "Absent clarification," opponents argue, "these ambiguous duties  
          may expose lenders to legal liability and have a chilling effect  
          on the reverse mortgage industry."

          Opponents also point out that existing state and federal law  
          already provides comprehensive consumer protections for reverse  
          mortgage applicants.  The vast majority of these mortgages,  
          opponents claim, are federally insured and covered by strong  
          consumer protections.  Both state and federal law, opponents  
          add, already require that all borrowers receive HUD-certified  
          counseling before a loan application may be completed. 

          Citing the Senate Judiciary Committee analysis, opponents note  
          that the bill does not detail what specific action would  
          constitute a violation of the "duty of honesty, good faith, and  
          fair dealing," and as such, cannot provide any guidance to those  
          who must comply with the provision.  Therefore, opponents claim,  
          the bill creates uncertainty as to "what legal exposure exists  
          for violation of this duty and what the reverse mortgage lender  
          can rely on in order to satisfy the duty of honesty, good faith,  
          and fair dealing.  Absent clear guidance, there is no clear way  
          for a lender to take steps to ensure that they are in compliance  
          with the new duty.  Given the unanswered legal questions and  
          ambiguities, this measure would have a chilling effect on  
          reverse mortgage sales." 

           Pending Related Legislation  :  AB 329 (Feuer) updates  
          California's state reverse mortgage law to incorporate recent  
          changes in federal law relating to conflicts of interest and  
          cross-selling of reverse mortgages with other financial  
          products; ensures that recent federal protections will apply to  
          both federally-backed and non-federally-backed loans in  
          California; enhances notice requirements and, like this measure,  
          requires a checklist that must be signed by both the borrower  
          and a HUD-certified counselor before the loan application can be  
          completed.  (Passed off Assembly Floor by a 68-2 vote and passed  
          out of Senate policy committee.  On Senate floor.) 

           REGISTERED SUPPORT / OPPOSITION  :

           Support 
           
          California Advocates for Nursing Home Reform (sponsor)
          AARP
          Aging Services of California 








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          California Alliance for Retired Americans (CARA)
          California Association of Mortgage Bankers
           
            Opposition 
           
          California Bankers Association
          California Financial Services Association
          California Independent Bankers Association 
          California Mortgage Bankers Association 


           Analysis Prepared by  :    Thomas Clark / JUD. / (916) 319-2334