BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  AB 699
                                                                  Page 1

          Date of Hearing:  March 22, 2011

                          ASSEMBLY COMMITTEE ON JUDICIARY
                                 Mike Feuer, Chair
                 AB 699 (Wagner) - As Introduced:  February 17, 2011

                             As Proposed to be Amended
           
          SUBJECT  :  Non-Probate Transfers: ReVOCABLE TRANSFER UPON DEATH 
          DEEDS

           KEY ISSUES  :   

          1)Should owners of real property be PERMITTED to transfer their 
            property on death outside of probate through a "ReVOCABLE 
            TRANSFER UPON DEATH DEED"?

          2)Might this bill INADVERTENTLY make estate planning more 
            complicated by creating yet another non-probate device WHICH 
            could add CONFUSion to THE ESTATE PLANNING PROCESS and make 
            FINANCIAL abuse easier to commit?

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

                                     SYNOPSIS 

          This bill, following recommendations by the California Law 
          Revision Commission (CLRC), allows owners of real property, 
          until January 1, 2017, to transfer their property upon death, 
          outside the normal probate procedure, through a written 
          instrument known as a "revocable transfer upon death deed" 
          (RTDD).  Very similar bills - AB 250 (DeVore, 2007) and AB 724 
          (DeVore, 2009-10) - unanimously passed out of this Committee 
          and the Assembly, but failed passage in the Senate.

          In 2005, legislation directed the CLRC to study California's 
          non-probate transfer provisions, as well as beneficiary deeds 
          in other states, in order to determine whether California 
          should enact legislation statutorily creating a beneficiary 
          deed.  In recommending creation of an RTDD in California, the 
          CLRC balanced the generally positive, although quite limited, 
          experience of other states, the need for a simple, low-cost 
          method of conveying real property with the very real concerns 
          of possible misuse or abuse raised by opponents of the RTDD.  








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          In order to address some of opponents' well-founded concerns, 
          the CLRC recommends that California undertake a comprehensive 
          review of all non-probate transfers and their consequence.  
          However, in the interim, the CLRC recommends that California 
          establish a carefully crafted RTDD.

          As recommended by the CLRC, this bill establishes a new, 
          non-probate method for conveying real property upon death 
          through an RTDD that is signed and recorded within 60 days of 
          execution.  The RTDD, which requires use of a statutorily 
          created deed, does not affect any ownership rights during the 
          transferor's lifetime nor does it convey any rights to the 
          beneficiary or the beneficiary's creditor during the 
          transferor's lifetime.  It may be revoked at any time by a 
          subsequently recorded document that disposes of the property.  

          In support, the author states that this bill is necessary to 
          "fill a major gap in estate planning instruments available to 
          ordinary citizens, by providing a straightforward, inexpensive, 
          and reliable means of passing real property directly to a 
          beneficiary, to go along with the many options California 
          citizens currently have to pass personal property to their 
          loved ones outside of the long, complicated and expensive 
          probate process.  The bill is particularly intended for the 
          benefit of senior citizens whose estate consists primarily - or 
          even exclusively - of the family home (there are thousands of 
          elderly people throughout the state who are barely getting by, 
          but whose home, purchased long ago and paid off, may be worth 
          several hundreds of thousands of dollars), and unmarried 
          homeowners who wish to leave their home to their partner, loved 
          one, or family member upon death, but do not want to transfer a 
          present ownership interest in the property ."  The bill is 
          co-sponsored by California Communities United Institute and the 
          Conference of California Bar Associations, and supported by 
          AARP and the California Senior Legislature who believe that the 
          bill provides seniors with a simple, no cost method to transfer 
          property to their heirs.
          
          The bill is opposed by the California Land Title Association, 
          the California Escrow Association, and California Advocates for 
          Nursing Home Reform, who argue that the bill inadvertently 
          creates "'drive-by' estate planning that puts California's most 
          vulnerable group - senior citizens - at great risk for personal 
          fraud."  









                                                                  AB 699
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          SUMMARY  :  Seeks to establish, until January 1, 2017, a new, 
          non-probate method for conveying real property upon death 
          through a "revocable transfer upon death deed."  Specifically, 
           this bill  : 
             
          1)Allows an interest in real property to be transferred on 
            death by recording an RTDD signed and acknowledged by the 
            record owner of the property and designating a beneficiary or 
            beneficiaries.  The deed transfers ownership of that property 
            interest upon the death of the owner.  Is effective for any 
            RTDD made by a transferor who dies on or after January 1, 
            2012, regardless of when the RTDD was executed or recorded.  
            No RTDD may be executed on or after January 1, 2017, but any 
            RTDD properly executed before that date remains valid and may 
            be revoked after that date. 

          2)Requires that to be valid an RTDD must be recorded within 60 
            days of execution.

          3)Provides that an RTDD does not affect any ownership rights 
            during the transferor's lifetime and nor does it convey any 
            rights to the beneficiary or the beneficiary's creditors 
            during the transferor's lifetime.  An RTDD is not effective 
            until the transferor's death. 

          4)Provides a statutory form RTDD and requires that an RTDD must 
            be in that form.  The statutory deed provides information to 
            the transferor, including explaining how the RTDD works, how 
            it is effectuated and some of its consequences.  

          5)Provides a statutory form for revocation of an RTDD.

          6)Provides that an RTDD may have multiple beneficiaries, who 
            take in equal shares as tenants in common, but does not 
            provide for alternate beneficiaries.  The RTDD does not 
            provide for class gifts, e.g., gifts to the transferor's 
            unnamed grandchildren.  

          7)Provides that an RTDD is revocable at any time by a 
            transferor with testamentary capacity.  If an RTDD and 
            another revocable instrument have both been recorded and both 
            purport to dispose of the same property, the instrument that 
            has been executed later prevails.  If two deeds - one 
            revocable and one irrevocable - are both recorded, the 
            irrevocable deed prevails, even if recorded earlier.  








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          8)Provides that an RTDD must transfer all the transferor's 
            interest in the property.

          9)Provides that property subject to an RTDD is still part of 
            the transferor's estate for purposes of Medi-Cal eligibility 
            and will be subject to Medi-Cal reimbursement claims.  
            Property subject to an RTDD is subject to claims from the 
            transferor's secured and unsecured creditors.  Allows the 
            beneficiary to avoid unsecured claims by returning the 
            property to the transferor's estate.

          10)Requires the beneficiary to effectuate transfer of the 
            property by recording an affidavit of the transferor's death.

          11)Provides that, if property is held in joint tenancy or as 
            community property with right of survivorship when the 
            transferor dies, the transfer is void and the property passes 
            pursuant to the right of survivorship.  Provides, in the 
            information accompanying the statutory deed, that if a 
            transferor wants to sever the joint tenancy and not have the 
            property pass through right of survivorship rules, the 
            transferor cannot use the RTDD.  

          12)Permits contest of the RTDD for, among other things, lack of 
            capacity to transfer, transfer to disqualified person, fraud, 
            duress, and undue influence.

          13)Requires the CLRC to study the effects of the RTDD and make 
            recommendations to the Legislature by January 1, 2016.

           EXISTING LAW  : 

          1)Directs the California Law Revisions Commission to study the 
            effect of California's non-probate transfer provisions and 
            statutes in other states that establish beneficiary deeds as 
            a means of conveying real property through non-probate 
            transfers, with the objective of determining whether such 
            legislation should be enacted in California.  (AB 12 
            (DeVore), Chap. 422, Stat. 2005.)

          2)Permits the non-probate transfer on death of non-real 
            property instruments including an insurance policy, contract 
            of employment, bond, mortgage, promissory note, certified or 
            uncertified security, account agreement, custodial agreement, 








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            deposit agreement, compensation plan, pension plan, 
            individual retirement plan, employee benefit plan, trust, 
            conveyance, deed of gift, marital property agreement, or 
            other written instrument of a similar nature.  (Probate Code 
            Section 5000.)

          3)Provides that upon death of one joint tenant, real property 
            held in joint tenancy with right of survivorship vests 
            immediately in the surviving joint tenant or tenants.  (Civil 
            Code Section 683.)

          4)Provides for the non-probate transfer of real property 
            insofar as persons may execute a revocable deed to a 
            beneficiary while reserving a life estate.  (Tennant v. John 
            Tennant Memorial Home (1914) 167 Cal. 570.)

          5)Provides that, if a transferee under a will, trust, deed or 
            other instrument fails to survive the transferor, transfer 
            does not lapse but passes to the issue (decedents) of the 
            transferee if the transferee is related to the transferor or 
            the transferor's spouse.  (Probate Code Section 21110.)

           COMMENTS  :  In 2005, the Legislature passed AB 12 (DeVore), 
          Chap. 422, Stat. 2005, which directed the CLRC to study 
          California's non-probate transfer provisions and determine 
          whether California should enact a beneficiary deed - a deed 
          which transfers real property outside of probate upon death of 
          the transferor.  In October 2006, the CLRC issued its 
          recommendation that California adopt a revocable transfer on 
          death deed, noting that while the deed has advantages and 
          disadvantages, creation of such a deed would, on the whole, be 
          beneficial in California.  AB 250 (DeVore, 2007) and AB 724 
          (DeVore, 2009-10) sought to implement the recommendations of 
          the CLRC and create an RTDD in California.  Both bills passed 
          out of the Assembly without a "no" vote, but failed passage in 
          the Senate.  This bill is nearly identical to those bills, 
          except that it does not allow for a life estate as part of an 
          RTDD.

          According to the author:

               Enactment of AB 699 will fill a major gap in estate 
               planning instruments available to ordinary citizens, by 
               providing a straightforward, inexpensive, and reliable 
               means of passing real property directly to a beneficiary, 








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               to go along with the many options California citizens 
               currently have to pass personal property to their loved 
               ones outside of the long, complicated and expensive 
               probate process.   The bill is particularly intended for 
               the benefit of senior citizens whose estate consists 
               primarily - or even exclusively - of the family home 
               (there are thousands of elderly people throughout the 
               state who are barely getting by, but whose home, purchased 
               long ago and paid off, may be worth several hundreds of 
               thousands of dollars), and unmarried homeowners who wish 
               to leave their home to their partner, loved one, or family 
               member upon death, but do not want to transfer a present 
               ownership interest in the property.  Existing law offers 
               these individuals no good options.  Transfer by will (even 
               a statutory or holographic will) makes the property 
               subject to statutory probate fees of thousands of dollars. 
                Establishing a revocable trust can cost well over $1,000 
               if done by a reputable attorney, and can place the 
               prospective trustor at the mercy of scam artists and 
               charlatans if it is not.  Other alternatives generally 
               suffer from problems of cost, complexity, tax 
               implications, irrevocability, or a combination of all 
               these issues.  (Footnote omitted.)
          
           California Law Revision Commission Study  :  As directed by the 
          Legislature, the CLRC conducted a study to determine whether a 
          beneficiary deed should be statutorily created in California.  
          In particular, the Legislature asked the CLRC to address the 
          following specific issues:

               (1) Whether and when a beneficiary deed would be the 
               most appropriate non-probate transfer mechanism to 
               use, if a beneficiary deed should be recorded or held 
               by the grantor or grantee until the time of death, 
               and, if not recorded, whether a potential for fraud is 
               created.
               (2) What effect the recordation of a beneficiary deed 
               would have on the transferor's property rights after 
               recordation.
               (3) How a transferor may exert his or her property 
               rights in the event of a dispute with the beneficiary.
               (4) Whether it would be more difficult for a person 
               who has transferred a potential interest in the 
               property by beneficiary deed to change his or her mind 
               than if the property were devised by will to the 








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               transferee or transferred through a trust or other 
               instrument.
               (5) The tax implications of a beneficiary deed for the 
               transferor, the transferee, and the general public as 
               a result of the non-probate transfer, including 
               whether the property would be reassessed and if tax 
               burdens would shift or decrease.

          The CLRC began its study by reviewing existing options for 
          transferring real property at death.  These methods include 
          transfer by will or intestate succession, trust, survivorship 
          rights created by joint tenancy or community property, transfer 
          with a reserved life estate, and a revocable transfer deed as 
          recognized by Tennant v. John Tennant Memorial Home (1914) 167 
          Cal. 570.  Each of the methods of transfer has its advantages 
          and disadvantages.  For example, a will generally requires 
          probate, which is a time consuming and costly way to transfer 
          property.  A trust is expensive to set up, particularly if the 
          sole purpose is to convey one piece of property.  Joint tenancy 
          with right of survivorship creates immediate property interests 
          in all the joint tenants.  A current transfer, with a reserved 
          life estate for the transferor, is nonrevocable, preventing the 
          transferor from later changing his or her mind.  A revocable 
          deed under Tennant has been used rarely and its legal 
          consequences are not fully understood.

          At the time of the CLRC study, nine other states, including 
          Colorado, New Mexico, Ohio and Wisconsin, statutorily 
          recognized an RTDD.  (Today four additional states have 
          statutorily authorized RTDDs.)  The CLRC's investigation 
          revealed minor difference between the states' RTDDs and found 
          that practitioners generally liked having the option of the 
          RTDD.  However, most of the statutes were too new to provide 
          evidence of their effectiveness or of their susceptibility to 
          misuse or abuse.  

          The CLRC then focused on the operational issues of how an RTDD 
          should work.  The result is the very detailed statutory rules 
          set out in this bill.  They govern how an RTDD is established, 
          revoked and challenged, rights of creditors, including Medi-Cal 
          reimbursement rights, and how the transfer works for property 
          held jointly.  Detailed provisions are set out above.

          Finally, the CLRC considered public comments.  Generally groups 
          that provide legal assistance to seniors favor creation of the 








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          RTDD.  These groups argue that seniors on a limited income 
          needed a low-cost, simple method of transferring real property. 
           An RTDD, they contend, will help individuals avoid both 
          probate and trust mills, which can be costly and inefficient, 
          especially for a small estate containing only a single family 
          home.  Other professionals, including judges, attorneys, 
          lenders and title companies had more reservations.  They noted 
          that while an RTDD creates a quick and low-cost way to transfer 
          property, "it is not necessarily the safest or most reliable 
          method of accurately ensuring the transferor's wishes are 
          carried out as the transferor intended."  (CLRC Report at 205.) 
           They argued that, like a quitclaim deed that can be executed 
          without an attorney, it can be abused and can help facilitate 
          fraud on the transferor or his intended beneficiaries.  
          Moreover, because it is so simple to use, it may be used 
          inappropriately, without advice of counsel.  Finally, they 
          argue that the RTDD is just another device added to the 
          proliferation of estate planning tools, resulting in further 
          "confusion, inconsistency, litigation, and frustration for all 
          involved."  (CLRC Report at 206.)

          In recommending creation of an RTDD in California, the CLRC 
          balanced the generally positive, although quite limited, 
          experience of other states, the need for a simple, low-cost 
          method of conveying real property with the very real concerns 
          raised by opponents of the RTDD.  In order to address some of 
          opponents' well-founded concerns, the CLRC recommends that 
          California undertake a comprehensive review of all non-probate 
          transfers and their consequences.  However, in the interim, the 
          CLRC recommends that California establish a carefully crafted 
          RTDD.

           National Conference of Commissioners on Uniform State Laws 
          Approves RTDDs  :  In 2009, the National Conference of 
          Commissioners on Uniform State Laws approved a uniform act on 
          RTDDs.  According to their report, 13 states, including 
          Arizona, Nevada and Oklahoma now authorize RTDDs, and five more 
          are considering it this year.  (National Conference of 
          Commissioners on Uniform State Laws,  Uniform Real Property 
          Transfer on Death Act  (2009).)  

           This bill establishes a mandatory RTDD form  .  This bill 
          establishes a mandatory form RTDD that must be used when 
          executing an RTDD.  The mandatory form prevents a transferor 
          from using the RTDD if he or she wants to transfer his or her 








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          property other than as permitted by the form.  Failure to use 
          the statutory form does not necessarily invalidate the deed, 
          but the provisions of this bill would not apply to such a deed. 
           The transfer may still be valid under the Tennant case.  The 
          transferor can also dispose of his or her property through use 
          of another testamentary instrument, such as a will or a trust.  


          Establishing a mandatory RTDD has several advantages.  It 
          standardizes the form, which will help ensure that property 
          owners who do not seek legal counsel may be able to 
          successfully transfer property through use of an RTDD.  It also 
          makes implementation of the RTDD easier for title companies.  
          In addition, the statutory deed informs transferors of their 
          rights and the rights of their beneficiaries, and explains some 
          of the pitfalls of the RTDD.  

          Some will argue that the RTDD should be designed to be more 
          flexible, taking into consideration many possible wishes that a 
          transferor may have and helping to effectuate them, 
          particularly allowing the transferor to create a life estate.  
          A life estate permits the holder to occupy the property 
          exclusively during his or her lifetime.  The property is then 
          transferred automatically to the remainder beneficiaries on the 
          death of the life tenant.  Life estates can serve very useful 
          estate planning purposes.   For example, a homeowner, who has 
          children from a prior marriage, can leave his house to his 
          children, while still ensuring his second wife has a home to 
          live for the remainder of her life.  Previous versions of the 
          bill allowed for a life estate. However, the Trusts and Estates 
          Section of the State Bar had opposed the life estate provision, 
          believing there were too many complicated considerations to 
          allow a life estate to be accomplished by a form deed, and this 
          bill does not permit the use of a life estate.

          However, the statutory form, with its significant risks of 
          misuse by those who do not consult with counsel when 
          appropriate, may not be able to be everything to every 
          transferor.  Instead, the form attempts to help effectuate the 
          most common wish of transferors with relatively simple property 
          issues - to transfer the property to their beneficiaries.  A 
          transferor with more complicated needs should rightly consult 
          with experts and transfer the property through other transfer 
          options.  









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           The RTDD provides for multiple beneficiaries, but not alternate 
          beneficiaries  .  The RTDD provides for transfer to multiple 
          beneficiaries who take their interest equally as tenants in 
          common.  The bill requires that the beneficiaries must be 
          specifically named and cannot include a class of people, such 
          as transfers to "my children and grandchildren."  Most other 
          states with RTDD also preclude class gifts.  Prohibiting class 
          gifts allows the title company to readily ascertain who the 
          beneficiaries are, thus preventing delays or other 
          complications in the transfer of title.

          The bill specifically prevents the use of alternate 
          beneficiaries should any named beneficiary predecease the 
          transferor.  As a result, the general rules of lapse come into 
          play.  Under California's lapse and anti-lapse rules, if a 
          transferee under a will, trust, deed or other instrument fails 
                     to survive the transferor, the transfer does not lapse but 
          passes to the transferee's issue (decedents) as long as the 
          transferee is related to the transferor or the transferor's 
          spouse.  (Probate Code Section 21110.)  If the transferee is 
          not related, the transfer fails and the property comes back 
          into the transferor's estate for disposition.  While several of 
          the states that have RTDDs have specifically prohibited 
          application of anti-lapse rules to these deeds, the CLRC 
          believes that "equity demands application of the anti-lapse 
          principles" to RTDDs just as they apply to other testamentary 
          gifts and that application of these principles is precisely 
          what the majority of transferors would intend.  (CLRC Report at 
          172.)

           If, at the transferor's death, property is held jointly with 
          right of survivorship, the RTDD is void  .  Under current law, 
          when property is help by joint tenancy or by community property 
          with right of survivorship and one of the joint tenants or 
          spouses dies, the property passes, by operation of law, to the 
          other joint tenant(s) or the surviving spouse.  Absent 
          severance of the joint tenancy, any attempt to transfer the 
          property by the first joint tenant to die is ineffective.  The 
          property passes to the surviving joint tenant(s) or spouse.

          The bill proposes to follow that general rule for the RTDD.  
          All joint tenants or spouses can execute a separate RTDD.  Only 
          the RTDD of the last joint tenant or spouse to die will be 
          effective.  That last joint tenant or surviving spouse can 
          always change his or her mind and revoke the RTDD since he or 








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          she owns the property free and clear.  The bill and the 
          statutory deed make clear that if property is held jointly with 
          right of survivorship, an RTDD executed by the first to die 
          will have no effect.

          Will the bill have the unintended consequence of steering 
          persons away from legal assistance that they may need  ?  It is 
          unclear what role lawyers will play in the execution and 
          recording of these RTDDs.  On the one hand, the author suggests 
          that the reform might allow real property owners to avoid 
          lawyers altogether through the simple recording of a 
          beneficiary deed.  On the other hand, the primary criticism of 
          the "trust mills" is that they minimize the role of lawyers, 
          through the use of prefabricated trusts, when the input of a 
          lawyer's expertise is often necessary.  The State Bar's 
          Conference of Delegates passed a resolution in response to the 
          original RTDD bill expressing concern that, in creating yet 
          another "probate avoidance" device, the bill may have the 
          unintended consequence of steering people away from needed 
          legal assistance that can avoid unforeseen problems in estate 
          planning. 

           An RTDD could increase the risk of financial abuse  .  A 
          simplified RTDD could make it easier to commit financial abuse. 
           Seniors could sign without realizing what they were signing or 
          its consequences.  Proponents of the bill counter that far 
          simpler tools - such as a quitclaim deed which transfer all of 
          a person's interest in real property to the beneficiary at 
          execution - already exist that can cause far more harm.  
          However, just because there are other tools to transfer 
          property that are also subject to abuse, does not mitigate the 
          fact that this new transfer tool could cause significant harm 
          to unwary seniors and other property owners:  There is a very 
          real possibility that an RTDD could be used as a tool for 
          financial abuse or could simply be misused by those who do not 
          understand the transfer deed and all its implications.  

          This concern is highlighted by a story from an opponent of a 
          previous version of the bill about his father whose live-in 
          caregiver not only had him execute a new will making the 
          caregiver his beneficiary but also made the caregiver his 
          beneficiary on all pay on death accounts and executed a New 
          Mexico RTDD in favor of the caregiver.  While this case does 
          indeed demonstrate how the RTDD can be misused and abused in 
          the wrong hands, it also makes clear that existing methods of 








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          conveying property at death can be abused and why significant 
          transfers to caregivers are particularly suspect.

          In recognition of the risks associated with an RTDD, the bill 
          directs the CLRC to study the effect of the RTDD in California 
          and report back to the Legislature by January 1, 2016.  The 
          report must address the following issues: (1) whether the 
          revocable transfer on death deed is working effectively; (2) 
          whether the revocable transfer on death deed should be 
          continued; (3) whether the revocable transfer on death deed is 
          subject to misuse or misunderstanding; (4) what changes should 
          be made to the revocable transfer on death deed or the law 
          associated with the deed to improve its effectiveness and to 
          avoid misuse or misunderstanding; and (5) whether the revocable 
          transfer on death deed has been used to perpetuate financial 
          abuse on property owners and, if so, how the law associated 
          with the deed should be changed to minimize this abuse.  

          The bill also, by its own terms sunsets on January 1, 2017.  
          RTDDs executed before that time would remain valid, but RTDDs 
          executed after that date would not be valid.  This sunset, 
          together with the study by CLRC, should help minimize risks of 
          abuse or misuse associated with the RTDD, but would not prevent 
          such risks during the five years that RTDDs would be valid in 
          California.

           Author's Amendment  :  This bill establishes a pilot program, 
          with a required study by CLRC.  However, as currently drafted, 
          the pilot terminates on the same dated that the required study 
          is due to the Legislature.  Thus, the Legislature may not have 
          the important evaluative information available to consider, if 
          it elects to extend the pilot before termination.  In order to 
          ensure that the Legislature has the required evaluation timely, 
          the author rightly agrees to amend the bill so that the 
          required evaluation is due a year before the pilot terminates.  
          This can be accomplished with the following amendment:

          On page 33, line 20, delete "2017" and insert: "2016"

           ARGUMENTS IN SUPPORT :  The bill is supported by AARP and the 
          California Senior Legislature who believe that the bill 
          provides seniors with a simple, low- cost method to transfer 
          property to their heirs without the time and expense of a 
          probate proceeding.









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           ARGUMENTS IN OPPOSITION  :  Opponents, argue  that the bill 
          inadvertently creates "'drive-by' estate planning that puts 
          California's most vulnerable group - senior citizens - at great 
          risk for personal fraud."  California Escrow Association and 
          California Land Title Association believe that if this bill 
          becomes law, RTDDs "will become the new form of easy, 
          convenient, and cheap elder abuse."  In addition, they believe 
          the RTDD is "complex and convoluted" and, when used by 
          transferors without advice from legal counsel, could well 
          create confusion and ambiguity that could cloud the property's 
          title.  California Advocates for Nursing Home Reform
          adds that the bill "may result in seniors inadvertently leaving 
          their estates to individuals whom they might not otherwise want 
          to succeed them."
          
           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          California Communities United Institute (co-sponsor)
          Conference of California Bar Associations (co-sponsor)
          AARP
          Congress Senior Legislature
          
           Opposition 
           
          California Advocates for Nursing Home Reform
          California Escrow Association
          California Land Title Association
          

           Analysis Prepared by  :   Leora Gershenzon / JUD. / (916) 
          319-2334