BILL ANALYSIS                                                                                                                                                                                                    ”

                                                                  SB 1191
                                                                  Page  1

          Date of Hearing:   July 3, 2012

                           ASSEMBLY COMMITTEE ON JUDICIARY
                                  Mike Feuer, Chair
                    SB 1191 (Simitian) - As Amended:  May 15, 2012

                              As Proposed to be Amended
          SENATE VOTE  :   23-13

          THE PROPERTY?

           FISCAL EFFECT  :  As currently in print this bill is keyed 

          This bill would require certain landlords (offering property 
          with one to four units) who have received a notice of default to 
          disclose that notice to any prospective tenant prior to entering 
          into a lease agreement for the property.  A violation would 
          allow the tenant to void the lease or be punishable by a minimum 
          financial penalty of two months' rent.  Supporters argue that 
          the bill helps ensure that Californians make rental decisions 
          with full and accurate information about the property that may 
          become their home.  Because it is not legally required to inform 
          an applicant that the rental unit they are considering is in 
          foreclosure, supporters argue, tenants often sign leases they 
          would not otherwise enter into only to find out that the 
          property will be up for auction, although the new owner is 
          legally obligated to honor the lease or provide at least 90 
          days' written notice before eviction.  Supporters include the 
          California Apartment Association, which argues that, unlike 
          apartments, purchasers of foreclosed single-family homes often 
          terminate any existing tenancies.  Opponents contend that the 
          measure unfairly targets owners of smaller properties and is 
          unduly punitive.  

          Proposed amendments narrow and clarify the measure, but there 
          remain outstanding issues to be resolved.  First, there is a 


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          question whether owner-occupied properties should be excluded 
          from this mandate so as to avoid inappropriately discouraging 
          rental arrangements designed to allow the homeowner to stay in 
          their homes, especially given the difficulty many homeowners 
          have encountered when they seek loan modifications from their 
          banks and servicers.  Secondly, there is a question whether a 
          monetary penalty should be imposed if the tenancy has not been 

           SUMMARY  :  Requires disclosure to prospective tenants when the 
          owner of certain residential property receives a notice of 
          default (NOD).  Specifically,  this bill  :   

          1)Requires specified landlords who have received a NOD that has 
            not been rescinded to notify a prospective tenant of that 
            default in writing prior to executing a lease agreement for 
            the property.  

          2)Provides that a violation of the bill would void the lease at 
            the election of the tenant and entitle the tenant to recovery 
            of twice the monthly rent or twice the actual damages, 
            whichever is greater if the tenancy is terminated.  

           EXISTING LAW  : 

           1)Regulates the non-judicial foreclosure of properties pursuant 
            to the power of sale contained within a mortgage contract.  To 
            commence the process, existing state law requires the trustee, 
            mortgagee, or beneficiary to record a Notice of Default and 
            allow three months to lapse before setting a date for sale of 
            the property.  (Civil Code Secs. 2924, 2924f.)  Existing law 
            governs the issuance of the Notice of Sale, and requires the 
            notice to be recorded at least 20 days prior to the date of 
            sale.  (Civil Code Sec. 2924f.) 

          2)Generally regulates the judicial foreclosure process, and 
            states that a notice of sale may not be given for at least 120 
            days after the notice of levy was served on the judgment 
            debtor.  (Code Civil Proc Sec. 701.510 et seq.)  

          3)Requires a trustee or authorized agent, upon posting a notice 
            of sale, to also post, and mail, a statutory notice informing 
            tenants that they are residents of a property subject to a 
            foreclosure sale.  (Civil Code Sec. 2924.8.)  


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           4)Provides that tenants living in a rental unit at the time the 
            property is sold in foreclosure must be given 60-days' notice 
            before they may be evicted.  This provision, which does not 
            apply if any party to the mortgage note remains in the 
            property as a tenant, subtenant, or occupant, sunsets on 
            January 1, 2013.  (Code Civil Proc. Sec. 1161b.)  

          5)Requires a successor in interest in a property subject to 
            foreclosure to provide a bona fide tenant in the property with 
            a 90-day notice to vacate.  The successor in interest must 
            also honor the tenant's lease until the end of the lease term 
            unless the property is sold to a purchaser who intends to 
            occupy the home as his or her primary residence.  In that 
            case, the tenant must be provided with a 90-day notice to 
            vacate (unless a longer period is required by state or local 
            law).  In addition, tenants of foreclosed properties must be 
            provided with 90-days' notice to vacate if there is no lease 
            or the lease is terminable at will.  These provisions sunset 
            on December 31, 2014.  ("Protecting Tenants at Foreclosure Act 
            of 2009," Public Law 111-22.)

          6)Contains various provisions regulating the hiring of real 
            property, as specified.  (Civil Code Sec. 1940 et seq.)

           COMMENTS  :  The author explains the reason for the bill as 

               Senate Bill 1191 helps ensure that Californians make rental 
               decisions with full and accurate information about the 
               property that may become their home.  While it seems like 
               common courtesy to tell someone that the apartment they're 
               considering is in foreclosure, it's not legally required. 
               As a result, tenants often sign leases only to find out 
               that in just a few days or weeks, the property will be up 
               for auction. There are several risks associated with 
               leasing a property in foreclosure.

               First, in advance of the foreclosure sale, tenants often 
               experience decreased services from landlords facing 
               financial difficulties.  For example, owners may fail to 
               pay utilities, or ignore requests for maintenance or 

               Second, after the foreclosure sale, tenants face a 
               tremendous amount of uncertainty. Tenants may not know to 


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               whom they should send rent, or direct requests regarding 
               the property. Similarly, tenants may not be aware of the 
               protections guaranteed to them under federal and state law, 
               and so may feel pressured to vacate or to terminate leases 
               through "cash for keys" offers. Third, there are several 
               circumstances where a tenant's lease may be invalidated by 
               the foreclosure sale. For example, if the new owner intends 
               to move into the property the tenant will have only 90 days 
               to vacate, regardless of the terms of the lease. In 
               addition, the federal Protecting Tenants at Foreclosure Act 
               - and pending legislation in California - do not apply to 
               certain leases, meaning that tenants may face eviction 
               before their lease concludes. 

               Fourth, in practice it is especially difficult for tenants 
               to recover security deposits during or after a foreclosure. 
                The defaulting landlord may lack the financial resources 
               to return it, and the new owner - though legally obligated 
               to return the deposit - is often reluctant to do so.  
               Finally, tenants in recently foreclosed properties often 
               face exposure to bad actors.  Tenant advocates report that 
               their clients are frequently subject to harassment and 
               misinformation from individuals seeking to remove tenants 
               from recently foreclosed properties.

          Tenants Together writes in support, "This is an important tenant 
          protection bill.  The fact that the foreclosure process is 
          underway is a material fact that should be disclosed to renters. 
           A landlord's foreclosure has significant impacts on tenants and 
          their rights.  Foreclosure may affect the length of the tenancy, 
          the housing conditions experienced by tenants, and the 
          likelihood that tenants get back their security deposits after 
          vacating.  It is only fair that tenants be notified of 
          foreclosure activity so they can make an informed choice about 
          their housing."

           Impact of Foreclosure Crisis On Tenants.  As this Committee has 
          frequently observed, California leads the nation with one of the 
          highest rates of foreclosure.  According to RealtyTrac, in 
          California, one in every 303 housing units received a 
          foreclosure filing in March 2012, and 48,422 houses received a 
          foreclosure notice in February alone.  Tenants living in those 
          homes have overwhelmingly been impacted.  A November 18, 2007 
          New York Times article, "As Owners Feel Mortgage Pain, So Do 
          Renters," noted "thousands of American families are losing their 


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          homes without ever missing a payment.  They are renters in 
          houses whose owners default on their mortgages - a large but 
          little noticed class of casualties."  

          In January 2011, Tenants Together released its third annual 
          report entitled "California Renters in the Foreclosure Crisis."  
          The report estimated that at least 38 percent of homes in 
          foreclosures were rentals and more than 200,000 California 
          renters were directly affected by home foreclosures in 2010 

           Current Protections For Tenants In Foreclosure  .  State and 
          federal laws have been enacted to provide tenants with 
          additional time to move when the home in which they are living 
          is the subject of a foreclosure.  In 2008, the Legislature 
          passed and the Governor signed SB 1137 (Perata, Corbett, 
          Machado, Ch. 69, Stats. 2008), which requires that tenants 
          receive 60-days' notice before they may be evicted after the 
          rental unit in which they are living is foreclosed.  These 
          provisions sunset on January 1, 2013.  Measures currently 
          pending before this Committee would revise and extend current 
          law for an additional six years.

          Federal lawmakers have also acted to protect tenants in 
          foreclosure situations.  On May 20, 2009, President Obama signed 
          S. 896, Public Law 111-22, which included the "Protecting 
          Tenants at Foreclosure Act of 2009" (PTFA).  The PTFA generally 
          requires a successor in interest in a property subject to 
          foreclosure to provide bona fide tenants with a 90-day notice to 
          vacate and, with limited exceptions, to honor the tenant's lease 
          until the end of the lease term.  In 2010, the President signed 
          legislation extending the PTFA until December 31, 2014 and 
          clarifying that its protections extend to tenants who have 
          entered into leases before the date on which complete title is 
          transferred as the result of a foreclosure.  

          The PTFA fundamentally changed the obligations of subsequent 
          owners of foreclosed properties (usually the foreclosing entity) 
          by modifying the general rule that foreclosure extinguishes the 
          lease of any tenant in the property.  While the notice provided 
          by this bill responds to the situation where a tenant signs a 
          lease after an NOD has been recorded and before the sale of a 
          foreclosed property - a sale that previously would have 
          extinguished the lease - the recent protection of those leases 
          under federal law changes the effect of this bill from one that 


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          warns tenants of a situation that would extinguish their lease 
          to one that informs tenants of information about the property 
          they are renting.

           This Committee Has Previously Passed Similar Legislation  .  This 
          bill is similar to AB 331 (Hall) of 2009 which would have 
          required a landlord to disclose any of the following 
          circumstances to a prospective tenant before the execution of a 
          rental agreement:  (1) any outstanding notice of default, or 
          notice of trustee's sale; (2) any pending suit to foreclose a 
          mortgage, trust deed, or vendor's lien under a contract of sale; 
          (3) any pending declaration of forfeiture or suit for specific 
          performance of a contract of sale; or (4) any pending proceeding 
          to foreclose a tax lien.  That measure passed this Committee 
          without opposition but was held in the Senate Judiciary 

           Potential Benefits And Detriments Of Proposed Notice.   As 
          discussed above, tenants in foreclosed properties are protected 
          in several ways under existing state law - tenants receive 
          notice of the pending foreclosure sale before their rental 
          property is sold, and tenants of foreclosed properties are 
          allowed to stay in the property for a period of time (state law 
          generally provides for 60 days, but federal law extends that 
          time period to 90 days).

          This bill seeks to increase tenant protections by requiring a 
          landlord to give prospective tenants a written notice of the 
          existence of an outstanding notice of default.  Unlike the 
          notice required under existing state law for a notice of sale, 
          this notification would be provided to prospective - not 
          existing - tenants, and the notice would inform prospective 
          tenants of the first step in the non-judicial foreclosure 
          process as opposed to the notice of sale, which tenants are 
          notified of under existing law and is provided at a minimum of 
          three to six months after the notice of default.  

          The notice proposed by this bill would provide useful 
          information to prospective tenants that may affect their rental 
          decision.  Although their lease would likely be protected under 
          federal law, those prospective tenants would be able to make the 
          educated decision to avoid the risks associated with renting a 
          property in foreclosure.  On this point, supporter Western 
          Center on Law & Poverty notes that the fact that foreclosure 
          proceedings have begun on the property is a "material fact 


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          ›that] is critical for tenants to make an informed choice about 
          whether to rent a particular dwelling.  Some tenants might be 
          willing to live with the risk that their tenancy may soon be 
          interrupted.  Others, for example those with children in school, 
          will want more certainty that the dwelling will remain available 
          to them for the foreseeable future."  There have also been 
          reports of unscrupulous landlords signing tenants to new leases 
          right before the foreclosure sale (and thus collecting first and 
          last month's rent plus a security deposit) and many allegations 
          that existing federal law requiring recognition of the lease by 
          a new owner is often not followed.

          It is useful to note that a notice of default can be cured, and 
          much of the recent federal loan modification efforts, as well as 
          pending proposals before this Legislature, have been to assist 
          those borrowers who are in default.  As a result, it is 
          important that any prospective tenant who receives notice that 
          their potential rental property is in default understands that 
          the notice of default does not impact the landlord-tenant 
          relationship, including their obligation to pay rent, and that 
          they do have rights under state and federal law should the 
          property be sold at a foreclosure sale.  Moreover, from the 
          perspective of a distressed homeowner, the rental of the 
          property may represent the only way to make the mortgage 
          payment.  The homeowner may have lost his or her job, failed to 
          qualify for a loan modification, and moved out of their primary 
          residence in an attempt to rent the family home in order to make 
          their mortgage payment.  Considering that a prospective tenant 
          could be discouraged from renting a home if they do, in fact, 
          know that the home is in foreclosure, the notice required by 
          this bill could potentially frustrate the leasing of homes by 
          those troubled borrowers.  Without tenants, a distressed 
          homeowner could be unlikely to have sufficient funds to pay the 
          mortgage, resulting in the loss of the home.

           The Committee may wish to explore with the author whether these 
          competing interests can best be balanced by focusing the bill on 
          property owners who are in the rental business, rather than 
          those who are renting their own primary place of residence, as 
          suggested in the amendment proposed below.

           Questions Regarding Exclusion of Most Apartments.   This bill 
          would omit most apartments from the notice requirements because 
          it is limited to single-family dwellings and multifamily 
          dwellings not exceeding four units.  In support of that 


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          limitation, supporter California Apartment Association contends 
          that the mortgage crisis is predominantly about single-family 
          homes and that the purchaser of a foreclosed home often 
          terminates the existing tenancy.  Despite those contentions, it 
          is important to note that apartments are not immune from 
          foreclosure.  The Associated Press' March 18, 2009 article 
          entitled Foreclosures Force Renting Families Onto Street 

               While the nation's default rate on apartment buildings is 
               still relatively low, it is rising quickly.  Fannie Mae, 
               for example, said its delinquency rate was 0.30 percent 
               at the end of last year, double what it was at the end of 
               September, and almost four times the rate at the end of 
               2007.  In Los Angeles, neighborhoods in the city's 
               low-income south and central areas are being walloped.  
               In 2007, buildings containing a total of 1,690 apartments 
               were foreclosed on.  In 2008, owners lost buildings 
               containing 4,789 apartments, according to the city 
               housing department.

          RealtyTrac data shows that there were 587 properties undergoing 
          foreclosure with five or more dwellings in select cities at the 
          end of February 2012 as follows:  Los Angeles had 212 such 
          properties; San Diego, 29; San Jose, 37; San Francisco, 53; 
          Fresno, 86; Sacramento, 25; Long Beach, 37; Bakersfield, 24; 
          Riverside, 20; Stockton, 13; San Bernardino, 11; Modesto, 26; 
          Moreno Valley, 10; and Roseville, 4.   

          As the author properly notes, "The foreclosure crisis is 
          primarily limited to smaller properties. According to DataQuick, 
          only 0.43% of notices of default filed in California in 2011 
          were for apartment buildings with five or more units.  In fact, 
          there were more notices of default filed for quadplexes 
          (buildings with four units) than for all buildings with five or 
          more units combined."  In addition, according to the author, 
          "tenants in large multifamily properties are less likely to face 
          exposure to bad actors seeking to remove existing tenants.  
          Tenants in single-family homes or small properties undergoing 
          foreclosure may receive 'cash for keys' offers, or 
          misinformation regarding the legitimacy of their lease.  Larger 
          multifamily properties are valuable because of their potential 
          to generate revenue through leases, and so successor interests 
          are far less likely to seek to remove existing tenants."  


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          Nevertheless, it is somewhat unusual to single-out one form of 
          rental housing for special notices regarding potential 
          foreclosure rights. Neither existing state law under SB 1137, 
          nor existing federal law under the PTFA, is limited to single 
          family and small multi-family units as this bill is.  Likewise, 
          currently pending proposals to reform and extend tenant 
          protections in foreclosure, such as the Attorney General's 
          sponsored legislation, AB 2610 and SB 1473, do not exclude 
          apartment renters. 

           Questions Regarding Remedies For Violation.   As currently 
          drafted, a violation of the notice requirements would void the 
          lease at the election of the tenant and entitle the tenant to 
          recover twice the monthly rent or twice the actual damages, 
          whichever is greater.  As set out in more detail below, 
          opponents argue that the bill's financial penalty is excessive.  
          By contrast, existing law imposing an obligation to notify 
          tenants of a notice of sale has no specified financial penalty 
          for violation.

          While a sufficient deterrent is necessary to ensure compliance 
          with the bill's requirements, the  Committee may wish to explore 
          with the author  whether a monetary remedy related to the 
          tenant's anticipated damages is needed if in fact the tenant has 
          not been damaged because there has been no termination of the 
          rental agreement.  There are a number of circumstances that may 
          arise by which the tenant would avoid financial harm.  The 
          notice of default may be cured.  If not cured, the rental period 
          may nevertheless be completed without incident before any 
          foreclosure sale takes place.  Indeed, even if the property is 
          sold the purchaser must honor any lease in most cases or provide 
          the tenant with at least 90 days' notice.  If the tenancy is not 
          affected, it may not be appropriate to require the landlord to 
          pay the tenant, or to do so in the amount proposed by the bill.  
          Where the tenancy is terminated, however, a financial penalty 
          bears a stronger relationship to the tenant's expected damages.  
          Thus, it may be appropriate to allow the tenant to void the 
          lease at any point and recover the financial penalty of two 
          months' rent to compensate the tenant for relocation costs 
          necessitated by the move, and to allow similar recovery where 
          the tenant suffers an eviction flowing from the notice of 
          default, but not to otherwise impose a financial penalty.  This 
          proposal is reflected in the amendments suggested below.

           ARGUMENTS IN OPPOSITION  :  A number of landlord associations 


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            oppose the bill.  
          The Apartment Association of California Southern Cities, the 
          NORCAL Rental Property Association, the East Bay Rental Housing 
          Association, and the Apartment Association of Orange County give 
          the following reasons for their opposition:

                 Only single family and one-to-four unit property owners 
               are penalized. Why aren't others penalized?
                 The required notice is equivalent to putting up a "Don't 
               Rent Here" sign.
                 Instead of helping people keep their property during 
               this foreclosure crisis, this bill facilitates and speeds 
               up the foreclosure process.
                 No showing of injury or harm to the tenant is required. 
                 Even though the foreclosure process can take years to 
               finalize, and even if the landlord cures, the bill contains 
               no limitation on how long a tenant may wait to bring a 
                 Property owners are not allowed to cure the NOD at any 
               point in the process, thus giving rise to an unwarranted 
               strict liability offense. 
                 The "twice the actual damages" penalty is too severe a 
               consequence and out of proportion with the aim of the bill. 

          In addition, the Apartment Association of Greater Los Angeles 
          (AAGLA), the San Diego County Apartment Association (SDCAA) and 
          the Santa Barbara Rental Property Association (SBRPA) argue that 
          the bill "is an especially punitive bill that while asserting a 
          well-intentioned public policy, targets only small property 
          owners to pay an exceptionally unreasonable financial penalty 
          and increases the likelihood that those property owners will 
          suffer a foreclosure."  These groups state:

                 By requiring the smallest and most vulnerable property 
               owners (one to four units) to notify prospective tenants of 
               Notice of Default - using prescriptive, alarming statutory 
               language which translates into essentially a "don't rent 
               here" sign - SB 1191 worsens the financial conditions of 
               these owners and hastens foreclosure.
                 SB 1191 also follows a strict liability standard to 
               impose financial punishment on owners who intentionally or 
               not violate its provisions.  Tenants, with no need to show 
               harm, can void leases and collect an amount equal to two 


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               months' rent or elect to stay and avoid paying two months' 
                 Issuing a warning to prospective tenants at the time of 
               default is misleading and pre-mature:
                 It hurts the housing market and doesn't help tenants - 
               scaring them from renting what are often the most 
               affordable rentals in the area. 
                 Tenants in foreclosed properties are already protected 
               by state and federal law - at least 60 and sometimes 90 
               days' notice in a month-to-month tenancy, or to the end of 
               an existing lease term.

           Proposed Amendments  .    Dialog between the author, the Committee 
          and interested parties has resulted in the following proposed 
          amendments.  As discussed above, the author has not indicated 
          his willingness to exclude owner-occupied properties or to limit 
          the financial penalty to cases in which the tenant has elected 
          to vacate or has been evicted.
           2924.9  .  2924.85  (a)  Subject to subdivision (f)  , every landlord 
          who  offers for rent  is in default under a mortgage or deed of 
          trust secured by  a single-family dwelling, or a multifamily 
          dwelling not exceeding four units, and who has received a notice 
          of default  that has not been rescinded with respect to a 
          mortgage or deed of trust secured by that property   from the 
          mortgagee, trustee, or other person authorized to take the 
          foreclosure sale  shall disclose the notice of default in writing 
          to any prospective tenant prior to executing a lease agreement 
          for the property subject to the notice.

          (b) A violation of subdivision (a) shall void the lease at the 
          election of the tenant  .  If a tenant elects to void the lease 
          and vacate the property or if the tenant elects to remain but is 
          evicted as the result of a foreclosure sale, a violation of 
          subdivision (a)   and  shall entitle the tenant to recovery of 
          twice the monthly rent or twice the actual damages, whichever is 
          greater,  and all prepaid rent from the landlord who received the 
          notice of default,  in addition to any other remedy that the law 
          may provide.

           (c) In lieu of the remedies in subdivision (b), if the tenant 
          elects not to terminate the lease and the foreclosure sale has 
          not occurred, and the tenancy is terminated as the result of a 
          foreclosure  sale   the tenant may elect to deduct a total amount 
          equal to two months' rent from future rent obligations owed the 


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          landlord who received the notice of default.

           (d) The written disclosure notice required by subdivision (a) 
          shall be  provided in English and the languages described in 
          Section 1632 in  substantially in the following form:

          The foreclosure process has begun on this property, and this 
          property may be sold at foreclosure. If you rent this property, 
          and a foreclosure sale occurs, the sale may affect your right to 
          continue to live in this property in the future. Your tenancy 
          may continue after the sale. The new owner must honor the lease 
          unless the new owner will occupy the property as a primary 
          residence, or in other limited circumstances. Also, in some 
          cases and in some cities with a "just cause for eviction" law, 
          you may not have to move at all. In order for the new owner to 
          evict you, the new owner must provide you with at least  60  90 
          days' written eviction notice in most cases  .  or 90 days if 
          required by any other provision of state or federal law. 
          However, some laws may prohibit eviction.   (e) A property manager 
          shall not be liable under this section for failure to provide 
          the written disclosure notice in subdivision (d) unless the 
          landlord has notified the property manager of the notice of 
          default and directed him or her in writing to deliver the 
          written disclosure, in which case the property manager shall be 
          liable to the extent specified in subdivision (b). This 
          subdivision shall not preclude a landlord from being held liable 
          when a tenant does not receive the written disclosure notice in 
          subdivision (d).
           (f)  This section does not apply to rental property that is 
          occupied by the landlord as his or her principal residence.

          (g) The rights and remedies provided by this section are in 
          addition to and independent of any other rights and remedies 
          under any other law. Nothing in this section shall be construed 
          to alter, limit, or negate any other rights or remedies.

          (h)  This section shall remain in effect only until December 31, 
           2019, and as of that date is repealed, unless a later enacted 
          statute, that is enacted before December 31, 2019, deletes or 
          extends that  date.


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          Asian Law Caucus
          California Apartment Association
          California Nurses Association
          California Public Interest Research Group 
          California Rural Legal Assistance Foundation
          Center for Responsible Lending
          Consumer Attorneys of California
          EAH Housing
          Eden Housing
          Greenlining Institute
          Housing Leadership Council of San Mateo County 
          Inquilinos Unidos
          Law Foundation of Silicon Valley
          Legal Aid Society of San Mateo County
          MidPen Housing
          National Housing Law Project
          Neighborhood Housing Services Silicon Valley
          Non-Profit Housing Association of Northern California
          Palo Alto Housing Corporation
          Santa Cruz County
          Tenants Together
          Western Center on Law & Poverty
          Apartment Association, California Southern Cities
          Apartment Association of Greater Los Angeles
          Apartment Association of Orange County
          East Bay Rental Housing Association
          NORCAL Rental Property Association
          San Diego County Apartment Association
          Santa Barbara Rental Housing Association

           Analysis Prepared by  :    Kevin G. Baker / JUD. / (916) 319-2334 


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