BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  AB 212
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          CONCURRENCE IN SENATE AMENDMENTS
          AB 212 (Lowenthal)
          As Amended June 24, 2013
          Majority vote 
           
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          |ASSEMBLY:  |54-22|(May 29, 2013)  |SENATE: |39-0 |(September 9,  |
          |           |     |                |        |     |2013)          |
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           Original Committee Reference:    JUD.  

           SUMMARY  :  Lowers the minimum threshold amount for aggregate  
          reporting of unclaimed property from $50 to $25, to take effect  
          July 1, 2014.  Specifically,  this bill  :   

          1)Allows, as of July 1, 2014, unclaimed property items valued  
            under $25 each to be reported in aggregate, rather than  
            accompanied by individually identifying information.

          2)Clarifies that the holder may impose a service charge of up to  
            $2 to send the notification, but only if the unclaimed  
            property has a value greater than $2.

           The Senate amendments  decrease, from $50 to $25, the threshold  
          value of property that may be reported in aggregate, and delete  
          the condition that such property may be reported in aggregate  
          only if the name of the owner is unknown and there is no last  
          known address of the owner in the records of the holder.
           
          FISCAL EFFECT  :  According to the Senate Appropriations  
          Committee:

          1)State Controller's Office (SCO) costs of approximately  
            $120,000 annually, beginning in 2014-15, to provide additional  
            notices to owners of lower-valued property escheated to the  
            state that was formerly included in the aggregate reporting  
            without owner contact information (General Fund).

          2)The SCO estimates revenue losses of $12,544 in 2015-16,  
            $92,544 in 2016-17, and $143,744 in 2017-18, with moderate  
            ongoing growth, as a result of increased claims by owners of  
            lower-valued property escheated to the state that was formerly  
            included in the aggregate reporting without owner contact  
            information (General Fund).  Actual losses could be higher,  








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            depending on how much of the current aggregate property  
            transferred to the state is valued over $25, and the claim  
            rate for lower valued property.  For example, if half of the  
            aggregate property currently transferred to the state in a  
            year has a value of $25 to $50, and the claim rate is one  
            fourth of the overall first year claim rate for escheated  
            property, the first year impact would be $30,400 (based on  
            $12.8 million in aggregate property transferred to the state  
            in 2011-12, and average overall first year claim rate of  
            1.9%).

           COMMENTS  :  Under existing law, holders of unclaimed property are  
          generally required to:  1) send due diligence notices to owners  
          identifying the property and notifying them that the property  
          may escheat to the state unless certain action is taken; and 2)  
          report to the State Controller the owner's name, address, and  
          other information appearing in the holder's records, if any.  If  
          the unclaimed property is valued at less than $50, however, the  
          holder is not required to provide any due diligence notice to  
          the owner, nor to report identifying information about the  
          property and its owner to the Controller, even if such  
          information is contained in the holder's own records of the  
          property.  Instead, many small properties valued at under $50  
          may be combined together into a single amount without  
          identifying information, and reported in aggregate to the  
          Controller as a single line item.

          This bill would simply lower the threshold amount for aggregate  
          reporting of unclaimed property from the amount of $50 to $25,  
          to take effect July 1, 2014.  In addition, holders of unclaimed  
          property valued at less than $50 would continue to be exempt  
          from the general requirement to send due diligence notifications  
          to owners prior to escheat for properties valued $50 or more.

          According to the author, this bill is needed to address certain  
          problematic aspects associated with aggregate reporting.  The  
          author states:

               Aggregate reporting presents many challenges for the  
               Unclaimed Property Program in achieving its mission to  
               reunite lost and abandoned property with the rightful  
               owner.  Since current statute does not require holders  
               to report owner information on accounts valued at less  
               than $50, aggregate properties are not itemized within  
               the unclaimed property database or displayed on the  








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               website for owners to search the SCO public website  
               and claim their properties.  If by chance, an owner  
               does learn that they have an aggregate property; many  
               complexities ensue for both holders and the SCO in  
               researching these properties and proving entitlement  
               when a claim is made.  Oftentimes when a customer  
               calls to make an inquiry regarding an aggregate  
               property, the State will refer them back to the holder  
               and conversely, the holder will refer them back to the  
               State.  This back and forth creates a great deal of  
               frustration for the property owner and inspires very  
               little public confidence of the Unclaimed Property  
               Program or the holder.

          The Unclaimed Property Law (UPL), enacted in 1958, establishes  
          procedures for the escheat of unclaimed personal property.  The  
          UPL establishes procedures to be followed when property goes  
          unclaimed, generally for a period of three years, and escheats  
          to the state.  Under existing law, the holder must annually  
          report on unclaimed property and turn the property over to the  
          Controller.  In turn, the Controller is required to mail a  
          notice to each person who appears to be entitled to unclaimed  
          property according to the report filed by a holder, in addition  
          to the requirement of publication of unclaimed property owners  
          in a newspaper of general circulation.  A person with an  
          interest in escheated property may file a claim to recover the  
          property from the state.  The Controller maintains a Web site  
          (  http://www.sco.ca.gov  ) where members of the public may search a  
          database to discover if the state is holding any of their  
          property, and may submit claims to recover the funds or  
          property.  

          Existing law expressly permits so-called "aggregate reporting"  
          for items of value under $50, even when an owner's contact  
          information, such as name, address, account number and social  
          security number, is known to the holder.  Aggregate reporting of  
          unclaimed property occurs when many small properties are added  
          together and reported as a single amount to the Controller  
          without including information about the individual owners and  
          properties that are being aggregated together.  In 2011-12, the  
          State Controller reports that over $12.8 million was transferred  
          to the state in aggregate without any accompanying information  
          that could identify the individual property owners, and that  
          this figure totals approximately $68 million over the past five  
          years.








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          According to the Controller, the task of reuniting these  
          properties with their rightful owners is nearly impossible after  
          they have been reported in aggregate.  Proponents contend that  
          aggregate reporting may unnecessarily prevent some owners from  
          being reunited with their property under $25, even when  
          identifying information is known to the holder, because that  
          information is essentially disregarded and wasted once the  
          property is reported in aggregate.  Furthermore, this result  
          does not appear to further one of the main objectives of the  
          UPL-to restore property to its rightful owner-and may in fact  
          hinder it.  Consequently, this bill seeks to restrict aggregate  
          reporting of unclaimed property by permitting it only for items  
          valued under $25 each.
           
          Existing law also requires holders of property to send due  
          diligence notices to property owners notifying them that their  
          property may escheat to the state, unless the property is valued  
          at less than $50.  The notice is intended to prompt the owner to  
          take some action on the account that will make the owner's  
          presence apparent to the holder, often by recovering the  
          property or restoring communication between holder and owner,  
          but in either case preventing escheat of the property to the  
          state pursuant to the UPL.  This bill continues existing law  
          requiring holders to send due diligence notices unless the  
          property is valued at less than $50.


           Analysis Prepared by  :    Anthony Lew / JUD. / (916) 319-2334 


          FN: 0002134