BILL ANALYSIS                                                                                                                                                                                                    �



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          ASSEMBLY THIRD READING
          AB 1275 (Chau)
          As Introduced February 22, 2013
          Majority vote 

           JUDICIARY           10-0                                        
           
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          |Ayes:|Wieckowski, Wagner,       |     |                          |
          |     |Alejo, Chau, Dickinson,   |     |                          |
          |     |Garcia, Gorell,           |     |                          |
          |     |Maienschein, Muratsuchi,  |     |                          |
          |     |Stone                     |     |                          |
          |-----+--------------------------+-----+--------------------------|
          |     |                          |     |                          |
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           SUMMARY  :  Revises the definition of "owner" under the Unclaimed  
          Property Law (UPL), and permits only owners meeting this  
          definition to file a claim for recovery of property.   
          Specifically,  this bill  :   

          1)Provides that, notwithstanding Code of Civil Procedure of  
            Section 1501(g), for purposes of filing a claim for property  
            escheated to the state, the term "owner" means the person who  
            had legal right to the property prior to its escheat, his or  
            her heirs or estate representative, his or her guardian or  
            conservator, or a public administrator acting pursuant to the  
            authority granted in Probate Code Sections 7660 and 7661.

          2)Provides that only an owner, as defined above, may file a  
            claim with the State Controller pursuant to the UPL.

          3)Clarifies that a person who claims to have been the owner (as  
            defined above) of property may file a claim with the  
            Controller seeking recovery, and that the Controller shall  
            consider each claim within 180 days to determine if the  
            claimant is the owner of the property.

           EXISTING LAW  :  

          1)Authorizes any person, excluding another state, who claims an  
            interest in property paid or delivered to the Controller under  
            the UPL to file a claim to the property or to the net proceeds  
            from its sale.  (Code of Civil Procedure (CCP) Section  








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            1540(a).  Unless otherwise noted, all further references are  
            to this code.)

          2)Requires the Controller to consider each claim within 180 days  
            after it is filed and allows the Controller to hold a hearing  
            and receive evidence.  Further requires the Controller to give  
            written notice to the claimant if he or she denies the claim  
            in whole or in part, and specifies rules for mailing of the  
            notice.  (Section 1540(b).)

          3)Defines "owner," for the purpose of filing a claim to recover  
            unclaimed property, to mean the person who had legal right to  
            the property prior to its escheat, his or her heirs, his or  
            her legal representative, or a public administrator acting  
            pursuant to the authority granted in Probate Code Sections  
            7660 and 7661.  (Section 1540(c).)

          4)Defines "owner" to mean a depositor in case of a deposit, a  
            beneficiary in case of a trust, or creditor, claimant, or  
            payee in case of other choses in action, or any person having  
            a legal or equitable interest in property subject to this  
            chapter, or his or her legal representative. (Section  
            1501(g).)

           FISCAL EFFECT :  None

           COMMENTS  :  According to the author, this bill is needed to  
          address consequences arising from a recent California Court of  
          Appeal decision interpreting the definition of the term "owner"  
          under the UPL.  The author states:
               
               The Fourth Circuit Court of Appeals in December 2012  
               ruled that the language in CCP Section 1540(a) permits  
               any person with an interest in the unclaimed property  
               to claim it, regardless of how "owner" is defined in  
               CCP Section 1540(d).  The court's interpretation means  
               that there is no legislative guidance governing which  
               claims the Controller should pay, and that any party  
               that has an interest in the property can file a claim  
               regardless of the potential invalidity of the claim. 
               
               AB 1275 would remedy this problem by clearly defining  
               the term "owner" for purposes of filing an unclaimed  
               property claim, and specifying that only an owner may  








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               file a claim for unclaimed property with the State  
               Controller. AB 1275 will provide for consistent  
               application of the UPL, fair and equitable payment of  
               claims to owners, and reduce potential litigation  
               associated with the interpretation of the current UPL  
               statute while helping reduce frivolous lawsuits filed  
               by parties that are not eligible to file a claim.

          The UPL, enacted in 1958, establishes procedures for the escheat  
          of unclaimed personal property.  Property escheated to the state  
          means the state has custody of the property in perpetuity, until  
          the owner claims the 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 "who claims 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. 

          In Weingarten Realty Investors v. Chiang (Cal. App. 4th,  
          December 19, 2012), a California court of appeal considered  
          whether under the UPL a judgment creditor may claim property  
          escheated to the state on behalf of the party owing a debt to  
          the creditor.  The UPL alternatively defines "owner" to include  
          "any person having a legal or equitable interest" in the  
          property at issue (Section 1501(g)), but also provides that for  
          the purpose of Section 1540, the term "owner" means "the person  
          who had legal right to the property prior to its escheat"  
          (Section 1540(d)).  Under subdivisions (a) and (b) of Section  
          1540, however, existing law specifically authorizes "any person  
          who claims an interest in property paid or delivered to the  
          Controller" to file a claim for return of the property, and  
          makes further references to "the claimant" rather than "the  
          owner."  The court of appeal analyzed the statute and concluded  
          that the Legislature did not intend to limit use of the claims  








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          procedure to "owners" as defined by Section 1540(d), but meant  
          to allow all parties with any interest, including creditors, the  
          right to submit claims for escheated property, consistent with  
          the wording of Section 1501(g) and Section 1540(a).

          According to the Controller, this interpretation of the statute  
          is problematic because it "increases the likelihood of competing  
          claims as well as litigation filed by parties over such  
          property."  The Controller also states:  "If a creditor is  
          allowed to file a claim, the Unclaimed Property Program may have  
          to validate the present existence of a third-party debt. . .  
          Moreover, the court's interpretation introduces uncertainty into  
          the law regarding which claims the Controller should approve for  
          payment, and in which order."  Finally, the Controller notes  
          that since the Program's inception in 1959, the legislative  
          direction the Controller has used to interpret the UPL required  
          the Controller to pay the claim to the property owner at the  
          time of escheatment.

          The Controller's contention that the court's interpretation in  
          Weingarten creates new responsibilities for the Controller's  
          office, such as validating third party debt and resolving  
          competing claims, which are beyond the scope of the Controller's  
          duties under existing law, appears meritorious.  

          This bill would revise Section 1540 to make it clear that an  
          owner is the person who had legal right to the property prior to  
          its escheat, and that only those persons (owners) or their heirs  
          or authorized representatives may file a claim for the recovery  
          of unclaimed property.  The changes proposed by this bill seek  
          to restore authority to the Controller to resume implementing  
          the UPL in the way that the Controller's office reportedly has  
          for over the past 50 years, prior to Weingarten, as well as  
          eliminate other sources of ambiguity that could lead to  
          litigation.

          This bill is opposed by United Asset Recovery (UAR), a  
          Carlsbad-based company that, according to its Web site,  
          specializes in the recovery of abandoned and unclaimed funds for  
          a fee.  In its letter of opposition, UAR urges the Legislature  
          not to approve legislation that would reverse the holding of  
          Weingarten.
           









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


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