BILL ANALYSIS Ó SENATE JUDICIARY COMMITTEE Senator Hannah-Beth Jackson, Chair 2015-2016 Regular Session AB 506 (Maienschein) Version: June 29, 2015 Hearing Date: July 7, 2015 Fiscal: No Urgency: No RD SUBJECT Limited liability companies: limited partnerships DESCRIPTION This bill seeks to make various changes to the California Revised Uniform Limited Liability Company Act (RULLCA). BACKGROUND A California limited liability company (LLC) is a hybrid between a corporation and a partnership. An LLC generally has the characteristics of a partnership for operational and taxation purposes, but its members enjoy the immunity provided by a corporation to its shareholders for contract debts or tort liability. The interest of a member in an LLC is an economic interest, in the same manner that a partnership interest or a corporate share is an economic interest, that may be transferred under terms and conditions provided by the LLC agreement, the partnership agreement, or the corporate structure. California first recognized LLCs in 1994 with the enactment of the Beverly-Killea Limited Liability Company Act (Beverly-Killea), which provided comprehensive provisions for the organization, management, and dissolution of LLCs. (SB 469 (Beverly, Ch. 1200, Stats. 1994).) That same year, the National Conference of Commissioners on Uniform State Laws (NCCUSL) approved the use of a Uniform Limited Liability Company Act. In 2006, after reviewing the development of LLC laws in the United States, NCCUSL adopted the Revised Uniform Limited Liability Company Act (RULLCA), which has been enacted in five states AB 506 (Maienschein) Page 2 of ? (Idaho, Iowa, Nebraska, Utah, and Wyoming) and the District of Colombia. In 2012, SB 323 (Vargas, Ch. 419, Stats. 2012), sponsored by the Partnerships and Limited Liability Companies Committee of the Business Law Section of the State Bar of California, was enacted to repeal Beverly-Killea and, taking into account California's particular LLC protections, replace it with a modified version of RULLCA. This bill, also sponsored by the Partnerships and Limited Liability Companies Committees of the Business Law Section of the State Bar of California, would make various changes to the RULLCA provisions. CHANGES TO EXISTING LAW 1.Existing law , the California Revised Uniform Limited Liability Company Act (RULLCA), governs all California limited liability companies (LLCs). (Corp. Code Sec. 17701.01 et seq.) This bill would specify that any operating agreements of LLCs entered into prior to January 1, 2014 (when RULLCA took effect, replacing the Beverly Killea LLC Act), remain governed by the Beverly Killea LLC Act. This bill would provide that specified provisions of the Labor Code, relating to consideration for employment and employment contracts, shall not apply to membership interests issued by any LLC or foreign LLC to the following persons: any employee of the LLC or foreign LLC or of any parent or subsidiary of either, pursuant to a membership interest purchase plan or agreement, or a membership interest option plan or agreement; and a person who is or is about to become an officer or manager (as appointed or elected by the members) of the LLC or foreign LLC or of any parent or subsidiary of either, in any transaction in connection with securing employment. This bill would replace references to a "holder of a transferable interest in the limited liability company" with "transferee," to reflect the correct terminology in RULLCA. This bill would also correct references to the term "majority in interest" which is not defined under RULLCA. This bill would revise and correct cross-references throughout AB 506 (Maienschein) Page 3 of ? various provisions of RULLCA and would otherwise add missing cross-references to conform potentially conflicting provisions. This bill would modify specified references to participation in the management or conduct of activities of the LLC to clarify that "participate" includes the right to vote. This bill would make other technical, or clarifying changes. 1.Existing law defines various terms for purposes of RULLCA. (Corp. Code Sec. 17701.02.) Existing law defines "electronic transmission by the limited liability company" to mean a communication delivered by specified means, including means of electronic communication to which both of the following apply: the communication is delivered to a recipient who has provided an unrevoked consent to the use of those means of transmission; and the communication creates a record that is capable of retention, retrieval, and review, and that may thereafter be rendered into clearly legible tangible form. However, an electronic transmission by a limited liability company to an individual member is not authorized unless, in addition to satisfying the requirements of this section, the transmission satisfies the requirements applicable to consumer consent to electronic records as set forth in the federal Electronic Signatures in Global and National Commerce Act. (Corp. Code Sec. 17701.02(i)(1)(A)-(C).) Existing law , in relevant part, defines "person" to mean an individual, partnership, limited partnership, trust, estate, association, corporation, limited liability company, or other entity, whether domestic or foreign. (Corp. Code Sec. 17701.02(v).) This bill would revise the definition of "electronic transmission by the limited liability company" by removing the requirement that the electronic transmission by an LLC to an individual member also satisfy requirements set forth under the federal Electronic Signatures in Global and National Commerce Act. This bill would expand to the definition of "person" to AB 506 (Maienschein) Page 4 of ? include a trustee of a trust, including, but not limited to, a trust described under the Probate Code's Trust Law, as specified. 1.Existing law prohibits an LLC operating agreement from doing certain things, including, in relevant part: eliminating the duty of loyalty, the duty of care, or any other fiduciary duty, subject to other specified provisions; eliminating the contractual obligation of good faith and fair dealing under specified provisions of Section 17704.09, subject to other provisions allowing for the operating agreement to modify the fiduciary duties of a member or manager, as specified; unreasonably restricting the duties and rights stated under Section 17704.10, which provides for the right to inspect various LLC documents; the right to a specified annual report for members in an LLC of more than 35 members, among other things; the right to a copy of the articles of incorporation or operating agreement, as specified; varying the requirements of Sections 17707.04 to 17707.08, inclusive, relating to the dissolution of an LLC, except as specified; restricting the right to approve a merger, conversion, or domestication under Section 17710.14 to a member that will have personal liability with respect to a surviving, converted, or domesticated organization; varying any provision under Article 10, relating to mergers and conversions; varying any provision under Article 12, relating to class provisions; or eliminating the obligation of good faith and fair dealing under specified provisions of Section 17704.09, but the operating agreement may prescribe the standards by which the performance of the obligation is to be measured, if the standards are not manifestly unreasonable. (Corp. Code Sec. 17701.10(c).) Existing law provides that, except as provided in the provisions above, and other specified laws, the provisions of RULLCA may be varied as among the members or as between the members and the LLC by the operating agreement, provided, however, that the provisions of Sections 17701.13 (relating to the designation of an agent for service of process and AB 506 (Maienschein) Page 5 of ? required records that must be maintained by the LLC), 17703.01 (providing that every member is an agent of an LLC unless the articles of organization state that the LLC is manager-managed at which point only the manager has agency power), 17704.07 (providing specified rules governing an LLC depending upon whether the LLC is member- or manager-managed), and 17704.08 (requiring reimbursement of any payments and indemnification of any debt, obligation, or other liability incurred by a member or manager in the course of the member's or manager's activities on behalf of the LLC, and authorizing the purchase of insurance for indemnification purposes) can only be varied by a written operating agreement. (Corp. Code Sec. 17701.10(d).) Existing law specifies that, notwithstanding prior statements, and in addition to the matters specified in the provisions above, the operating agreement must not: vary the definitions of RULLCA, as specified, except as specified therein; or vary a member's rights under specified law that provides that every member is an agent of an LLC unless the articles of organization state that the LLC is manager-managed at which point only the manager has agency power; or other specified law, which provides for the right to inspect various LLC documents; the right to a specified annual report for members in an LLC of more than 35 members, among other things; the right to a copy of the articles of incorporation or operating agreement, as specified. (Corp. Code Sec. 17701.10(d).) This bill would modify the provisions limiting what an operating agreement can do. These modifications include: adding or otherwise revising various cross references; consolidating potentially duplicative language prohibiting the elimination of the obligation of good faith and fair dealing by instead providing that, subject to specified law, the operating agreement shall not eliminate the contractual obligation of good faith and fair dealing under existing law, as specified, but the operating agreement may prescribe the standards by which the performance of the obligation is to be measured, if the standards are not manifestly unreasonable as determined at the time the standards are prescribed; repealing the language prohibiting an operating agreement from unreasonably restricting the duties and AB 506 (Maienschein) Page 6 of ? rights under specified law, which provides for the right to inspect various LLC documents; the right to a specified annual report for members in an LLC of more than 35 members, among other things; the right to a copy of the articles of incorporation or operating agreement, as specified; expanding the general prohibition against varying the requirements of Sections 17707.04 to 17707.08, inclusive, relating to the dissolution of an LLC, to apply more generally to the RULLCA article on dissolution and winding up, as well as the RULLCA article on formation of an LLC; and prohibiting the variation of specified provisions relating the application of RULLCA. 1.Existing law governs distributions made by an LLC before its dissolution and winding up. This bill would add a provision specifying that the profits and losses of a limited liability company shall be allocated among the members, and among classes of members, in the manner provided in the operating agreement. If the operating agreement does not otherwise provide, profits and losses must be allocated in proportion to the value, as stated in the required records, of the contributions the limited liability company has received from each member. 2.Existing law provides that an LLC is a member-managed LLC unless the articles of organization and the operating agreement do either of the following: expressly provide that the LLC is or will be "manager-managed" or "managed by managers" or that management of the LLC is or will be "vested in managers;" or include words of similar import. (Corp. Code Sec. 17704.07(a).) Existing law specifies that in a member-managed LLC, certain rules apply, including that a difference arising among members as to a matter in the ordinary course of the activities of the LLC shall be decided by a majority of the members of the LLC which the difference among the members has arisen. (Corp. Code Sec. 17704.07(b).) Existing law specifies that in a manager-managed LLC, certain AB 506 (Maienschein) Page 7 of ? rules apply, including that the consent of all members of the LLC is required to do any of the following: sell, lease, exchange, or otherwise dispose of all, or substantially all, of the LLC's property, as specified; approve a merger or conversion under the RULLCA article governing mergers and conversions; undertake any other act outside of the ordinary course of the LLC's activities; or amend the operating agreement. (Corp. Code Sec. 17704.07(c)(4).) Existing law further specifies that in a manager-managed LLC, a manager may be chosen at any time by the consent of a majority of the members and remains a manager until a successor has been chosen, unless the manager at an earlier time resigns, is removed, or dies, or, in the case of manager that is not an individual, terminates. A manager may be removed at any time by the consent of the majority of the members without notice or cause. (Corp. Code Sec. 17704.07(c)(5).) Existing law generally provides that members have the right to vote on a dissolution of the LLC and on a merger of the LLC as provided under specified law. This bill would modify the above to provide, instead, that an LLC is a member-managed LLC unless the articles of organization contain a statement to the effect that the LLC is to be manager-managed, as required under other specified law. This bill would modify the above rule for member-managed LLCs to instead provide that a difference arising among members as to a matter in the ordinary course of the activities of the LLC shall be decided by a majority of the members. This bill would modify the above rule for member approvals required for certain activities by a manager-managed LLC to delete the requirement that an LLC obtain all members' consent to amend the operating agreement and to approve a merger or conversion under the RULLCA article on mergers and conversions and would, instead, provide that consent of all the LLC members is required to do the following: sell, lease, exchange, or otherwise dispose of all, or substantially all, of the LLC's property, as specified; or except as otherwise provided in the RULLCA article on AB 506 (Maienschein) Page 8 of ? mergers or conversions, any other act outside of the ordinary course of the LLC's activities. This bill would modify the above rule for the removal of a manager of a manager-managed LLC to repeal language giving the LLC authority to remove a manager at any time, upon consent of a majority of the members, without notice. The bill would provide, instead, that the manager can be removed at any time by the consent of a majority of members without cause, subject to the rights, if any, of the manager under any service contract with the LLC. This bill would add that members also have the right to vote on any conversion of the LLC to another business entity, under specified law. 1.Existing law requires that an LLC reimburse for any payment made and indemnify for any debt, obligation, or other liability incurred by a member of a member-managed LLC or the manager of a manager-managed LLC in the course of the member's or manager's activities on behalf of the LLC, if, in making the payment or incurring the debt, obligation, or other liability, the member or manager complied with specified statutory fiduciary duties, duties of loyalty, and duties of care. (Corp. Code Sec. 17704.08(a).) Existing law authorizes and LLC to purchase and maintain insurance on behalf of a member or manager of the LLC against liability asserted against or incurred by the member or manager from that status, even if the operating agreement could not eliminate or limit the person's liability to the LLC for the conduct giving rise to the liability, under specified law. (Corp. Code Sec. 17704.08(b).) This bill would add that, except as provided under specified law (allowing for an operating agreement to alter or eliminate the indemnification for a member or manager provided in the provision above, and to eliminate or limit a member or manager's liability to the LLC and members for money damages, except as specified), an LLC may reimburse any payment made and indemnify any debt, obligation, or other liability incurred by other persons, including, without limitation, any officer, employee, or agent of the LLC, in the course of that person's activities on behalf of the LLC. AB 506 (Maienschein) Page 9 of ? This bill would expand the above authorization for an LLC to purchase and maintain liability insurance for "members" and "managers" to instead authorize the purchase and maintenance of insurance for any person. This bill would require, without limiting the above requirement to reimburse any payment and indemnify any debt, obligation or other liability incurred by a member of a member-managed LLC or manager of a manager-managed LLC, as specified, that an LLC indemnify an agent of the LLC to the extent that the agent has been successful on the merits in defense or settlement of any claim, issue, or matter in any proceeding in which the agent was or is a party or threatened to be made a party by reason of his or her status as an agent of the LLC, against expenses actually and reasonably incurred by the agent, if the agent acted in good faith and in a manner that the agent reasonably believed to be in the best interests of the LLC and its members. This bill would define the terms "agent," "expenses," and "proceeding," for these purposes. 2.Existing law provides various rules for when a person dissociates as a member of the LLC. (Corp. Code Sec. 17706.03.) This bill would add a provision specifying that if a member dies, or a guardian or conservator of the estate is appointed for the member, or a member's interest is being administered by an attorney in fact under a valid power of attorney, the member's executor, administrator, guardian, conservator, or other legal representative may exercise all of the member's rights for the purpose of settling the member's estate or administering the member's property, including any power the member had under the articles of organization or an operating agreement to give a transferee the right to become a member. 3.Existing law includes various provisions governing suits for judicial dissolution. (Corp. Code Sec. 17707.03.) This bill would specify that nothing in those provisions shall be construed to limit the remedies otherwise available to a court of competent jurisdiction over the dissolution. 4.Existing law requires that any certificate or statement of AB 506 (Maienschein) Page 10 of ? conversion be executed and acknowledged by all members, unless a lesser number is provided in the articles of organization or operating agreement and meets specified requirements. (Corp. Code Sec. 17710.06(b).) This bill would instead require that the certificate or statement of conversion be executed and acknowledged by all members of a member-managed LLC or all managers of a manager-managed LLC, unless a lesser number is provided in the articles of organization or operating agreement and meets specified requirements. 5.Existing law provides that each membership interest of the same class of any constituent LLC, other than a membership interest in another constituent LLC that is being canceled and that is held by a constituent LLC or its parent or an LLC of which the constituent LLC is a parent must, unless all members of the class consent, be treated equally with respect to any distribution of cash, property, rights, interests, or securities. Existing law , commonly referred to as the 50/90 rule, provides that notwithstanding the above, except in a merger of an LLC with an LLC that controls at least 90 percent of the membership interests entitled to vote with respect to the merger, the unredeemable membership interests of a constituent LLC may be converted only into unredeemable interests or securities of the surviving LLC or other business entity, or a parent if a constituent LLC or a constituent other business entity or its parent owns, directly or indirectly, prior to the merger, membership interests of another constituent LLC or interests or securities of a constituent other business entity representing more than 50 percent of the interests or securities entitled to vote with respect to the merger of the other constituent LLC or constituent other business entity or more than 50 percent of the voting power, as defined under existing law, of a constituent other business entity that is a domestic corporation, unless all of the members of the class consent. This bill would allow for an LLC to modify the unanimous approval standard above in its written operating agreement. COMMENT AB 506 (Maienschein) Page 11 of ? 1. Stated need for the bill According to the author: This bill would amend the Revised Uniform Limited Liability Company Act ("RULLCA") which took effect January 1, 2014. It will fix certain cross referencing and typographical errors and inconsistencies in RULLCA that make it difficult to understand and less attractive to business owners and investors. It eliminates an inconsistency on what vote is needed to accomplish a merger or conversion and creates indemnification rights for agents similar to those afforded agents of California corporations. It also clarifies RULLCA's transition rules to avoid potential disputes as to whether RULLCA or prior law, the Beverly-Killea Limited Liability Company Act ("Beverly-Killea"), governs the limited liability company ("LLC"). 2. Bill seeks to not only correct ambiguities and inconsistencies in the recently enacted RULLCA, but also substantively improve various provisions of the act As stated by the sponsor of this bill, the Partnership and Limited Liability Companies Committee of the Business Law Section of the State Bar of California (PLLC committee), this bill is intended to address ambiguities and inconsistencies in the California Revised Uniform Limited Liability Company Act (RULLCA), and to make further improvements. The sponsor explains that these inconsistencies largely exist because when SB 323 (Vargas, Ch. 419, Stats. 2012) was enacted in 2012 to implement RULLCA in this state, it did not replicate the National Conference of Commissioners on Uniform State Laws' (NCCUSL) model law, word-for-word. Instead, the Legislature specifically sought to incorporate numerous provisions from the state's preceding act, the Beverly Killea Limited Liability Company Act (Cal. Corp Code [Secs.] 17000-17656), in order to improve upon the NCCUSL version. As described by the PLLC committee: The carried-over provisions include[d:] (i) important topics (e.g., meetings, officers, voting rights, and mergers and conversions) that were not covered in the NCCUSL version; (ii) particular requirements of the Business Programs Division of the California Secretary of State (e.g., member information rights and certain restrictions on operating agreement AB 506 (Maienschein) Page 12 of ? amendments; (iii) certain investor protections (e.g., the requirement for filing biennial statements of information); and (iv) other provisions (e.g., for limited liability company ("LLC") dissolutions that the Committee believed were more comprehensive and substantially better than what was included in the NCCUSL version of the same topic. In general, the Committee believes that NCCUSL's version was overly slanted in favor of LLC management, but that RULLCA as enacted in California is a more balanced law that more effectively protects the interests of LLC members. Challenges were involved, however, in carrying over provisions from Beverly Killea into SB 323 because the statutory numbering convention was different, the organizational structure was different, and various defined terms in Beverly Killea differed from the corresponding terms in the NCCUSL version of RULLCA. [ . . . ] In addition, since SB 323's enactment, the Committee has engaged in robust discussions with, and has received comments from, many experienced LLC law practitioners in California. As a result of those discussions, the Committee collected some further suggestions for clarification and improvement of RULLCA. This bill would correct the ambiguities and inconsistencies, and make some further improvements for the benefit of California attorneys and judges who must work with and interpret RULLCA in the future, as well as for the benefit of all California business enterprises that wish to conduct their business in the LLC form. The PLLC committee draws particular attention to one provision of the bill that would amend RULLCA's transition rule in Section 17713.04 of the Corporations Code, which currently provides that RULLCA generally applies only to the acts or transactions by an LLC or by the members or managers of the LLC, or "contracts" entered into by the LLC or by the members or managers of the LLC, on or after January 1, 2014, and that the prior law (the Beverly Killea LLC Act) governs all acts or transactions by an LLC or by the members or managers of the LLC company occurring, or contracts entered into by the LLC or by the members or managers of the LLC, prior to that date. This bill, the sponsor writes, seeks to clarify that the term "contracts" includes "LLC operating agreements, such that "the operating agreements of LLCs existing prior to January 1, 2014 are governed by Beverly Killea and should not necessarily need to be amended after that date. RULLCA applies to all LLCs and operating agreements AB 506 (Maienschein) Page 13 of ? entered into on or after January 1, 2014. Whether the operating agreement of an existing LLC should be amended after January 1, 2014, e.g., to take advantage of RULLCA provisions, is an issue for practitioners to decide in consultation with their clients on a case-by-case basis." Other notable changes proposed to the current RULLCA, include: The addition of a provision not previously carried over by SB 323 from the Beverly Killea LLC Act (former Corp. Code Sec. 17110(d)), which provides that certain provisions of the Labor Code relating to property pledged by an employee in connection with an employment offer (Labor Code Sec. 406) and prohibiting the conditioning of an employment offer or an investment in the business by the prospective employee (Labor Code Sec. 407), do not apply to specified membership interests issued by the LLC or foreign LLC. The incorporation of a provision specifying a default rule for how to allocate losses and profits among members, that is substantially similar to the default rule provided under the Beverly Killea LLC Act (former Corp. Code Sec. 17202) and the default rule for partnerships under the California Revised Uniform Partnership Act (Corp. Code Sec. 15905.035). Specifically, the bill would provide that the allocation of profits and losses among LLC members, and among classes of members, in the manner provided in the operating agreement. In the event that the operating agreement is silent, profits and losses would be allocated in proportion to the value, as stated in the required records, of the contributions the LLC has received from each member. The removal of authorization for a manager-managed LLC to remove a manager at any time upon consent of a majority of the members, without any notice. The bill would instead provide that the manager can be removed at any time by the consent of a majority of members without cause, subject to the rights, if any, of the manager under any service contract with the LLC. The addition of language confirming that members of an LLC have, in addition to the right to vote on a dissolution or merger of the LLC under specified law, the right to vote on any conversion of the LLC to another business entity, under specified law. To carry over a provision specifying what happens if a member dies, or a guardian or conservator of the estate is appointed for the member, or a member's interest is being administered by an attorney in fact under a valid power of attorney-namely, the member's executor, administrator, guardian, conservator, AB 506 (Maienschein) Page 14 of ? or other legal representative would be authorized to exercise all of the member's rights for the purpose of settling the member's estate or administering the member's property, including any power the member had under the articles of organization or an operating agreement to give a transferee the right to become a member. 3. Indemnification provisions Existing law requires that an LLC reimburse any payment made and indemnify any debt, obligation, or other liability incurred by a member of a member-managed LLC or the manager of a manager-managed LLC in the course of the member's or manager's activities on behalf of the LLC, if, in making the payment or incurring the debt, obligation, or other liability, the member or manager complied with specified statutory fiduciary duties, duties of loyalty, and duties of care. This section further authorizes an LLC to purchase and maintain insurance on behalf of a member or manager of the LLC against liability asserted against or incurred by the member or manager from that status, even if the operating agreement could not eliminate or limit the person's liability to the LLC for the conduct giving rise to the liability, under specified law. This bill would now add that an LLC may reimburse any payment made and indemnify any debt, obligation, or other liability incurred by other persons, including, without limitation, any officer, employee, or agent of the LLC, in the course of that person's activities on behalf of the LLC, except as specified. The bill would also expand the existing authorization for an LLC to purchase and maintain liability insurance for "members" and "managers" so as to authorize the purchase and maintenance of liability insurance for any person. Furthermore, the bill would require that an LLC indemnify an agent of the LLC to the extent that the agent has been successful on the merits in defense or settlement of any claim, issue, or matter in any proceeding in which the agent was or is a party or threatened to be made a party by reason of his or her status as an agent of the LLC, against expenses actually and reasonably incurred by the agent, if the agent acted in good faith and in a manner that the agent reasonably believed to be in the best interests of the LLC and its members. The bill also, however, expressly states that this new requirement does AB 506 (Maienschein) Page 15 of ? not limit the LLC's broader indemnification obligation for members and managers. According to materials provided by the sponsor, the new additions effectively provide for indemnification of agents that is similar to the existing law indemnification for corporate agents under Section 317 of the Corporations Code. 4. Bill would allow for LLCs to opt out of the 50/90 rule by way of written operating agreements Under existing law, in a merger of one LLC into another, unless the LLC is merging with an LLC that controls at least 90 percent of the membership interests entitled to vote for or against the merger, the unredeemable membership interests of a constitute LLC can be converted only into unredeemable interests or securities of the surviving LLC or other business entity, or a parent (i.e. the interests cannot be "cashed out"), if, prior to the merger, the constituent LLC or its parent owns, directly or indirectly, more than 50 percent of the membership interests of other constituent entitled to vote with respect to the merger of the other constituent LLC, unless all members of the class consent. (See Corp. Code Sec. 17710.12(b)(2).) In other words, in order to protect minority members from being forced to cash out in a merger, existing law requires that unanimous member approval be given for the merger to occur if the acquiring party in a merger owns more than 50 percent but less than 90 percent of all of the interests of the target LLC that are entitled to vote, prior to the merger. Otherwise, any unredeemable membership interests can only be converted into unredeemable membership interests in the surviving LLC or surviving business entity. This bill would now add language authorizing the LLC to require something other than unanimous approval in their written operating agreement. In order to address concerns, the author has agreed to remove this language, as follows: Author's amendment : On page 43, strike out line 3, in its entirety AB 506 (Maienschein) Page 16 of ? On page 43, line 4, strike "notwithstanding" and insert "(2) Notwithstanding" Support : Conference of California Bar Associations Opposition : None Known HISTORY Source : Partnership and Limited Liability Companies Committee of the Business Law Section of the California State Bar Related Pending Legislation : None Known Prior Legislation : SB 323 (Vargas, Ch. 419, Stats. 2012), recast and reorganized the Beverly-Killea Limited Liability Company Act into the current California Revised Uniform Limited Liability Company Act (RULLCA). SB 1186 (Torres, 2014) would have, among other things, amended the 50/90 rule for corporations to only require majority approval instead of unanimous approval to force minority shareholders to cash out in a merger covered by the 50/90 rule. That bill was held in this Committee and ultimately died without a hearing. Prior Vote : Assembly Floor (Ayes 76, Noes 0) Assembly Banking and Finance Committee (Ayes 12, Noes 0) **************