BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                     AB 587


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          Date of Hearing:  May 13, 2015


                        ASSEMBLY COMMITTEE ON APPROPRIATIONS


                                 Jimmy Gomez, Chair


          AB  
          587 (Chau) - As Amended April 30, 2015


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          |Policy       |Housing and Community          |Vote:|7 - 0        |
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          |             |Judiciary                      |     |10 - 0       |
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          Urgency:  No  State Mandated Local Program:  YesReimbursable:   
          Yes


          SUMMARY:


          This bill establishes a tax abatement program until 2019,  
          allowing mobilehome owners to bring their title into compliance  
          without having to pay all of the past due taxes and fees on the  








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          home, often accrued by a previous owner.  The bill also creates  
          a temporary moratorium, coinciding with the abatement program,  
          on evictions that are based on lack of accurate title, as long  
          as the park resident has applied for the abatement program and  
          completes the title transfer within a specified time.  


          FISCAL EFFECT:


          1)Significant costs to HCD of $360,000 (Mobilehome Manufactured  
            Home Revolving Fund) in 2015-16, 2016-17, and 2017-18 to fund  
            five positions to process the anticipated increase in  
            applications.  HCD estimates approximately 100,000 mobilehome  
            owners could be eligible to participate in the tax abatement  
            program.  If 10% of those eligible participate, 30,000  
            additional applications for registration and titling will be  
            generated over the 3-year period.


          2)Foregone property tax revenues to local taxing entities,  
            unknown but potentially in the low millions of dollars,  
            resulting from the abatement program provisions that cap the  
            amount of delinquent property taxes owed and waive interest  
            and penalties. These losses are not reimbursable under the  
            bill. Staff notes that not all past taxes are forgiven under  
            this bill, but rather only a portion of the taxes accrued by  
            the current owner (applicant). Past owners are still liable  
            for their taxes and penalties owed.


          3)Potentially reimbursable costs to county tax collectors to  
            implement the program.


          COMMENTS:


          1)Purpose.  According to the author, there are thousands,  








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            perhaps tens of thousands, of homeowners who believe they own  
            their homes but never had title properly transferred to them.  
            Because of the sometimes informal nature of mobilehome sales,  
            buyers and sellers may not be aware that delinquent taxes and  
            fees prevent title from transferring.  Sellers may not even be  
            aware that a delinquency exists because of, for example,  
            limited notification requirements for vehicle license fee  
            (VLF) delinquencies, or outdated ownership information at the  
            county or state level.  In these situations, a buyer may only  
            become aware of the delinquency when he or she tries to  
            transfer title at HCD.  If a seller does not pay the  
            delinquent fees or taxes and associated penalties, and the  
            buyer cannot pay them but has already purchased the  
            mobilehome, they are left with few options other than to keep  
            the home with an outdated title.


            The three-year abatement program proposed by this bill would  
            reduce past due taxes and fees by capping the amount owed and  
            waiving penalties and interest.  According to the author, this  
            encourages homeowners with outdated title to come forward and  
            apply to transfer title into their names, thereby updating  
            state and county records to ensure accurate VLF and local  
            property tax (LPT) billing in the future. The bill further  
            encourages owners to come forward by creating a temporary  
            moratorium on evictions based on lack of accurate title as  
            long as the park resident has applied for the abatement  
            program.


          2)Background. HCD is responsible for the titling and  
            registration of mobilehomes.  Homes that were purchased new  
            prior to July 1, 1980 were treated as vehicles and not subject  
            to LPT, but rather to an "in lieu" VLF paid annually to HCD.   
            Mobilehomes that were purchased after July 1, 1980 are  
            generally subject to LPT.  Homeowners have the option to  
            voluntarily transfer their homes from the VLF system to the  
            LPT system, but not vice-versa.  









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            Prior to transferring title of a mobilehome, a buyer of a home  
            on the LPT system must obtain a Tax Clearance Certificate  
            (TCC) from the county tax collector indicating that all  
            property taxes have been paid.  Similarly, if the mobilehome  
            is on the VLF system, all past due fees and penalties must be  
            paid to HCD prior to transfer of title, as well as a use tax.   
            Regardless of whether a mobilehome is on the VLF or LPT  
            system, delinquent fees or taxes prevent HCD from amending the  
            title of that home under existing law.  If a buyer cannot pay,  
            and the seller will not pay or cannot be located, the buyer is  
            left without legal proof of ownership of the home, and HCD,  
            the county tax collector, and the county tax assessor may not  
            have up-to-date ownership information for the home.  


            Nonconformance with HCD's titling and registration  
            requirements can cause a number of problems for mobilehome  
            owners, including preventing them from legally making repairs  
            to the home, insuring the home, and from transferring  
            ownership of the home to another party.  Nonconformance may  
            also subject the homeowner to eviction from a park under  
            current law.


          3)Arguments in Support. Advocates for mobilehome owners as well  
            as many homeowners' associations believe this bill provides a  
            fair and commonsense approach to "ensure that mobilehome  
            owners are not caught in an untenable position due to the  
            liabilities of a previous owner, and ensures that they will  
            not be evicted from their mobilehome park due to lack of  
            compliance with local or state laws, but rather be allowed to  
            remain in their home."


            They further note that in addition to unraveling problems  
            caused by years of bad registration practices, the bill  
            "provides the framework for ensuring in the future that state  
            and local government has procedures in place to ensure that  








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            title is properly transferred when a home is sold... and that  
            they can collect fees and taxes and ensure their records are  
            accurate and up-to-date." 


          4)Arguments in Opposition.  The California Association of County  
            Treasurers and Tax Collectors (CACTTC) oppose this bill unless  
            significantly amended to, among other things, eliminate any  
            abatement of taxes-the central feature of the bill.  CACTTC  
            disputes the premise of the bill that many people purchasing a  
            mobilehome do not realize the necessary steps that must be  
            taken to properly transfer title and ownership of the home.   
            In addition, CACTTC objects to the large financial losses  
            that, it asserts, counties would incur if this bill were to  
            become law.  


          5)Related legislation.  


             a)   AB 682 (Williams), pending in this Committee, would  
               authorize a person to have specified alternation,  
               conversion, and repairs made to a mobilehome, for purposes  
               of implementing the Mobilehome park Utility Upgrade  
               Program, without filing an application with HCD. 


             b)   AB 999 (Daly), pending in this Committee, would  
               establish due process requirements for mobilehome park  
               owners to dispose of an abandoned mobilehome without first  
               being required to pay any unpaid property taxes on the  
               mobilehome.  


          


          Analysis Prepared by:Jennifer Swenson / APPR. / (916)  
          319-2081








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