BILL ANALYSIS                                                                                                                                                                                                    Ó



          SENATE COMMITTEE ON APPROPRIATIONS
                             Senator Ricardo Lara, Chair
                            2015 - 2016  Regular  Session

          AB 2637 (Wilk) - Franchise investments:  offer and sale of  
          registered franchises:  registration exemption
          
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          |Version: June 16, 2016          |Policy Vote: B. & F.I. 7 - 0,   |
          |                                |          JUD. 7 - 0            |
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          |Urgency: No                     |Mandate: No                     |
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          |Hearing Date: August 1, 2016    |Consultant: Debra Cooper        |
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          This bill meets the criteria for referral to the Suspense File.


          Bill  
          Summary:  AB 2637 would exempt a franchisor from the requirement  
          to re-register its franchise disclosure document with the  
          Department of Business Oversight (DBO) each time it negotiates  
          changes to the franchise agreement described in that disclosure  
          document with a franchisee, as specified.


          Fiscal  
          Impact:   
           Unknown, but potentially significant costs to DBO to  
            investigate any reported violations. (State Corporations Fund)


           Potential minor cost savings to DBO due to a reduction in  
            administrative workload for filing exempted franchise  
            disclosure documents. (State Corporations Fund)








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          Background:  The California Franchise Investment Law (CFIL) regulates  
          franchise investment opportunities by subjecting various aspects  
          of the franchise relationship to filing, review, and oversight  
          by DBO. 
          In 2004, the Business Law Section of the California State Bar  
          sponsored AB 2921 (Cox, Chapter 458, Statutes of 2004) to makes  
          changes to the CFIL to help franchisees by promoting  
          transparency. The Franchise Law Committee of the Business Law  
          Section of the California State Bar is sponsoring this bill to  
          mitigate unintended consequences of Corporations Code Section  
          31109.1, created by AB 2921, which hindered the ability of  
          franchisees and franchisors to negotiate franchise agreements. 


          The intended purpose of Section 31109.1 was to create full  
          disclosure to promote fairness among franchises. However,  
          according to the sponsors, Section 31109.1 actually served to  
          decrease the number of situations in which franchisors were  
          willing to negotiate with franchisees. 




          Proposed Law:  
            
          This bill would remove the following conditions that must be met  
          in order for a franchisor to claim an exemption from having to  
          amend its franchise registration in connection with a negotiated  
          sale:
                 Within five days, a prospective franchisee must receive  
               a summary description of each material negotiated term that  
               was negotiated by the franchisor for a California franchise  
               during the prior 12 months.
                 A prospective franchisee must receive a statement  
               indicating that copies of the negotiated terms are  
               available upon written request. 
                 A prospective franchisee must receive, upon request, the  
               name, telephone number, and address of the representative  
               of the franchisor.
                 The negotiated terms, on the whole, confer additional  
               benefits on the franchisee.










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          This bill would instead add to the requirements that a  
          franchisor must meet that the cover page, a state cover page, or  
          a state addendum of the disclosure document specifically states,  
          "You and the franchisor may agree to sign the forms of franchise  
          agreement and other agreements attached to this disclosure  
          document. However, California law does not prohibit you and the  
          franchisor from negotiating changes to the franchise agreement  
          and other agreements, nor does it require you or the franchisor  
          to negotiate any changes."




          Related  
          Legislation:  AB 2921 (Cox, Chapter 458, Statutes of 2004)  
          revises the conditions that are required to be satisfied for the  
          exemption from registration for a franchise agreement with an  
          existing franchisee of a franchisor.


          Staff  
          Comments:  The provisions of this bill have the potential to  
          create a new category of fraud and abuse that would be  
          investigated and enforced by DBO. DBO would be able to enforce  
          any violations under Section 31400 of the Corporations Code  
          which states that "whenever it appears to the commissioner that  
          any person has engaged or is about to engage in any act or  
          practice constituting a violation of any provision of this law  
          or any rule or order hereunder, the commissioner may in the  
          commissioner's discretion bring an action, or the commissioner  
          may request the Attorney General to bring an action in the name  
          of the people of the State of California, in the superior court  
          to enjoin the acts or practices or to enforce compliance with  
          this law or any rule or order hereunder. Upon a proper showing a  
          permanent or preliminary injunction, restraining order or writ  
          of mandate shall be granted and a receiver or conservator may be  
          appointed for the defendant or the defendant's assets." As such,  
          DBO would be able to investigate violations to the extent that  
          they are aware of violations. DBO currently has an Enforcement  
          Division that takes enforcement actions and orders issued by the  
          commissioner.


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