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 ----------------------------------------------------------------- | | | | | | ----------------------------------------------------------------- |--------------------------------+--------------------------------| | | | |Version: June 16, 2016 |Policy Vote: B. & F.I. 7 - 0, | | | JUD. 7 - 0 | | | | |--------------------------------+--------------------------------| | | | |Urgency: No |Mandate: No | | | | |--------------------------------+--------------------------------| | | | |Hearing Date: August 1, 2016 |Consultant: Debra Cooper | | | | ----------------------------------------------------------------- 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) AB 2637 (Wilk) Page 1 of ? 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. AB 2637 (Wilk) Page 2 of ? 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. -- END -- AB 2637 (Wilk) Page 3 of ?