BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                     SB 197  


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          Date of Hearing:  July 15, 2015


                        ASSEMBLY COMMITTEE ON APPROPRIATIONS


                                 Jimmy Gomez, Chair


          SB 197  
          (Block) - As Amended June 25, 2015


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          Urgency:  No  State Mandated Local Program:  YesReimbursable:   
          No


          SUMMARY:


          This bill allows licensees under the California Finance Lenders  
          Law (CFLL) to pay compensation to unlicensed persons or  
          companies for the referral of one or more borrowers to the  
          licensee so long as the referral results in the consummation of  
          a commercial loan, the loan contract provides an annual  
          percentage rate that does not exceed 36%, the licensee discloses  
          the referral arrangement to the borrower, and the licensee  
          obtains documentation from the prospective borrower confirming  
          the borrower's commercial status and creditworthiness.  The bill  
          requires licensees to maintain records of all compensation paid  
          for at least four years and to report annually information on  








                                                                     SB 197  


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          referrals requested by the Commissioner of Business Oversight.


          FISCAL EFFECT:


          Likely minor GF annual administrative costs to the Department of  
          Business Oversight, in the range of $20,000-30,000, to examine  
          loans for compliance; minor and absorbable enforcement costs.


          COMMENTS:


          1)Purpose.  According to the author, allowing CFLL-licensed  
            commercial lenders to pay fees for the successful referral of  
            business eliminates a competitive disadvantage in customer  
            acquisition relative to other commercial lenders.  The  
            sponsors believe companies that are not subject to the CFLL  
            often offer less favorable loan terms than CFLL licensees, but  
            borrowers never learn about the availability of more favorable  
            loans because CFLL lenders cannot compensate for referral of  
            business.  The author and supporters contend SB 197 will  
            improve the ability of lenders to identify small businesses  
            customers and help them access favorable credit.


          2)License to Facilitate.  Current law prohibits CFLL licensees  
            from paying compensation to any person or company that is  
            unlicensed in exchange for the referral of business.  This  
            places CFLL licensees at a disadvantage compared with merchant  
            advance companies, who are not licensed because they are  
            technically not making loans, and companies that partner with  
            banks, who are not licensed because they offer loans under the  
            partnering banks' charters.  Supporters argue referrals remain  
            the most efficient means of acquiring new small business  
            customers as general advertising cannot be sufficiently  
            targetted.  The prohibition on referral fees is intended to  
            protect borrowers from predatory lending.  AB 197 seeks to  








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            protect customers by limiting fees paid to only those  
            referrals that result in consummated loans that meet the  
            bill's specified lending requirements.


          Analysis Prepared by:Joel Tashjian / APPR. / (916)  
          319-2081