BILL ANALYSIS                                                                                                                                                                                                    Ó






           ----------------------------------------------------------------- 
          |SENATE RULES COMMITTEE            |                        SB 574|
          |Office of Senate Floor Analyses   |                              |
          |(916) 651-1520    Fax: (916)      |                              |
          |327-4478                          |                              |
           ----------------------------------------------------------------- 


                                   THIRD READING 


          Bill No:  SB 574
          Author:   Pan (D)
          Amended:  4/22/15  
          Vote:     21  

           SENATE EDUCATION COMMITTEE:  7-0, 4/29/15
           AYES:  Liu, Block, Hancock, Leyva, Mendoza, Monning, Pan
           NO VOTE RECORDED:  Runner, Vidak

           SENATE APPROPRIATIONS COMMITTEE:  7-0, 5/28/15
           AYES: Lara, Bates, Beall, Hill, Leyva, Mendoza, Nielsen
           
           SUBJECT:   University of California:  alternative investment  
                     information


          SOURCE:    California Newspaper Publishers Association
          
          DIGEST:   This bill requires the University of California (UC)  
          to obtain specified information from each private equity fund,  
          venture fund, hedge fund, or absolute return fund in which the  
          UC provides or has provided funds for investment.
          


          ANALYSIS:   
          Existing law:

          1)Defines "alternative investment" as an investment in a private  
            equity fund, venture fund, hedge fund, or absolute return  
            fund.

          2)Exempts specified records regarding alternative investments in  








                                                                     SB 574  
                                                                    Page  2


            which public investment funds are invested from disclosure,  
            unless the information has already been publicly released by  
            the keeper of the information.  Information exempted from  
            disclosure includes due diligence materials that are  
            proprietary, quarterly and annual financial statements,  
            meeting materials, records containing information regarding  
            the portfolio positions in which alternative investment funds  
            invest, capital call and distribution notices, and alternative  
            investment agreements and all related documents.

          3)Requires disclosure of specified information regarding  
            alternative investments. These required disclosures include  
            the following:

             a)   The name, address, and vintage year of each alternative  
               investment vehicle.

             b)   The dollar amount of the commitment made to each  
               alternative investment vehicle by the public investment  
               fund since inception.

             c)   The dollar amount of cash contributions made by the  
               public investment fund to each alternative investment  
               vehicle since inception.

             d)   The dollar amount, on a fiscal year-end basis, of cash  
               distributions received by the public investment fund from  
               each alternative investment vehicle.

             e)   The dollar amount, on a fiscal year-end basis, of cash  
               distributions received by the public investment fund plus  
               remaining value of partnership assets attributable to the  
               public investment fund's investment in each alternative  
               investment vehicle.

             f)   The net internal rate of return of each alternative  
               investment vehicle since inception.

             g)   The investment multiple of each alternative investment  
               vehicle since inception.

             h)   The dollar amount of the total management fees and costs  
               paid on an annual fiscal year-end basis, by the public  
               investment fund to each alternative investment vehicle.







                                                                     SB 574  
                                                                    Page  3



             i)   The dollar amount of cash profit received by public  
               investment funds from each alternative investment vehicle  
               on a fiscal year-end basis.  (Government Code § 6254.26) 

          4)Governs, pursuant to the California Public Records Act (CPRA),  
            the disclosure of information collected and maintained by  
            public agencies. Generally, all public records are accessible  
            to the public upon request, unless the record requested is  
            exempt from public disclosure. There are 30 general categories  
            of documents or information that are exempt from disclosure,  
            essentially due to the character of the information.  Unless  
            it is shown that the public's interest in disclosure outweighs  
            the public's interest in non-disclosure of the information,  
            the exempt information may be withheld by the public agency  
            that has custody of the information. 

          5)Defines state agency, for purposes of the CPRA, to include  
            every state officer, department, division, bureau, board, and  
            commission or other state body or agency, except for the  
            Legislature and the Judiciary.  The California State  
            University, the University of California, and the California  
            Community Colleges are considered to be state agencies for  
            this purpose.  (Government Code § 6250, et. al.)

          This bill requires the University of California to obtain the  
          information required to be disclosed under specified Government  
          Code provisions (§ 6254.26) from each private equity fund,  
          venture fund, hedge fund, or absolute return fund in which the  
          UC provides, or has provided, funds for investment.

          Comments


          1)Need for the bill.  Under the CPRA, specified information  
            about alternative investments must be disclosed if public  
            funds are used for investment.  According to the author, the  
            courts recently ruled that the UC Regents are allowed to  
            refrain from obtaining this information from the two largest  
            venture capital partners with whom the UC invests.  As a  
            result, the UC Regents can avoid the disclosure requirements  
            which would otherwise apply since they cannot disclose  
            information which they do not possess.  








                                                                     SB 574  
                                                                    Page  4


            According to the author, the UC has invested over $239 million  
            in 10 venture capital funds.  This bill would require the UC  
            to obtain the specified information and allow Californians and  
            UC employees to track the performance of investments on which  
            their pensions rely. This bill is sponsored by the California  
            Newspaper Publishers Association.

          2)Related Court Cases. This bill is intended to respond to a  
            ruling by the California Court of Appeals in Regents of the  
            University of California v. Superior Court (2013) 222 Cal.  
            App. 4th 383, appealing the decision of the Superior Court for  
            Alameda County in regards to a request by Reuters America LLC  
            for specific financial information from the UC Regents  
            pertaining to their investments in specified funds.

            The court noted that the primary issue in the case was whether  
            a public agency can be required under the California Public  
            Records Act (Government Code § 6250, et. seq.) to seek records  
            it does not prepare, own, use or retain in the conduct of its  
            business. 

            The Superior Court found that the Regents were required to use  
            "objectively reasonable efforts" to obtain individual fund  
            information for the Regent's current investments from Kleiner  
            Perkins Caulfield & Byers (Kleiner Perkins) and Sequoia  
            Capital (Sequoia) even though the Regents had not prepared,  
            owned, used, or retained this fund information.  However, this  
            ruling was overturned by the appeals court which found that,  
            because the information was not prepared, owned, used, or  
            retained by the Regents, records reflecting such information  
            in the hands of Kleiner Perkins and Sequoia were not "public  
            records" within the meaning of the California Public Records  
            Act. 

          3)History.  Court documents noted that as of October 2012, the  
            Regents owned investment assets of about $71.6 billion which  
            help pay for employee pensions, student scholarships,  
            research, and other university operations.  Since 1979, about  
            2 percent of the Regent's multi-billion dollar investment  
            portfolio has been invested in "private equity;" limited  
            partnerships formed and managed by private parties to invest  
            in private companies. 

            Until 2003, the Regents did receive information from the  







                                                                     SB 574  
                                                                    Page  5


            private equity firms that allowed it to monitor its private  
            equity investments.  In 2003, however, in response to a claim  
            by the Coalition of University Employees, the Alameda County  
            Superior Court ruled that this information was subject to  
            disclosure under the California Public Records Act.  A UC  
            Regents petition to seek review of that decision by an appeals  
            court was denied.  Following this decision, the two private  
            equity firms that were the subject of the 2013 court case,  
            Kleiner Perkins and Sequoia, stopped providing fund specific  
            information and stopped inviting the Regents to participate in  
            new funds.  It appears that Sequoia did allow the Regents to  
            invest in private equity funds again beginning in 2010. 

          FISCAL EFFECT:   Appropriation:    No          Fiscal  
          Com.:YesLocal:   No

          According to the Senate Appropriations Committee:

           UC indicates that this bill would require it to obtain the  
            required information from the investment firms through  
            litigation.  UC anticipates such costs to be at least  
            $500,000. 



          SUPPORT:   (Verified5/28/15)


          California Newspaper Publishers Association, CNPA Services, Inc.  
          (source)
          American Federation of State, County and Municipal Employees,  
          AFL-CIO


          OPPOSITION:   (Verified5/28/15)


          University of California


          Prepared by:Kathleen Chavira / ED. / (916) 651-4105
          5/31/15 12:22:21









                                                                     SB 574  
                                                                    Page  6


                                   ****  END  ****