BILL ANALYSIS                                                                                                                                                                                                    



                                                                      AB 655
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          Date of Hearing:  May 12, 2009

                           ASSEMBLY COMMITTEE ON JUDICIARY
                                  Mike Feuer, Chair
                    AB 655 (Emmerson) - As Amended: April 16, 2009

                    PROPOSED CONSENT (As Proposed to be Amended)

           SUBJECT :  SELF-STORAGE FACILITIES: LIEN SALES

           KEY ISSUE  :  SHOULD VARIOUS NON-CONTROVERSIAL CHANGES BE MADE TO  
          THE CALIFORNIA SELF-STORAGE ACT'S REMEDIES AND PROCEDURES?  

           FISCAL EFFECT  :  As currently in print this bill is keyed  
          non-fiscal.

                                      SYNOPSIS

          This bill proposes various non-controversial changes to the  
          remedies and procedures of the California Self-Service Storage  
          Facility Act (the Act) for self-storage facility owners when  
          occupants are delinquent in paying rent or other charges.  The  
          bill, as proposed to be amended, seeks to permit owners who send  
          a preliminary lien notice to an occupant by first-class mail  
          with certificate of mailing to, upon effective date of the lien,  
          deny the occupant access, enter the space, and remove property  
          for safekeeping.  The bill requires the owner to send an  
          occupant notice of a lien sale while also providing the occupant  
          with specified information about how to challenge the lien, and  
          provides that the lien sale can be no earlier than 21 days after  
          the date of mailing.  The bill requires that the lien sale be  
          advertised in a newspaper of general circulation if one exists  
          in the district where the sale will be held.  As currently in  
          print, the bill would provide that the owner may assess a late  
          fee equal to the greater of $20, or 20% of the monthly rent, and  
          recover reasonable expenses incurred in collecting rent and  
          enforcing the lien.  However, in response to concerns raised by  
          this Committee this part of the bill pertaining to late fees  
          will be deleted.  In addition, the author has proposed a  
          non-controversial technical amendment, whereby the advertisement  
          for a lien sale shall no longer include the occupant's storage  
          space number, in order to protect the occupant's privacy and  
          belongings.  This bill is supported by the sponsor, California  









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          Self Storage Association, 103 self-storage facility owners and  
          managers, and numerous individuals.  This bill has no known  
          opposition.  The bill was approved on April 14, 2009 by the  
          Assembly Committee on Business and Professions by a vote of 8-0.
           
          SUMMARY  :  Makes various changes to the remedies and procedures  
          of the California Self-Service Storage Facility Act (the Act)  
          for self-storage facility owners when occupants are delinquent  
          in paying rent or other charges.  Specifically,  this bill  : 

          1)Permits an owner who sends an occupant a preliminary lien  
            notice by first-class mail with certificate of mailing, if the  
            total amount due has not been paid within 14 days of the  
            termination date provided in the preliminary notice, to deny  
            the occupant access to the space, enter the space, and remove  
            the property for safe keeping.

          2)Requires an owner, after sending a preliminary lien notice, to  
            send an occupant a notice of lien sale stating all of the  
            following:

             a)   That the occupant's right to use the space has  
               terminated and the occupant no longer has access to the  
               property;
             b)   That any stored property is subject to a lien, the  
               current amount of the lien, and that the lien will continue  
               to increase if rent is not paid;
             c)   That the property will be sold to satisfy the lien after  
               a specified date not less than 21 days from the mailing of  
               the lien sale notice;
             d)   That the occupant may regain full use of the space by  
               paying the full lien prior to the date of sale that was  
               provided;
             e)   A "conspicuous" statement that the occupant may  
               challenge the sale by filing an action in any court of  
               competent jurisdiction;
             f)   That any excess proceeds of the sale (over the lien  
               amount and costs of sale) will be retained by the owner,  
               and that the occupant can claim them for one year after the  
               sale, after which they will escheat to the county where the  
               sale takes place.

          3)Eliminates the occupant's right to return a declaration in  









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            opposition to the lien sale, as provided under existing law.

          4)Requires the lien sale to be advertised once a week for two  
            weeks consecutively in a newspaper of general circulation in  
            the jurisdiction where the sale is to be held.

          5)Provides that the advertisement must include a general  
            description of the goods, the name of the person on whose  
            account they are being stored, the space number of the  
            occupant, and the name and location of the storage facility.

          6)Provides that if there is no newspaper of general circulation  
            published in the judicial district where the sale is to be  
            held, that the advertisement shall be posted at least 10 days  
            before the sale, in at least six conspicuous places in the  
            neighborhood of the proposed sale.  

          7)Permits a person claiming a right to the stored goods prior to  
            any lien sale to pay the lien amount and one month's rent in  
            advance, in which case the owner must retain the property  
            pending a court's disposition of it; and prescribes the  
            procedures to be followed if a court order is not obtained.

          8)As currently in print, permits an owner to assess a late fee  
            equal to the greater of $20 or 20% of the monthly rent, and to  
            recover reasonable expenses incurred in collecting rent and  
            enforcing a lien.  In response to concerns raised by this  
            Committee, the author has decided to remove these provisions  
            from the bill.  
           
          EXISTING LAW  :

          1)Permits an owner who sends an occupant a preliminary lien  
            notice by certified mail to, upon the effective date of the  
            lien, deny the occupant access to the space, enter the space,  
            and remove property for safe keeping.  However, if the owner  
            sends notice by first-class mail with certificate of mailing,  
            the owner may not remove the property for at least 14 days  
            following the effective date of the lien.  (Business &  
            Professions Code section 21705.)
           
           2)Requires an owner to send an occupant a notice of lien sale  
            stating that any stored property will be sold to satisfy the  









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            lien after a specified date that is at least 14 days from the  
            date of mailing, unless the amount of the lien is paid or the  
            occupant returns a declaration in opposition to the lien sale  
            in a specified form.  (Business & Professions Code section  
            21705(c).)  

           3)Requires the lien sale to be advertised in a newspaper of  
            general circulation or posted in conspicuous places in the  
            neighborhood of the proposed sale, as specified.  (Business &  
            Professions Code section 21707.)
             
           4)Permits a person claiming a right to the stored goods prior to  
            any lien sale to pay the lien amount and reasonable expenses,  
            in which case the owner must retain the property pending a  
            court's disposition of it.  (Business & Professions Code  
            section 21709.)  

           5)Provides that an owner may assess a reasonable late payment  
            fee if an occupant does not pay the entire amount of the  
            rental fee, as specified.  (Business & Professions Code  
            section 21713.5.)

          6)Provides, in the absence of a statutory permitted fee, the  
            fairness of a late fee is governed by Civil Code Section 1671,  
            which provides that in a commercial context a contract  
            liquidating the damages for the breach of the contract is  
            valid unless the party seeking to invalidate the provision  
            establishes that the provision was unreasonable under the  
            circumstances existing at the time the contract was made.   
            (Civil Code Section 1671, subdivision (b).)

          7)Provides that a reasonable late payment fee is one that does  
            not exceed the following:  

              a)   $10, if the rental fee is $60 or less per month;  
              b)   $15, if the rental fee is greater than $60 but less than  
               $100 per month; or  
              c)   $20 or 15% of the monthly rental fee, whichever is  
               greater, if the rental fee is $100 or more per month.   
               (Business & Professions Code section 21713.5(b).)  

           Provides that a charge that may be imposed for late payment of  
          an installment due on a loan secured by a mortgage or a deed of  









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          trust on real property containing only a single-family,  
          owner-occupied dwelling, shall not exceed either (1) the  
          equivalent of 6 percent of the installment due that is  
          applicable to payment of principal and interest on the loan, or  
          (2) five dollars ($5), whichever is greater.  (Civil Code  
          Section 2954.4(a).) 
           
          COMMENTS  :  According to the author, "AB 655 updates the  
          California Self-Service Storage Facilities Act by making it more  
          consistent with other statutory lien enforcement procedures and  
          allowing owners to utilize new methods of communication.  AB 655  
          will eliminate the Declaration of Opposition to Lien Sale and  
          replace it with a clearer Notice of Lien Sale to delinquent  
          occupants to inform them of their right to file suit to stop the  
          sale of their property.  In most instances the occupant would be  
          able to file suit in small claims court and once the legal  
          documents are served, the sale of the occupant's property may  
          not proceed until a hearing is held.  Currently, most delinquent  
          occupants are confused by the Declaration and its intentions;  
          therefore, its elimination would clarify the law.  Additionally,  
          this bill will provide more time for the occupant to act after  
          being notified by mail than under current law, as well as allow  
          the owner to mail the notice by first class mail with  
          certificate of mailing.  This less expensive method of sending  
          the notice provides a single method of delivery and thereby  
          avoids procedural errors that could be made under the current  
          Act."

           Background  .  As the Business and Professions Committee found,  
          the Act was enacted in 1980 and has been the self-storage  
          industry's primary remedy for dealing with delinquent occupants  
          for over 30 years.  That Committee stated that the law provides  
          storage facility owners with the means to regain possession of  
          the storage space and to dispose of any contents when occupants  
          do not pay rent.  In addition, the law allows owners to recoup  
          their lost rent by holding a lien sale.

           Method of Service and Time Frame  .  Existing law permits an owner  
          who sends a preliminary lien notice by certified mail or by  
          first-class mail with certificate of mailing to immediately deny  
          the occupant access to the space as of the effective date of the  
          lien.  However, an owner who sent the notice by certified mail  
          can immediately remove the property from the space, whereas an  









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          owner who sent notice by first-class mail with certificate of  
          mailing must wait 14 days before removing the property.  This  
          bill would provide that under either method of notice, the owner  
          can enter the space, deny the occupant access, and remove  
          property if the occupant has not paid the lien amount within 14  
          days.

           Declaration of Opposition and New Notice Requirements  .  Existing  
          law requires an owner to send a blank document (Declaration of  
          Opposition) to the occupant with the notice of lien sale.  If  
          the occupant completes the form and returns it to the owner  
          prior to the date of sale, the owner must seek a court order to  
          enforce the lien.  This bill places the burden on the occupant  
          to either pay the amount owed, or to file a court action to  
          prevent the lien sale.  The author states that many occupants  
          find the Declaration confusing, and that the bill provides a  
          clearer statement to occupants of their rights.  This bill  
          requires that, with the notice of lien sale, the owner provide  
          the occupant with information about the occupant's rights (e.g.,  
          to file an action in court, to pay the full amount owed and  
          recover his or her property, etc.).  Moreover, the bill extends  
          the current provision that the sale can take place within 14  
          days of notice, to a requirement that the sale take place no  
          earlier than 21 days after notice is mailed.

           Late Fee Approach to Remain Existing Law  .  The existing statute  
          provides that owners may assess a "reasonable" late fee, and  
          provides a range of fees, from $10 to $20 per month, depending  
          on the amount of monthly rent, pursuant to legislation enacted  
          in 2000 (AB 2263 (Correa), Chapter 156.  For example, existing  
          law provides that the late fee is $10 if the monthly rent is $60  
          or less, and ratchets up a bit for higher cost rentals.  This  
          bill, as proposed to be amended, maintains the existing late fee  
          scheme in this area by deleting all of Section 8 of the bill.
           
          PRIOR ARGUMENTS IN OPPOSITION  :  The California Newspaper  
          Publishers Association (CNPA) opposed the bill as introduced,  
          because it eliminated the requirement that the lien sale  
          advertisement be published in a newspaper of general  
          circulation.  CNPA stated that publication in a newspaper  
          guarantees that the community has notice of an event of great  
          public importance, namely, the severing of an individual's legal  
          relationship to his or her personal property.  However, the  









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          author amended the bill to reinstate the newspaper publication  
          requirement, and CNPA withdrew its opposition.

           Author's Proposed Late Fee Amendment to Return This Part of Bill  
          Back to Current Law  :  As noted above, the author has agreed to  
          delete section 8 of the bill in Committee to return this part of  
          the bill to current law.
           
          Additional Author's Technical Amendment  :  The author has also  
          proposed to amend the bill in Committee to correct a potential  
          privacy problem with the current manner in which a lien sale  
          must be advertised.  The proposed amendment provides that the  
          occupant's name, but not his or her storage space number, will  
          be included in the lien sale advertisement.  The corrected  
          Section 4 of the bill, beginning at page 4, line 24, would  
          instead read:  

            "  SEC. 4. Section 21707 of the Business and Professions Code is  
          amended to read:

          21707.  (a)  After the expiration of the time given in the notice  
          of lien sale, pursuant to subdivision (b) of Section 21705, or  
          following the failure of a claimant to pay rent or obtain a  
          court order pursuant to Section 21709,  the sale shall be  
          advertised and the personal property shall be sold  an  
          advertisement of the sale shall be published once a week for two  
          weeks consecutively in a newspaper of general circulation  
          published in the judicial district where the sale is to be held.  
           The advertisement shall include a general description of the  
          goods, the name of the person on whose account they are being  
          stored,  the space number of the occupant,  and the name and  
          location of the storage facility. If there is no newspaper of  
          general circulation published in the judicial district where the  
          sale is to be held, the advertisement shall be posted at least  
          10 days before the sale in not less than six conspicuous places  
          in the neighborhood of the proposed sale. The sale shall be  
          conducted in a commercially reasonable manner. After deducting  
          the amount of the lien and costs of sale, the owner shall retain  
          any excess proceeds of the sale on the occupant's behalf. The  
          occupant, or any other person having a court order or other  
          judicial process against the property, may claim the excess  
          proceeds, or a portion thereof sufficient to satisfy the  
          particular claim, at any time within one year of the date of  









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          sale. Thereafter, the owner shall pay any remaining excess  
          proceeds to the treasury of the county in which the sale was  
          held."
           
          PRIOR LEGISLATION  :  AB 790 (Frommer), Chapter 267, Statutes of  
          2003: authorized an owner to provide preliminary lien notice by  
          regular first-class mail (in addition to certified mail) if he  
          or she obtains a certificate of mailing indicating the date of  
          mailing; but prohibited the owner from removing property until  
          14 days after the lien date if using this method rather than  
          certified mail.

          AB 2263 (Correa), Chapter 156, Statutes of 2000: authorized the  
          owner of a self-storage facility to assess occupants a late  
          payment fee for delinquent rental fee payments, as specified,  
          and provided that liens imposed include late payment fees.
           
          REGISTERED SUPPORT/OPPOSITION  :  
           
           Support
           
          California Self Storage Association (sponsor)
          103 Self Storage Facility Owners and Managers
          Numerous Individuals
           
          Opposition 

           None on file
           
          Analysis Prepared by  :  Drew Liebert and Rachel Anderson / JUD. /  
          (916) 319-2334