BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 1291
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          CONCURRENCE IN SENATE AMENDMENTS
          AB 1291 (Niello)
          As Amended September 4, 2009
          Majority vote 
           
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          |ASSEMBLY:  |78-0 |(June 3, 2009)  |SENATE: |40-0 |(September 10, |
          |           |     |                |        |     |2009)          |
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           Original Committee Reference:    JUD.  

           SUMMARY  :  Seeks various reforms of the Unclaimed Property Law  
          (UPL) intended to strengthen property owners' rights and ensure  
          that property holders reasonably inform their customers about  
          risks associated with leaving accounts dormant and about the law  
          that causes unclaimed property to escheat to the state after a  
          period of inactivity.  Specifically,  this bill  :   

          1)Provides that certain banking and financial accounts held by a  
            business association escheat to the state if, during the  
            previous three years, there has been no activity on the  
            account and no communication between the banking organization  
            and account owner, either electronically or in writing.

          2)Permits banking and financial organizations, as defined, to  
            make reasonable efforts to notify owners of certain property  
            electronically when the owner has consented to electronic  
            notifications, that the customer's deposit, account, shares,  
            or other interest in the banking or financial organization  
            will escheat to the state pursuant to specified provisions of  
            law.

          3)Codifies specific language and format requirements for the due  
            diligence notice sent by business associations holding safe  
            deposit boxes to the owners of the property in safekeeping.   
            In the notice, the business association (holder) must provide  
            a description of the escheat process, including the necessity  
            of filing a claim for the return of the property, and other  
            required notice information, such as the time for the last  
            account activity.  Specifically:  

             a)   The face of the notice shall contain a heading centered  
               at the top that reads as follows:  "THE STATE OF CALIFORNIA  
               REQUIRES US TO NOTIFY YOU THAT YOUR UNCLAIMED PROPERTY MAY  








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               BE TRANSFERRED TO THE STATE IF YOU DO NOT CONTACT US;" and,

             b)   Permits the holder to provide additional due diligence  
               letters complying with these specifications at any time.

          4)Provides that, at the time a new account is opened with any  
            banking organization, financial organization or business  
            association, as defined, the organization or association must  
            provide a written notice to the person opening the account  
            informing the person that his or her property may escheat to  
            the state if no activity occurs on the account for more than  
            three years.

          5)Requires that in order for a holder to be relieved of  
            liability for the property escheated to the California State  
            Controller (Controller), the holder must have complied with  
            requirements for sending due diligence letters to the owner.

          6)Makes clarifying and technical changes to correct minor  
            problems relating to timing of notices, problems that stem  
            from enactment of SB 86, the omnibus budget trailer bill for  
            2007.  Specifically:

             a)   Authorizes the Controller to postpone the delivery of  
               unclaimed property and the remit report required under law;

             b)   Clarifies that interest applies when a holder fails to  
               file a Notice Report on time or in the manner required by  
               law; and,

             c)   Clarifies that the timeframe for sending due diligence  
               letters is based on when the property is reportable instead  
               of transferable, thus ensuring consistency with other  
               provisions that reflect the fact that due diligence letters  
               are sent by the holder before the property is reported to  
               the Controller's Office.  
           
           The Senate amendments:   

          1)Provide that a deposit or account held or owing by a business  
            association to the state shall not escheat to the state if,  
            during the previous three years, the owner has also maintained  
            an active individual retirement account (IRA) or other  
            retirement plan or account with the same business association,  
            as specified.








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          2)Provide that contents of safety deposit boxes will not escheat  
            to the state if the owner has maintained other active  
            accounts, as specified, with the business association holding  
            the safety deposit box.

          3)Establish a $10,000 limit on the amount of interest the  
            Controller may collect from a holder of unclaimed property  
            escheated to the state when that holder paid or delivered the  
            unclaimed property to the state in timely manner but filed a  
            report not in substantial compliance with Code of Civil  
            Procedure Section 1530 (requiring an accounting report of  
            escheated property).

          4)Make technical changes to correct certain cross-references.

           AS PASSED BY THE ASSEMBLY  , this bill was substantially similar  
          to the version approved by the Senate.
           
          FISCAL EFFECT  :  According to the Senate Appropriations  
          Committee, the Controller estimates a need for 2.6 PY of  
          permanent staff to manage the retaining of escheated property  
          with no apparent commercial value for seven years, rather than  
          the 18 months required in existing law.  This would result in  
          administrative costs of $125,000 in 2010-11 and ongoing costs of  
          $202,000.

           COMMENTS  :  This bill, sponsored by the Controller's Office,  
          proposes various reforms of the Unclaimed Property Law that are  
          intended to strengthen property owners' rights and ensure that  
          property holders reasonably inform their customers about risks  
          associated with leaving accounts dormant, and to inform them  
          about the law that causes unclaimed property to escheat to the  
          state after a period of inactivity.

          Existing law only requires holders to send a single due  
          diligence letter at a specified time to owners.  If the owner  
          fails to receive the letter or mistakes the letter for junk  
          mail, they may fail to realize that the property soon becomes  
          reportable and escheatable to the Controller.  This bill seeks  
          to provide clearer notification to owners that their property is  
          in danger of escheat, with the optimal goal of reuniting more  
          owners with their property, prior to reporting to the  
          Controller's Office.









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          In addition, this bill seeks to notify owners about the  
          possibility under state law that their property may escheat to  
          the state if no activity occurs on a new bank account for more  
          than three years.  Consumers should benefit from dissemination  
          of information about the state's escheat law so they can take  
          steps to prevent their property from escheating to the  
          Controller.  Requiring the business association or bank to  
          provide this notification whenever a new account is opened is a  
          sensible time to provide such information.

          Recent amendments remove provisions relating to the escheat of  
          property in safe deposit box accounts and the payment of  
          interest by the Controller when returning funds to claimants  
          under the Unclaimed Property Law.

          Importantly, this bill does not impose additional reporting  
          requirements or penalty increases for failing to report  
          unclaimed property that were the Governor's stated basis for  
          vetoing last year's SB 1319 (Machado), a predecessor to this  
          bill.

           
          Analysis Prepared by  :   Anthony Lew / JUD. / (916) 319-2334 


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