BILL ANALYSIS                                                                                                                                                                                                    



                                                                       



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          |SENATE RULES COMMITTEE            |                  AB 1718|
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                                 THIRD READING


          Bill No:  AB 1718
          Author:   Blumenfield (D)
          Amended:  8/9/10 in Senate
          Vote:     21

           
           SENATE REVENUE & TAXATION COMMITTEE :  3-0, 6/23/10
          AYES:  Wolk, Alquist, Padilla
          NO VOTE RECORDED:  Walters, Ashburn

           SENATE BANKING, FINANCE, AND INS. COMM  :  10-0, 6/30/10
          AYES:  Calderon, Cogdill, Correa, Florez, Kehoe, Liu,  
            Lowenthal, Padilla, Price, Runner
          NO VOTE RECORDED:  Cox

           SENATE APPROPRIATIONS COMMITTEE  :  Senate Rule 28.8 

           ASSEMBLY FLOOR  :  76-0, 6/2/10 - See last page for vote


           SUBJECT  :    Taxation:  property tax postponement

           SOURCE  :     Author


           DIGEST  :    This bill establishes the County Deferred  
          Property Tax Program for Senior Citizens and Disabled  
          Citizens, authorizes a county to elect to participate in  
          the program by adopting a resolution indicating the  
          county's intention to participate in and administer the  
          program, and specifies that the requirements of a county or  
          county officials set forth in the bill are conditioned upon  
          the county's passage of the resolution.
                                                           CONTINUED





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           ANALYSIS  :    The Senior Citizens and Disabled Citizens  
          Property Tax Postponement Law (PTP), until February 20,  
          2009, authorized a claimant, as defined, to file a claim  
          with the Controller to postpone the payment of ad valorem  
          property taxes, where household income, as defined, did not  
          exceed specified amounts.  Existing law authorized the  
          Controller, upon approval of the claim, to either make  
          payment directly to specified entities, or to issue the  
          claimant a certificate of eligibility that constituted a  
          written promise of the state to pay the amount specified on  
          the certificate, as provided.  Existing law required these  
          payments to be made out of a specified funds appropriated  
          to the Controller, as specified, and also required repaid  
          property tax postponement payments be transferred, as  
          specified, to the General Fund.

          This bill establishes the County Deferred Property Tax  
          Program for Senior Citizens and Disabled Citizens,  
          authorizes a county to elect to participate in the program  
          by adopting a resolution indicating the county's intention  
          to participate in and administer the program, and specifies  
          that the requirements of a county or county officials set  
          forth in the bill are conditioned upon the county's passage  
          of the above-described resolution.

          This bill authorizes a claimant, as defined, upon verifying  
          a county's participation in the program, to apply, within a  
          specified filing period, to the county to participate in  
          the program.  The bill requires the county treasurer, or  
          another appropriate county official, to review the  
          claimant's application for program participation, as  
          specified, and, if the claimant is eligible, and if there  
          are sufficient funds within the county's Property Tax  
          Deferral Fund, which this bill would require a  
          participating county to establish within its treasury, to  
          (1) defer property taxes on the claimant's residential  
          dwelling for that fiscal year, (2) issue a subvention  
          payment to that county's general fund, equivalent to the  
          amount of the deferred property taxes, from the county's  
          Property Tax Deferral Fund, and (3) apportion that  
          subvention payment in the same manner as if the property  
          taxes had been paid.  The bill authorizes the county  
          treasurer of a participating county, if he or she makes a  







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          specified determination, upon the adoption of a specified  
          resolution by that county's board of supervisors, to  
          deposit specified funds in the county treasury for the  
          purpose of investment of those funds in the county's  
          Property Tax Deferral Fund.

          This bill requires the amount of property taxes deferred,  
          plus any interest accrued thereon, to be secured by a  
          county property tax lien, as specified.  The bill also  
          requires the lien to be evidenced by a notice of lien, and  
          various county officials to process and record the notice  
          of lien, as specified.  The bill requires a participating  
          county to charge a claimant a specified adjusted rate of  
          interest on the amount owed for the deferment of property  
          taxes.  The bill requires the amount secured by the lien to  
          be increased to reflect the accrual of interest on the  
          property taxes deferred, or decreased by the amount of any  
          payment made to reduce the amount secured by the lien.  The  
          bill provides procedures for the release of the lien if the  
          obligation is paid in full or otherwise discharged, and  
          would require all amounts owed by a claimant under the  
          program to become due immediately under specified  
          circumstances.

          This bill authorizes a participating county to charge a fee  
          to the claimant to cover the actual costs of administering  
          the program, and would require the fee proceeds to be  
          deposited in an account within the county's Property Tax  
          Deferral Fund, to be used exclusively for those  
          administration costs.  The bill specifies that costs to  
          foreclose on a residential dwelling for which property  
          taxes have been deferred under the program are  
          administrative costs.

          The bill prohibits a mortgagee, trustee, or other person  
          authorized to take sale on the real property for which  
          property taxes are deferred due to the failure to pay  
          property taxes from filing a notice of default based solely  
          on the failure to pay property taxes if the mortgagor or  
          trustor provided the mortgagee, trustee, or other person  
          authorized to take sale, evidence of the mortgagor's or  
          trustor's participation in the Senior Citizens and Disabled  
          Citizens Property Tax Postponement Program during the  
          2008-09 fiscal year. The bill would require the Controller  







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          to provide written notice to individuals that participated  
          in the program during 2008, 2009, or the 2008-09 FY for use  
          as written confirmation of that participation.

          This bill is intended to restore a version of the PTP  
          program that relies on county investments to fund the PTP  
          loans to qualified claimants. It is designed to help  
          seniors and disabled individuals as well as to alleviate  
          the negative impact of the program suspension on local  
          government revenues. 

           FISCAL EFFECT  :    Appropriation:  Yes   Fiscal Com.:  Yes    
          Local:  No

          Since the funding for the revised PTP program is expected  
          to come from county deposits, this bill would result only  
          in moderate costs to the GF.  The Controller's Office  
          indicates that it would require an additional three  
          positions, at about $278,000 per year, to administer a  
          fully operational PTP program.  Ongoing costs would be  
          covered by PTP fees and net interest earnings to the Fund.   
          However, initial start up costs not covered by the fees and  
          earnings - potentially in the range of $100,000 in FY  
          2010-11 and $150,000 in FY 2011-12 - would be from the GF.  
          In addition, the provision allowing county tax collectors  
          to cancel delinquent penalties and interest would result in  
          unknown, probably modest, costs to the state, since a  
          portion of the local revenues offset the state's obligation  
          for K-12 schools under Proposition 98. 

           SUPPORT  :   (Verified  8/17/10)

          State Controller
          California State Association of Counties
          Howard Jarvis Taxpayers Association
          Urban Counties Caucus 

           OPPOSITION  :    (Verified  8/17/10)

          California Land Title Association
          California Bankers Association
          California Financial Services Association

           ARGUMENTS IN SUPPORT  :    The California State Association  







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          of Counties (CSAC), along with county assessors,  
          auditor-controllers, and treasurer-tax collectors, has been  
          working with Assemblymember Blumenfield, the State  
          Controller's Office, and the State Treasurer's Office to  
          identify program improvements and a new financing  
          mechanism, which will allow the Senior Citizens Property  
          Tax Postponement Program to be fully self-funded, while  
          continuing to allow eligible Californians to utilize the  
          program.  CSAC observes that the original program had a  
          minimal start-up cost, and, in most years, generated  
          revenue for the state General Fund.  CSAC is committed to  
          help this bill's author develop a workable program that  
          does not result in a cost to the General Fund.

          The Urban Counties Caucus supports the effort to reinstate  
          the discontinued property tax postponement program.  "This  
          program was eliminated last year because the program failed  
          to pay for itself in 2007-08 and 2008-09 mostly due to the  
          housing crisis.  However, in most years this program pays  
          for itself and often generates revenue for the General  
          Fund."  

          The Howard Jarvis Taxpayers Association (HJTA) has long  
          been in favor of the Senior Citizens Property Tax  
          Postponement Program.  In a declining economy, ensuring  
          that seniors on fixed incomes are able to stay in their  
          homes is of prime importance to HJTA.

           ARGUMENTS IN OPPOSITION  :    The California Land Title  
          Association (CLTA) asks whether it is sound public policy  
          to give property tax postponement liens a superpriority  
          over other liens, such as child support liens.   
          "California's 'first in time, first in right' law creates a  
          fair procedure where liens for lenders, general creditors,  
          judgment creditors, and custodial parents, etc., protect  
          themselves by quickly recording a lien with the county  
          recorder's office in which the affected real property is  
          located.  This recordation process creates 'constructive  
          notice' to the world that the recording party wishes to  
          protect their interest from all competing creditors and  
          they do so according to the recordation date of their  
          liens.  Even custodial parents owed child support are  
          required to record an 'abstract of support' lien on real  
          property and wait for reimbursement behind other previously  







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          recorded liens, or other tax liens which are granted a  
          'superpriority' status.  Thus, superpriority status of  
          liens is very rarely created in California law so as not to  
          disrupt this predictable and orderly process."  CLTA  
          believes that the judgment lien status given to loans under  
          the now-discontinued property tax postponement program was  
          appropriate, because existing Revenue and Taxation Code  
          Section 20605 prohibits a lender from requiring a borrower  
          to pay into an impound account to cover taxes.  If a lender  
          cannot charge for taxes through an impound account, then  
          their security interest in the property must trump that of  
          the Controller's lien, as set forth in existing law.  Under  
          current law, a lender's security interest in real property  
          for which it has provided a loan is protected by a deed of  
          trust recorded against the property, which, for all  
          practical purposes, is superior to all other recorded liens  
          on the real property.  

          The California Bankers Association and the California  
          Financial Services Association state, "With respect to the  
          AB 1718's creation and recordation of a super lien for the  
          payment of delinquent property taxes, the measure creates a  
          violation of the terms of the mortgage or deed of trust.   
          The measure futher limits the ability of a lender/servicer  
          from enforcing performance of the contract by precluding  
          the commencement of non-judicial foreclosure through the  
          filing of a notice of default for five years.  AB 1718  
          creates [an] ex post facto law and impairs the obligation  
          of the mortgage contract in violation of the state and  
          federal constitutions.

           ASSEMBLY FLOOR  :  
          AYES:  Adams, Ammiano, Anderson, Arambula, Bass, Beall,  
            Bill Berryhill, Blakeslee, Block, Blumenfield, Bradford,  
            Brownley, Buchanan, Caballero, Charles Calderon, Carter,  
            Chesbro, Conway, Cook, Coto, Davis, De La Torre, De Leon,  
            DeVore, Emmerson, Eng, Evans, Feuer, Fletcher, Fong,  
            Fuentes, Fuller, Furutani, Gaines, Galgiani, Garrick,  
            Gilmore, Hagman, Hall, Harkey, Hayashi, Hernandez, Hill,  
            Huber, Huffman, Jeffries, Jones, Knight, Logue, Bonnie  
            Lowenthal, Ma, Mendoza, Miller, Monning, Nava, Nestande,  
            Niello, Nielsen, Norby, V. Manuel Perez, Portantino,  
            Ruskin, Salas, Saldana, Silva, Skinner, Smyth, Solorio,  
            Swanson, Torlakson, Torres, Torrico, Tran, Villines,  







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            Yamada, John A. Perez
          NO VOTE RECORDED:  Tom Berryhill, Lieu, Audra Strickland 


          DLW:nl  8/17/10   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE

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