BILL ANALYSIS                                                                                                                                                                                                    







          
                             SENATE JUDICIARY COMMITTEE
                           Senator Ellen M. Corbett, Chair
                              2009-2010 Regular Session


          SB 95                                                       S
          Senator Corbett                                             B
          As Amended March 16, 2009
          Hearing Date: March 31, 2009                                9
          Civil Code; Vehicle Code                                    5
          ADM:jd                                                      
                                                                      

                                        SUBJECT
                                           
                    California Car Buyers' Protection Act of 2009

                                      DESCRIPTION  

          This bill would increase from $50,000 to $100,000 the bond  
          required of a vehicle dealer   for issuance or renewal of a  
          dealer's license by the Department of Motor Vehicles (DMV).

          This bill would provide that a person who bought or leased a  
          vehicle or motorcycle and who suffers any loss or damage related  
          to the purchase or lease by reason of any fraud or contract or  
          statutory violation in connection with the purchase or lease  
          would have a right of action against the dealer and the dealer's  
          bond for actual damages plus any incidental and consequential  
          damages.

          This bill would prioritize claims against a dealer's bond as  
          follows: first, DMV claims (unpaid license and registration fees  
          and sales taxes); second, claims of any person who purchased or  
          leased a vehicle or motorcycle; and third, claims by the  
          financing agency and any other persons or entities.

          This bill would provide that, if a dealer acquires a used  
          vehicle with a balance due to a secured party (a financing  
          agency or lender), the dealer must submit to the DMV evidence in  
          the form of a notarized receipt from the secured party that the  
          dealer has paid off the entire balance prior to transferring the  
          vehicle, or prior to the date when payment is due, whichever  
          occurs first.  
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           This bill would make it unlawful for a dealer to sell or  
          transfer a used vehicle with a balance due to a secured party  
          prior to paying off the entire balance and submitting the  
          notarized receipt to the DMV. 

          This bill would make failure to comply with the above two  
          provisions regarding dealer pay offs unlawful under the Consumer  
          Legal Remedies Act (CLRA) as an unfair or deceptive act or  
          practice.  

          (This analysis reflects author's amendments to be offered in  
          committee.)

                                      BACKGROUND  

          A recent Associated Press (AP) article reported, "About a  
          quarter of all car buyers are vulnerable because they still owe  
          money on their trade-in or lease when they buy another vehicle,  
          according to industry tracker Edmunds.com.  It's become more  
          common for a driver to owe money on a trade-in as people stretch  
          their car payments over six or seven years to make them more  
          affordable."  As reported by the AP, San Francisco Chronicle,  
          KOVR-TV, Los Angeles Times, KCRA-TV, KXTV, KGO-TV and other news  
          organizations, many car buyers are falling victim to auto  
          dealers who engage in unlawful activities prior to closing their  
          doors.  

          Nationwide auto dealerships are going out of business or are in  
          bankruptcy.  California has been hit hard because it has the  
          nation's largest auto market, with more dealers going out of  
          business or declaring bankruptcy and more buyers who owe money  
          on their trade-ins.  Since the beginning of 2009, approximately  
          two dozen dealers have closed their doors.  Among the  
          dealerships that have gone out of business in California are  
          Fairfield Ford, Elk Grove Saturn, Superior Nissan of Fremont,  
          Superior Toyota of Oakland, and Great Valley  
          Chrysler-Jeep-Mazda-Isuzu.  This trend is predicted to continue  
          for the foreseeable future.  

          According to the auto industry trade publication Automotive  
          News, "Peter Welch, president of the California [New] Car  
          Dealers Association ? said California lost 116 [new car]  
          dealerships in the first 11 months of 2008 ? He believes  
          closures will total 150 [new car dealerships] by year end and  
          predicts as many as 500 closings in 2009."
                                                                      



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          According to a chart provided by the DMV to the news media, more  
          than 416 independent used car dealers also went out of business  
          during the first 11 months of 2008.  Some of the individuals  
          associated with those dealerships then turned around and  
          re-opened under different names, sometimes at the same location.

          The dilemma that car buyers face is that hundreds of dealerships  
          - including large franchised dealerships that have been in  
          business for years - are suddenly closing their doors without  
          any warning, taking hundreds of their customers down with them.   
          At the same time, some dealers are engaging in unfair,  
          deceptive, fraudulent, and unlawful practices, including failure  
          to pay off balances due on trade-ins.  This bill is intended to  
          address the consumer problems that have arisen, particularly  
          from dealership closures.  

           Under current law, dealers are required to post a $50,000 bond  
          with the DMV.  Some other states have bond requirements greater  
          than $100,000 (Hawaii, $200,000; Maryland, up to $300,000),  
          while others are lower. 
          
                                CHANGES TO EXISTING LAW
            
           1.Existing law  provides that before any dealer's or  
            remanufacturer's license is issued or renewed by the DMV to  
            any applicant, the applicant must procure and file with the  
            DMV a bond executed by an admitted surety insurer, approved as  
            to form by the Attorney General, and with the condition that  
            the applicant is prohibited from practicing any fraud or  
            making any fraudulent representation that would cause a  
            monetary loss to a purchaser, seller, financing agency, or  
            governmental agency.  (Vehicle Code (VC) section 11710(a).)

             Existing law  provides that a dealer's bond must be in the  
            amount of $50,000, except the bond of a dealer exclusively in  
            motorcycles or all-terrain vehicles must be in the amount of  
            $10,000.  Before the license is renewed by the DMV, the  
            dealer, other than a dealer who deals exclusively in  
            motorcycles or all terrain vehicles, is required to procure  
            and file a bond in the amount of $50,000.  A remanufacturer  
            bond must also be in the amount of $50,000.  (VC section  
            11710(b).)

             This bill  would increase the dealer bond from $50,000 to  
            $100,000.  The motorcycle or all-terrain dealer bond would  
                                                                      



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            remain at $10,000 and the remanufacturer bond would remain at  
            $50,000.
           
          2.Existing law  provides that, if any person (1) suffers any loss  
            or damage by reason of any fraud practiced on him by a  
            licensed dealer or one of the dealer's salesmen acting for the  
            dealer, in his behalf, or within the scope of employment of  
            such salesman and such person has possession of a written  
            instrument furnished by the licensee, containing stipulated  
            provisions and guarantees which the person believes have been  
            violated by the licensee, or (2) suffers any loss or damage by  
            reason of the violation of any of the registration provisions  
            of this code, or (3) is not paid for a vehicle sold to and  
            purchased by a licensee, than any such person has a right of  
            action against such dealer, his salesman, and the surety upon  
            the dealer's bond, in an amount not to exceed the value of the  
            vehicle purchased from or sold to the dealer.  (VC section  
            11711.)

             This bill  would provide that, if a person who bought or leased  
            a motor vehicle or a motorcycle at retail suffers any loss or  
            damage related to the purchase or lease of that vehicle by  
            reason of any fraud or contract or statutory violation  
            practiced on him or her by a licensed dealer or one of the  
            dealer's salespersons acting for the dealer, on his or her  
            behalf, or within the scope of the employment of his or her  
            salesperson in connection with the purchase or lease of the  
            motor vehicle, then that person would have a right of action  
            against the dealer, his or her salesperson, and the surety  
            upon the dealer's bond for actual damages plus any incidental  
            and consequential damages.  

           3.Existing law  provides that claims, against the surety upon a  
            dealer's bond, of a financing agency that has loaned money to  
            a licensee are allowed only to the extent that the claims of  
            any other person or entity with respect to the bond have been  
            satisfied first.  Such claims are entitled to preference over  
            the claims of the financing agency.  However, as to any  
            conditional sales contract, as defined, acquired by way of  
            purchase or pledge, a financing agency is entitled to  
            protection under the bond with the same preference as other  
            persons if the financing agency has been defrauded by a  
            licensee.  (VC section 11722.)

             This bill  would provide that claims, against the surety upon a  
            dealer's bond, of a financing agency that has loaned money to  
                                                                      



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            a licensee, or claims based upon accepted assignments of  
            conditional sales agreements, or the purchase of conditional  
            sales agreements or of any other agreement entered into with a  
            licensee would be allowed only to the extent that the claims  
            of any persons who purchased or leased a motor vehicle or a  
            motorcycle at retail are satisfied first.  Such claims would  
            be entitled to preference over the claims of the financing  
            agency and other persons or entities, except the DMV (for  
            unpaid license and registration fees and sales taxes).

           4.Existing law  , the CLRA, provides that 24 specified unfair  
            methods of competition and unfair or deceptive acts or  
            practices undertaken by a person in a transaction intended to  
            result or that results in the sale or lease of goods or  
            services to a consumer are unlawful.  (Civil Code (CC) section  
            1770.)

             This bill  would provide that, if a dealer acquires a used  
            vehicle with a balance due to a secured party, the dealer must  
            submit to the DMV evidence in the form of a notarized receipt  
            from the secured party that the dealer has paid off the entire  
            balance prior to transferring the vehicle, or prior to the  
            date when payment is due, whichever occurs first.  
             
            This bill  would make it unlawful for a dealer to sell or  
            transfer a used vehicle with a balance due to a secured party  
            prior to paying off the entire balance and submitting the  
            notarized receipt to the DMV. 

             This bill  would make failure to comply with the above two  
            provisions regarding dealer pay offs unlawful under the CLRA  
            as an unfair or deceptive act or practice.  

             This bill  would provide that nothing in this act may be  
            construed to limit, in any way, the existing rights, remedies,  
            or recourses available to any person who purchases or leases  
            vehicles at retail.

             This bill  makes certain legislative findings and declarations.  
             (See Comment 9.)

                                        COMMENT
           
           1.Stated need for the bill  
          
          The sponsor, Consumers for Auto Reliability and Safety (CARS),  
                                                                      



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          writes:
          
            When dealerships go out of business they not only fail to pay  
            off liens, but also fail to honor warranties, service  
            contracts, and other services for which car buyers have paid  
            in advance, costing car buyers millions of dollars and eroding  
            consumer confidence.  While SB 729 last year created a fund to  
            help consumers whose lives are destroyed by these  
            irresponsible car dealers, SB 729 did not address the problem.  
             Dealers still can sell vehicles without paying off the title.

            In 2008, 120 new-car dealerships and over 416 used car  
            dealerships went out of business in California.  Industry  
            analysts predict that even more dealerships will go out of  
            business in 2009.  As dealerships close their doors, they are  
            leaving consumers with unpaid liens on vehicles they  
            traded-in, as well as a second loan on the newer vehicle they  
            purchased at the dealership.  Too often the consequence is  
            destruction of consumer credit, repossession of the vehicles,  
            job losses due to the lack of transportation to get to work,  
            and bankruptcy.  

           2.Consumer protections in SB 95  

          The bill contains the following consumer protections:
           Requires auto dealers to: 1) pay off the entire amount owed on  
            traded-in vehicles prior to transferring ownership or before  
            the first payment is due, whichever comes first; and 2)  
            provide a notarized receipt from the lienholder to the DMV  
            confirming that the lien has been satisfied.
           Increases the dealer bond requirement for new and used car  
            dealers from $50,000 to
            $100,000 -- on a par with Arizona, but still less than  
            Maryland (up to $300,000) and Hawaii (up to $200,000).  This  
            is consistent with the $100,000 bond amount in legislation  
            sponsored by the California New Car Dealers Association (AB  
            1939, DeSaulnier, 2008) and would provide consumers greater  
            access to compensation for losses and damages related to the  
            purchase or lease of a vehicle.
                          Clarifies that wronged retail car buyers have  
            access to the bond, second only to the DMV.
                          Allows consumers to recover actual damages plus  
            incidental and consequential damages.
                          Eliminates restrictions that narrowed the  
            grounds for consumers to access the bond, so that more victims  
            of salvage fraud, predatory lending, and other illegal  
                                                                      



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            practices may be able to recoup their losses when a dealer  
            goes out of business.
           Makes it unlawful under the CLRA to sell or transfer a used  
            vehicle with a balance due to a lender prior to paying off the  
            balance and submitting the notarized receipt to the DMV.  This  
            would allow injured consumers access to remedies available  
            under the CLRA.
                          Clarifies that the new law will not limit  
            existing rights, remedies, or recourses available to consumer  
            victims under existing law.

           1.Consumer complaints to the DMV  

          The DMV reports that the number of consumer complaints involving  
          a dealer's failure to pay off a trade-in has risen significantly  
          from prior years.  As of the end of February 2009, the DMV  
          states that it is investigating 256 active cases where a dealer  
          has failed to pay off a consumer's trade-in and 564 additional  
          consumer complaints that the consumer had not yet received  
          verification that title to a vehicle bought from or sold to a  
          dealer had been transferred.  

           2.Existing bond requirements are insufficient; cost of bond  
           
           In 2002, SB 1458 (Romero, Chapter 303, Statutes of 2002)  
          increased the dealer bond requirement for new and used car  
          dealers from $10,000 to $50,000.  When SB 729 (Padilla, Chapter  
          437, Statutes of 2007) (See Comment 7) was being considered, the  
          California District Attorneys Association stated that, even with  
          that increase,

            [t]he existing [$50,000] bond is inadequate to address the  
            problem [when dealers go out of business] because (1) the  
            amount of the bond is too small to compensate for all losses;  
            (2) the bond covers various losses including the state's loss  
            of vehicle license and registration fees and sales taxes which  
            have a first priority claim on bond funds; (3) consumers may  
            have to institute costly litigation to enforce payment on the  
            bond; and (4) the surety insurer issuing the bond may file an  
            interpleader action allowing the surety insurer to deduct  
            litigation expenses thereby reducing the total amount of bond  
            funds available to pay claims.  

          Comment 7 provides details of a number of dealerships across  
          several counties that have gone out of business and left  
          consumers with losses, some in excess of $1 million (Vacaville  
                                                                      



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          Ford, 100 victims).

          CARS writes:

            Bonds are often the only recourse customers have when a dealer  
            goes out of business.  Further, if bonds are designed and set  
            properly, they can play a role in weeding out shady dealers  
            who have bad credit, generate complaints, and enter into a  
            business such as selling cars with the knowledge that they can  
            engage in illegal practices and then go out of business,  
            leaving their customers holding the bag.  Bonds can also help  
            address the problem of "revolving door" dealerships, where the  
            same cast of characters open up a business, stiff consumers  
            and the state, then turn around and get a license under a  
            relative's name and repeat the pattern of bad acts again and  
            again.

            The DMV has suffered cutbacks and lacks the staff and  
            resources to adequately police the auto market.  The DMV is  
            often slow to respond effectively to consumer complaints.  The  
            bond requirement is a private backup to the DMV that can help  
            weed out dealers who are undercapitalized and/or engage in  
            unlawful acts and practices.  In the current market, consumers  
            have no way of knowing whether a dealer is going to be in  
            business from one day to the next.  The bond requirement can  
            help weed out the ones that are going to go under before they  
            take hundreds of consumers down with them.

          CARS further writes:

            When the bond was raised in 2002, many dealerships made dire  
            predictions that the sky would fall and California's car  
            market would collapse.  However, the market continued to  
            thrive and many dealers made record profits for several years  
            after the measure was enacted. ?  SB 95 would raise the bond  
            requirement from $50,000 to $100,000.  According to a major  
            surety company that provides bonds for dealerships in all 50  
            states, the rates for dealers to obtain California's bond are  
            as follows: 1) $800 per year (Super Preferred); 2) $1000 per  
            year (Preferred); and 3) $1,500 per year (Standard).

           3.Fraud standard in current law; addition of breach of contract  
            and statutory violations  

          Under current law a consumer who suffers any loss or damage  
          related to the purchase or lease of a vehicle due to fraud has a  
                                                                      



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          private right of action against the dealer, the dealer's  
          salespersons, and the surety on the dealer's bond in an amount  
          not to exceed the value of the vehicle purchased from or sold to  
          the dealer.  

          The elements of actionable fraud are a deceit (one who willfully  
          deceives another with intent to induce him or her to alter his  
          or her position to his or her injury or risk), which is either:  
          1) the suggestion, as a fact, of that which is not true by one  
          who does not believe it to be true; 2) the assertion, as a fact,  
          of that which is not true, by one who has no reasonable ground  
          for believing it to be true; 3) the suppression of a fact, by  
          one who is bound to disclose it, or who gives information of  
          other facts which are likely to mislead for want of  
          communication of that fact; or 4) a promise made without any  
          intention of performing it.  (CC sections 1709, 1710.)

          The author and sponsor, CARS, assert that, because fraud (an  
          intentional act) is often difficult to prove and breach of  
          contract and statutory violations are also of concern and appear  
          to be a growing problem as dealerships go out of business, SB 95  
          would add those violations to VC section 11711 (fraud and other  
          violations of law).  In addition, SB 95 would provide for actual  
          damages plus any incidental and consequential damages, such as  
          auto rental costs.
           

          4.Notarized receipt provision of SB 95  

           This bill would provide that, if a dealer acquires a used  
           vehicle with a balance due to a secured party (a financing  
           agency or lender), the dealer must submit to the DMV evidence  
           in the form of a notarized receipt from the secured party that  
           the dealer has paid off the entire balance due prior to  
           transferring the vehicle, or prior to the date when payment is  
           due, whichever occurs first.  Some stakeholders have voiced  
           concern about the workability of a notarized receipt.  The  
           author and sponsor have agreed to continue to work with  
           stakeholders to find the best way to verify that the dealer has  
           paid off any balance due on a trade-in.

           5.Senate Bill 729 - Consumer Motor Vehicle Recovery Corporation  

          Senate Bill 729 (Padilla, Chapter 437, Statutes of 2007) created  
          the Consumer Motor Vehicle Recovery Corporation (CMVRC), a  
          nonprofit mutual benefit corporation, with a board of directors  
                                                                      



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          with certain powers and duties, in order to provide payments to  
          consumers on eligible claims, including a vehicle dealer or  
          lessor-retailer's failure to remit license or registration fees,  
          failure to pay off a trade-in's sale or lease balance owed, or  
          failure to pay proceeds of a consignment sale.  A consumer may  
          file an application with the CMVRC for the payment of the  
          consumer's eligible claim if the dealer or lessor-retailer  
          against whom the claim is asserted has ceased selling and  
          leasing vehicles or is in bankruptcy.  

          The DMV is required to charge dealers and lessor-retailers a fee  
          of $1.00 for each vehicle sold by the dealers and  
          lessor-retailers, up to $2,500 per dealer per year.  The fees  
          are continuously appropriated to the DMV for quarterly payment  
          to the CMVRC until the recovery fund has reached $5 million.  To  
          date the DMV has collected approximately $720,000.  Oversight  
          and review of the CMVRC is done by the Attorney General.

          Although the CMVRC was to be implemented by July 1, 2008,  
          information provided to CARS indicates that the CMVRC is not yet  
          fully implemented.  The information also indicates that all the  
          board members have been appointed; the board is in the process  
          of devising the claims forms and having them translated; the  
          CMVRC is close to the point where it may start accepting claims;  
                                                and it may be a matter of weeks before it is ready to begin  
          processing claims.  

          The sponsor, CARS, states that, based on information provided by  
          the California District Attorneys Association (CDAA) to the  
          Judiciary Committee in support of SB 729, when dealerships go  
          out of business they sometimes leave many victims holding the  
          bag, resulting in more than $1 million in losses at a single  
          dealership.  Examples provided by the CDAA include:
           Solano County dealership (Vacaville Ford); more than 100  
            victims, and more than $1 million in losses.
           Alameda County dealership; 50 victims and losses in excess of  
            $1 million.
           Riverside County dealership; 6 victims; $50,000 in losses.
           Placer County dealership; 8 victims; $50,000 in losses.
           Marin County dealership; losses of approximately $100,000.
           Monterey County dealership; more than 80 victims; more than $1  
            million in losses.

          CARS writes:

            Even if it were funded at the maximum level allowed by law,  
                                                                      



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            based on prior history, the demise of five large new car  
            dealerships could deplete the entire fund.  Meanwhile,  
            hundreds of new car dealerships are predicted to close this  
            year.  The [CMVRC] also allows claims for only a narrow subset  
            of violations involving failures to pay off liens, failures to  
            provide clear title, or pocketing the proceeds from  
            consignment sales.  In addition, due to various delays, to  
            date, the [fund] has not paid a single claim.

           1.Requirements of and remedies and defenses available under the  
            CLRA  

          This bill would make failure to comply with the two provisions  
          of the bill that require a dealer to pay off the entire balance  
          due on a trade-in unlawful under the CLRA as an unfair or  
          deceptive act or practice.  (CC section 1770.)  As such, the  
          remedies available under the CLRA would be available to a  
          consumer who suffers damages as a result of a dealer's failure  
          to pay off the balance due on a trade-in.  Those remedies  
          include: 1) actual damages; 2) an order enjoining the methods,  
          acts, or practices; 3) restitution of property; 4) punitive  
          damages; and 5) any other relief the court deems proper.  (CC  
          section 1780.)

          Civil Code section 1782 provides that 30 days or more prior to  
          the commencement of an action for damages under the CLRA, the  
          consumer must: 1) notify the person alleged to have employed or  
          committed methods, acts, or practices declared unlawful by  
          Section 1770 of the particular alleged violations of Section  
          1770; and 2) demand that the person correct, repair, replace, or  
          otherwise rectify goods or services alleged to be in violation  
          of Section 1770.  This would provide the dealer the opportunity  
          to rectify the situation, without litigation, by paying off the  
          balance due on the vehicle.

          Civil Code section 1784 provides that no award of damages may be  
          given in any action based on a method, act, or practice declared  
          to be unlawful by Section 1770 if the person alleged to have  
          employed or committed such method, act, or practice (a) proves  
          that such violation was not intentional and resulted from a bona  
          fide error notwithstanding the use of reasonable procedures  
          adopted to avoid any such error and (b) makes an appropriate  
          correction, repair, or replacement or other remedy of goods and  
          services.


                                                                      



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           2.Legislative findings and declarations  

          This bill would make a number of legislative findings and  
          declarations, including:
           During the past year at least 480 licensed new and used auto  
            dealerships have gone out of business in California and it is  
            projected that the numbers will continue to accelerate for the  
            foreseeable future.
           Consumers who purchase vehicles from dealerships licensed by  
            the DMV have a reasonable expectation that the dealerships  
            have sufficient resources to honor their contractual  
            commitments.
           When dealerships go out of business they often fail to pay off  
            liens and also fail to honor warranties, service contracts,  
            and other services for which car buyers have paid in advance,  
            costing thousands of car buyers millions of dollars in losses.
           When dealerships go out of business without honoring their  
            obligations, car buyers often face ruinous consequences  
            through no fault of their own, resulting in harm to their  
            credit, repossessions, job losses, home foreclosures, and  
            bankruptcy.
           The DMV projects that the current funding available for the  
            CMVRC will not be sufficient to meet demand.

           1.Opposition  

          Opponent California New Car Dealers Association (CNCDA) makes a  
          number of arguments in opposition to the trade-in and bond  
          provisions of the bill.

              a.   Trade-ins  

            CNCDA argues that the provision in the bill that would make it  
            unlawful to sell or transfer a used vehicle with a balance due  
            to a lender prior to paying off the balance due is overly  
            broad and vague and would lead to "innumerable unintended  
            consequences."

               The proposed statute is triggered and takes control in  
               every possible situation when a dealer "acquires" a used  
               vehicle "with a balance due to a secured party."  This goes  
               well beyond acceptance of a trade-in with a prior credit or  
                                                                      



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               lease balance.

            CNCDA lists a number of situations, which it argues the  
            provision would extend to, such as dealer acquisition of a  
            used vehicle with a clean title from another dealer, but where  
            the selling dealer's landlord claims its lease with the dealer  
            gives it a security interest in personal property located on  
            the premises.

            CNCDA further argues that the provision requiring pay off of  
            the entire balance due before the earlier of either  
            transferring the vehicle or when payment is due is also overly  
            broad and would create harsh and unnecessary consequences.

               A dealer would be required to make payment by the time  
               payment is due, even though the dealer was never a party to  
               the payment obligation and most likely was never informed  
               of payment due dates, let alone being provided with a copy  
               of the security agreement. ?  It is unreasonable to impose  
               satisfaction of a contractual commitment upon a dealer who  
               never had an opportunity to negotiate or even read the  
               commitment. ?  [T]he [provision] as drafted constitutes a  
               wholesale shift of risk to otherwise innocent purchasing  
               dealers and away from secured parties and vehicle sellers -  
               businesses who are in much better positions to protect  
               against such risk.  The [provision] is not reasonably  
               limited to protecting used vehicle purchasers or trade-in  
               customers.

            CNCDA is also opposed to the notarized receipt provision in  
            the bill:

               The bill leaves to the imagination the form of such a  
               receipt, the time frame within which it would be returned  
               (keeping in mind that the secured party has the right to  
               payment in full of all charges up until the time the  
               receipt is returned to the dealer), the manner DMV would  
               want it submitted, and how the DMV would provide evidence  
               of submission back to the dealer.

            CNCDA asserts that this would interfere with a dealer's  
            ability to gain working capital while the dealer waits for the  
            notarized receipt.  "Used vehicle inventory is a wasting asset  
            that rapidly depreciates in value.  Dealers need to be able to  
            sell trade-in vehicles as soon as they tender the pay off to a  
            lienholder."  (See Comment 6 regarding the author's and  
                                                                      



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            sponsor's commitment to continue to work with stakeholders on  
            the notarized receipt provision.)

              b.   Dealer bond provisions  

            CNCDA argues that increasing the bond to $100,000 would force  
            many honest dealers out of business because no surety company  
            would issue them a bond.  At the same time however, CNCDA has  
            told the author and sponsor that it is not opposed to the  
            increased bond.  

            CNCDA objects to eliminating the current limitation on  
            liability (the value of the vehicle) and replacing that limit  
            with a provision that would impose liability for actual  
            damages plus incidental and consequential damages.  "Moreover,  
            the grounds for liability would be greatly expanded to cover  
            not only fraud, but contract or statutory violation related to  
            the purchase or lease of a vehicle."  CNCDA asserts that  
            "these expansive new causes of action" against a dealer bond  
            would result in the following:
                                  The bill would create a private right  
               of action for every state and federal statute to which a  
               dealer is subject during a sale; not only consumer  
               protection statutes, but all others as well, which would  
               amount to "a wholesale repeal of California law limiting  
               certain private rights of action ? ."
                                  The bill is overbroad in that it would  
               allow expanded damages to include actual, incidental, and  
               consequential damages in every case.
                                  The bill would allow damages for any  
               violation of contract (whether or not cured).  This bill  
               thus "supports absurd results, such as damage claims for  
               contract violations that are not material or that result  
               from mistake or are otherwise made in good faith."
                                  Dealer liability for the acts of  
               salespersons under the bill is overbroad and amounts to  
               "strict liability."
                                  Removing the limit on the maximum claim  
               (the value of the vehicle) would "permit bond resources to  
               be exhausted in satisfaction of claims exceeding the value  
               of the vehicle for items such as lost income, lost profits,  
               value of the bargain, replacement transportation, etc."  
                                  The bill would "channel most disputes  
               with dealers toward the bonding company and away from  
               courts and administrative agencies."
                                  Due to the "breadth and scope of causes  
                                                                      



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               of action that could be asserted against a dealer bond  
               under [the bill] and the amount of damages that could be  
               collected, it is doubtful that many bonding companies, if  
               any, would be willing to underwrite the risk of  
               indemnifying dealers under such a scheme."

            The California Motorcycle Dealers Association (CMDA) also  
            opposes the bill "because of the overly severe provisions that  
            will have an extremely negative effect on the motor vehicle  
            dealers that remain in California.  It will only serve to  
            exacerbate an already difficult economic environment with  
            regulations that punish all dealers ? .  [Requiring] a  
            notarized release of liens will grind the resale process to a  
            halt, which is the only thing keeping many dealers in business  
            because the sale of new vehicles has been drastically reduced  
            by the economy and lack of consumer financing."  The CMDA  
            argues that the CMVRC should be relied upon and this bill  
            should be dropped and should only be reconsidered if the CMVRC  
            does not provide results.  

           1.Author's amendments 

          The amendments on pages 4, 5, 9, and 10 remove the provisions  
          regarding the New Motor Vehicle Board and its authority and  
          duties under VC section 3050.

          On page 3, line 11, delete the word "licensed" and insert the  
          word "new" in its place.

          On page 3, line 11, insert the word "licensed" after the word  
          "used."

          On page 4, delete lines 36 through 40.  

          On page 5, delete lines 1 through 12.

          On page 8, line 26, delete "advertising the vehicle for sale  
          or."

          On page 9, delete lines 15 through 40.  

          On page 10, delete lines 1 through 26.

          On page 10, line 28, delete the word "acquires" and insert the  
          word "purchases."

                                                                      



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          On page 10, lines 33-34, delete "offer for sale, advertise for  
          sale," and insert the word "sell" after "to."

          On page 12, lines 37 to 40 and page 13, lines 1 to 10 are  
          amended to read as follows:

          11711.  (a) If a person who bought or leased a motor vehicle or  
          motorcycle at retail suffers any loss or damage related to the  
          purchase or lease of that vehicle by reason of any fraud or  
          contract or statutory violation practiced on him or her by a  
          licensed dealer or one of the dealer's salespersons acting for  
          the dealer, on his or her own behalf, or within the scope of the  
          employment of his or her salesperson in connection with the  
          purchase or lease of that motor vehicle, or by reason of the  
          violation by such dealer or salesperson of any of the provisions  
          of Division 3 (commencing with Section 4000) of this code, than  
          that person shall have a right of action against the dealer, his  
          or her salesperson, and the surety upon the dealer's bond for  
          actual damages plus any incidental and consequential damages.


           Support  :  Congress of California Seniors; California Statewide  
          Law Enforcement Association; Consumer Federation of California;  
          Consumers Union; American Federation of State, County and  
          Municipal Employees; Consumer Watchdog; California Public  
          Interest Research Group; two individuals; Consumer Attorneys of  
          California; Teamsters

           Opposition  :  California New Car Dealers Association; California  
          Motorcycle Dealers Association; Watt Automotive, Santa Rosa

                                        HISTORY
           
           Source  :  Consumers for Auto Reliability and Safety

           Related Pending Legislation  :  None Known

           Prior Legislation  :

          AB 1939 (DeSaulnier, 2008), among other things, would have  
          increased the amount of the dealer's and remanufacturer's bond  
          to $100,000.  This bill died in the Senate Transportation and  
          Housing Committee.

          SB 729 (Padilla, Chapter 437, Statutes of 2007) (See Comment 7  
          for details.)
                                                                      



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          SB 1458 (Romero, Chapter 303, Statutes of 2002), among other  
          things, increased the amount of a vehicle dealer's bond and a  
          remanufacturer's bond to $50,000, except the amount of a dealer  
          who deals exclusively in motorcycles remains at $10,000.

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