BILL ANALYSIS                                                                                                                                                                                                    






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


          SB 1047 (Correa)
          As Amended April 15, 2010
          Hearing Date: May 4, 2010
          Fiscal: No
          Urgency: No
          BCP:jd
                    

                                        SUBJECT
                                           
               Mobilehomes: Nonprofit Resident-owned Mobilehome Parks

                                      DESCRIPTION  

          This bill would clarify that the tenant provisions of the  
          Mobilehome Residency Law apply in nonprofit resident-owned  
          mobilehome parks to members of the nonprofit mutual benefit  
          corporation that lease a space in the park.

                                      BACKGROUND  

          Enacted in 1978, the Mobilehome Residency Law (MRL) governs the  
          relationship between park owners or managers and the residents  
          of the 4,800+ mobilehome parks and manufactured housing  
          communities in California.  In most of those parks, residents  
          own their home but lease the land on which their home is  
          installed.  

          Over the past twenty years, residents have been increasingly  
          interested in various ways to purchase their parks and the space  
          upon which the home is installed.  One method of purchasing a  
          park - the nonprofit mutual benefit corporation (the subject of  
          this bill) - is described by the Department of Real Estate as  
          follows:

            Park residents need a legal entity to purchase their park.   
            A nonprofit mutual benefit corporation is well suited to  
            this purpose.  In general, the nonprofit corporation makes  
            an offer of participation to the residents.  Residents who  
            decided to participate become shareholders or members of the  
            corporation.  As residents purchase shares or memberships in  
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            the corporation, cash is accumulated for the down payment  
            required to purchase the park.  The officers of the  
            corporation, elected by the members and acting on their  
            behalf, negotiate with the seller to purchase the park and  
            solve problems relating to conversion.  After conversion,  
            the corporation may manage the park.

          To deal with the various facets of mobilehome parks and  
          manufactured housing communities, the MRL is divided into nine  
          different Articles.  Articles 1-8 of the MRL deal with legal  
          rights and remedies for mobilehome parks which rent space to  
          residents. Article 9 of the MRL generally deals with the legal  
          rights and remedies of resident owned mobilehome parks. Under  
          existing law, residents who have shares in a nonprofit mutual  
          benefit corporation but lease their space from that corporation  
          fall under Article 9, but not Articles 1-8 of the MRL.  To  
          address concerns that those residents should, instead, be  
          subject to the provisions of the MRL that deal with tenants,  
          this bill would clarify that Articles 1-8, but not Article 9, of  
          the MRL apply in that circumstance. 

                                CHANGES TO EXISTING LAW
           
           Existing law  , the Mobilehome Residency Law (MRL), contains nine  
          Articles that extensively regulate the rights, responsibilities,  
          obligations, and relationships between mobilehome park  
          owners/management and park residents.  Articles 1 - 8 deal with  
          legal rights and remedies related to the leasing of space by  
          tenants; Article 9 contains provisions that apply to resident  
          owned parks. (Civ. Code Sec. 789 et seq.)

           Existing law  provides that in a subdivision, cooperative, or  
          condominium for mobilehomes, or a resident-owned mobilehome  
          park, Articles 1 through 8 of the MRL apply only to residents  
          who do not have an ownership interest in the subdivision,  
          cooperative, or condominium for mobilehomes, or a resident-owned  
          mobilehome park.  Existing law further provides that Article 9  
          of the MRL governs residents who do have an ownership interest  
          in the subdivision, cooperative, or condominium for mobilehomes,  
          or resident-owned mobilehome park. (Civ. Code Sec. 799.1.)  

           This bill  would clarify that Articles 1 through 8, but not  
          Article 9, of the MRL apply to nonprofit resident-owned  
          mobilehome parks.

           This bill  would define a "nonprofit resident-owned mobilehome  
                                                                      



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          park" as a park owned and operated by a nonprofit mutual benefit  
          corporation, as specified, whose members consist of park  
          residents where there is no recorded condominium plan, tract,  
          parcel map, or declaration.
           
          This bill  would provide that a "mobilehome park," as defined in  
          the MRL, includes a "nonprofit resident-owned mobilehome park"  
          where the member leases his or her space, and make other  
          conforming changes.

                                           







                                       COMMENT
           
          1.   Stated need for the bill  

          According to the author:

            The present law treats . . . members of a mutual benefit  
            non-profit corporation as if they actually own the space in  
            which their home is sited and treats them as if the typical  
            CC&R provisions apply and provide governance as to their  
            actions in such a park.  No such CC&R provisions exist and  
            the persons who are members lease the home site from the  
            Corporation in which they are members and as such these  
            members have neither the protection of the Civil Code  
            sections set forth in [Civil Code Section 798] or the  
            typical CC&R provisions.  The Corporation also has no viable  
            method to enforce the members obligations outside the leases  
            which often refer to [Civil Code Section] 798 which per  
            [Civil Code Section 799] cannot apply and cannot be used to  
            enforce the Park leases or Rules and Regulations.

          2.    Bill would clarify the application of the MRL to nonprofit  
            resident-owned mobilehome parks

           Under existing law, residents of a mobilehome park may form a  
          nonprofit mutual benefit corporation for the purpose of  
          purchasing the park.  The residents must then obtain permission  
          from the Department of Corporations to issues shares - the  
                                                                      



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          corporation owns the park but each resident may purchase a  
          share.  This bill seeks to clarify the application of the MRL to  
          residents who are both members of the corporation and lease  
          their space from that corporation.

          The provisions of the MRL are separated into nine different  
          articles - the first eight deal with residents who rent their  
          space from the park, including requirements regarding the rental  
          agreement, rules and regulations, fees, utilities, rent control,  
          homeowner communications and meeting, termination of tenancy,  
          and transfer of mobilehomes.  Article 9 (the last article)  
          applies to residents who have an ownership interest in a  
          subdivision, cooperative, or condominium for mobilehomes, or a  
          resident-owned mobilehome park.  That article further states  
          that in a subdivision, cooperative, condominium, or  
          resident-owned park, Articles 1 through 8 (the provisions  
          governing the landlord tenant relationship) only apply to  
          residents without an ownership interest.  Given that residents  
          who do have a share in a nonprofit mutual benefit corporation  
          but lease their space arguably do have an ownership interest in  
          the park, that provision removes the protections contained in  
          the tenant provisions of Articles 1 through 8.

          As a result, the author notes that those members, and the  
          corporation, do not have the protection of the provisions of the  
          MRL that typically govern residents who rent their space in the  
          park.  In response to those concerns, this bill would  
          specifically provide that Articles 1 through 8 (the tenant  
          provisions), not Article 9, apply to nonprofit resident-owned  
          mobilehome parks where the member of the corporation leases  
          their space from the park.  That application ensures that even  
          though those residents do have an ownership interest in the  
          nonprofit mutual benefit corporation, they still have the  
          protections of the tenant portions of the MRL when they lease  
          their space from that corporation.

          Committee staff further notes that that the application of  
          Articles 1 through 8, but not Article 9, is consistent with the  
          structure of the MRL - the MRL is generally written to make  
          those two sets of Articles exclusive. 

          3.    Definition of "nonprofit resident-owned mobilehome park"  

          This bill would define "nonprofit resident-owned mobilehome  
          park" as a park owned and operated by a nonprofit mutual benefit  
          corporation whose members consist of park residents where there  
                                                                      



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          is no recorded condominium plan, tract, parcel map, or  
          declaration.  Staff notes that the lack of recordation of those  
          documents ensures that the bill addresses the narrow situation  
          where a nonprofit mutual benefit corporation has been formed,  
          but the property has not been formally subdivided.  If the park  
          is subdivided, Article 9 would apply to residents with an  
          ownership interest while Articles 1 through 8 continues to apply  
          to residents without that interest.

          4.    Opposition by the Western Manufactured Housing Communities  
            Association (WMA) to be removed by clarifying amendment  

          WMA, in opposition to the April 15, 2010 version of this bill,  
          states that while there are legitimate concerns that the author  
          is looking to address, the bill is not clear and could have  
          potential unintended consequences.  To address those concerns,  
          WMA "respectfully request[s] that no changes be made in the 798  
          portion of the Mobilehome Residency Law (MRL) and that the bill  
          only make changes to the 799 portion."

          Consistent with that request, the clarifying amendment in  
          Comment 5 would, in fact, strike the proposed changes to Section  
          798.  The author has agreed to accept that amendment, and, based  
          upon that proposed amendment, WMA has removed their opposition.

          5.   Clarifying amendment  

          The author has agreed to accept the following amendment to  
          clarify the provisions of this bill:

          Strike entire contents of the bill and insert:

               SECTION 1. Section 799.1 of the Civil Code is amended to  
          read:

               799.1 (a) This article shall govern the rights of a  
          resident who has an ownership interest in the subdivision,  
          cooperative, or condominium for mobilehomes, or a resident-owned  
          mobilehome park in which his or her mobilehome is located or  
          installed.  In a subdivision, cooperative, or condominium for  
          mobilehomes, or a resident-owned mobilehome park, Articles 1  
          (commencing with Section 798) to 8 (commencing with Section  
          798.84), inclusive, shall apply only to a resident who does not  
          have an ownership interest in the subdivision, cooperative, or  
          condominium for mobilehomes, or the resident-owned mobilehome  
          park, in which his or her mobilehome is located or installed. 
                                                                      



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               (b) Notwithstanding subdivision (a), in a mobilehome park  
          owned and operated by a nonprofit mutual benefit corporation,  
          established pursuant to Section 11010.8 of the Business and  
          Professions Code, whose members consist of park residents where  
          there is no recorded condominium plan, tract, parcel map, or  
          declaration, Articles 1 (Commencing with Section 798) to 8  
          (commencing with Section 798.84), inclusive, shall govern the  
          rights of members who are residents that have a rental agreement  
          with the corporation.
          

           Support  :   None Known

           Opposition  :   Western Manufactured Housing Communities  
          Association (removed upon acceptance of the amendment in Comment  
          5)

                                        HISTORY
           
           Source  :  Author

           Related Pending Legislation  :  None Known

           Prior Legislation  :  None Known

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