BILL ANALYSIS
SENATE COMMITTEE ON BANKING, FINANCE,
AND INSURANCE
Senator Ronald Calderon, Chair
SB 1275 (Leno) Hearing Date: April 7, 2010
As Introduced: February 19, 2010
Fiscal: Yes
Urgency: No
SUMMARY Would require servicers to complete additional
actions, as specified, before recording a notice of default
(NOD), and record a new document, called a declaration of
compliance, as an attachment to every NOD; and would establish
specific penalties to be applied to servicers who failed to
comply with the provisions of the bill, as specified. Would
include the following, among the additional actions that
servicers would be required to perform, prior to recording a
NOD: mail borrowers a notice informing them of their
foreclosure-related rights and regarding foreclosure avoidance
options that may be available to them; mail borrowers an
application for a loan modification or other alternative to
foreclosure; evaluate borrowers who submit a written request for
a loan modification or other alternative to foreclosure for that
modification or other alternative; mail borrowers who have been
denied a loan modification or other alternative to foreclosure a
detailed denial explanation letter explaining the reasons for
their denial.
DIGEST
Existing law
1. Prescribes rules that govern the nonjudicial foreclosure
process in California (Civil Code Section 2924 et seq.). A
layman's description of the portions of the process that are
relevant to this bill follows immediately below. Modifications
that were made to this process by three recently-enacted pieces
of legislation are described in Existing Law numbers 2 and 3,
below.
a. The nonjudicial foreclosure process begins with the
recordation of a notice of default (NOD) by a mortgagee,
trustee, beneficiary, or authorized agent. The NOD must be
SB 1275 (Leno), Page 2
recorded in the county in which the property securing the
defaulted loan is located, and must be mailed to specified
persons with a financial interest in the property, including
the property owner. Existing law does not prescribe the
minimum amount of time that must pass between a delinquency
and the recordation of a NOD, although NODs are commonly
recorded only after a borrower is at least 90 days delinquent
on his or her mortgage loan;
b. At least three months must pass after the recordation of
a NOD, before the mortgagee, trustee, beneficiary, or
authorized agent may record a notice of sale. Notices of
sale must be recorded in the county in which the property
securing the defaulted loan is located, mailed to the
property owner and other specified persons with a financial
interest in the property, published in a newspaper of general
circulation, and posted on the property that is the subject
of the sale;
c. At least 20 days must pass after recordation of a notice
of sale, before a property may be sold. However, sale dates
may be, and often are, postponed. Under existing law, a sale
date may be postponed for any of the following reasons: a)
upon the order of any court of competent jurisdiction; b) if
stayed by operation of law; c) by mutual agreement, whether
oral or in writing, of any trustor and any beneficiary or any
mortgagor and any mortgagee (i.e., by mutual agreement
between a borrower and his or her lender); and/or d) at the
discretion of the trustee. A new notice of sale must be
recorded, if a postponement or postponements delay the sale
for more than 365 days following the first scheduled sale
date;
2. Pursuant to SB 1137 (Perata), Chapter 69, Statutes of 2008,
until January 1, 2013, requires the following, before a NOD may
be recorded on a mortgage or deed of trust, which was recorded
from January 1, 2003 through December 31, 2007, and which is
secured by single-family, owner-occupied residential real
property:
a. A mortgagee, beneficiary, or authorized agent must
contact a borrower in person or by telephone, in order to
assess the borrower's financial situation and explore options
for the borrower to avoid foreclosure. Contact (or attempted
contact, if a borrower is unreachable) must be made
telephonically and in writing, as specified. During the
SB 1275 (Leno), Page 3
initial contact, the mortgagee, beneficiary, or authorized
agent must advise the borrower that he or she has the right
to request a subsequent meeting, which, if requested, must
occur within 14 days of request. The mortgagee, beneficiary,
or authorized agent must also provide the borrower with a
toll-free telephone number that can be used by the borrower
to contact a HUD-certified housing counseling agency;
b. A mortgagee, beneficiary, or authorized agent must wait
at least 30 days after making initial contact with a
borrower, or satisfying specified due diligence requirements
to make contact, before it may record a NOD on a loan covered
by the provisions of SB 1137;
c. Each NOD that is recorded on a loan covered by the
provisions of SB 1137 must include a statement that the
mortgagee, beneficiary, or authorized agent contacted the
borrower, tried with due diligence to contact the borrower,
or that no contact was required, because one of the express
exemptions applied. Exemptions from the bill's contact
requirements are provided, in cases where a borrower has
already surrendered the property, has contracted with an
organization or other entity that advises borrowers on how to
"game" the foreclosure process, or has filed for a bankruptcy
that is still before a court;
3. Pursuant to SB 7 (Corbett) and AB 7 (Lieu), Chapters 4 and 5,
Statutes of 2009-2010 Second Extraordinary Session, until
January 1, 2011, requires the following, before a notice of sale
may be recorded on a mortgage or deed of trust, which was
recorded from January 1, 2003 to January 1, 2008, and which is
secured by single-family, owner-occupied residential real
property:
a. A mortgagee, trustee, or other person authorized to take
sale must wait an additional 90 days (over and above the
three months described in Existing law 1b above), before
recording a NOD. Exemptions from this additional 90-day
delay may be obtained by mortgage lenders and servicers who
apply to the Department of Financial Institutions,
Corporations, or Real Estate (depending on their primary
regulator), and who are deemed by the relevant commissioner
to have implemented a comprehensive loan modification
program, as specified;
b. Each notice of sale must include a declaration from the
SB 1275 (Leno), Page 4
mortgage loan servicer, indicating whether the servicer
obtained an order of exemption from one of the commissioners,
which was current and valid on the date the notice of sale
was recorded, or that no additional delay was required,
because one of the express exemptions applied. Exemptions
from the bill's 90-day delay requirements are provided, in
cases where a borrower has already surrendered the property,
contracted with an organization or other entity that advises
borrowers on how to "game" the foreclosure process, or filed
for a bankruptcy that is still before a court; and in cases
where the loan was made, purchased, or is being serviced by a
state or local public housing agency or authority.
This bill
1. Would, with one exception (see Number 3 below), apply its
requirements to mortgages and deeds of trust recorded prior
to January 1, 2009, which are secured by single-family,
owner-occupied, residential real property;
2. Would require a mortgagee, trustee, beneficiary, or
authorized agent to do all of the following, before
recording a NOD on a loan covered by the bill:
a. Provide a specified notice to borrowers, informing
them of their foreclosure-related rights, and explaining
various foreclosure avoidance options. This notice would
have to be made available by an unnamed state government
entity, in English and each of the five foreign languages
listed in Civil Code Section 1632 (Spanish, Tagalog,
Korean, Vietnamese, and Chinese);
b. Provide borrowers with an application for a loan
modification and other options for avoiding foreclosure;
c. Evaluate the written request of any borrower who
applies for a loan modification or other alternative to
foreclosure;
i. If the servicer determines that a
borrower is not eligible for a loan modification,
the servicer must send the borrower a denial
explanation letter, via certified mail, at least 15
days before the servicer records a NOD. This denial
explanation letter must explain in detail when and
why the borrower's application for a loan
SB 1275 (Leno), Page 5
modification was denied, and whether the borrower
was considered for any other alternative to
foreclosure. The denial explanation letter must
also include the name and contact information of the
holder of the note (an entity which is different
than the servicer, if the loan has been
securitized), and must include instructions
regarding how the borrower may dispute the written
decision(s) reflected in the denial explanation
letter;
ii. The bill is silent on the actions that
must be taken by the servicer, if the borrower's
request for an alternative to foreclosure is
approved;
3. Would require a mortgagee, beneficiary, or authorized agent
to do all of the following, concurrent with recordation of
an NOD on any mortgage or deed of trust, regardless of
whether the mortgage is secured by single-family or
multi-family residential real property or commercial
property:
a. Record a new document, called a Declaration of
Compliance. The Declaration of Compliance is a "check
the box" document, which asks the mortgagee, beneficiary,
or authorized agent to identify which of several specific
provisions of law apply to the loan, which of several
specific provisions of law were followed in connection
with the loan, and which of several specific options the
borrower elected, with respect to requesting a loan
modification. The Declaration of Compliance must be
signed by an individual having personal knowledge of the
information it contains;
4. Would provide that failure to record a Declaration of
Compliance, or recordation of a Declaration of Compliance
that fails to meet the requirements of the bill, is grounds
for either monetary damages or voiding the foreclosure sale,
depending on the entity to which the foreclosed home is sold
at the foreclosure sale, as follows:
a. If the property that is the subject of the
declaration is taken back by the financial institution
that initiated the foreclosure, the borrower may bring an
action to have the foreclosure sale voided;
SB 1275 (Leno), Page 6
b. If a bonafide third party acquires the property
through foreclosure sale, the bill authorizes the
borrower that previously owned the home to recover the
greater of $10,000 or treble damages from the entity that
failed to properly record a declaration;
5. Would provide an express exemption from its requirements,
in cases where a borrower has already surrendered the
property, has contracted with an organization or other
entity that advises borrowers on how to "game" the
foreclosure process, or has filed for a bankruptcy that is
still before a court;
6. Would sunset on January 1, 2013;
7. Would expand the coverage of SB 1137, to include mortgages
and deeds of trust recorded prior to January 1, 2009, which
are secured by single-family, owner-occupied, residential
real property;
8. Would require a mortgagee, beneficiary, or authorized agent
to do the following, concurrent with recordation of an NOD
on a loan that is subject to the requirements of SB 1137:
a. Mail the borrower a separate letter, via certified
mail, which includes the dates and times of, and
addresses and telephone numbers used to contact (or to
attempt to contact) the borrower, pursuant to the
requirements of SB 1137.
COMMENTS
1. Purpose of the bill To improve the procedures and
processes under existing foreclosure prevention programs,
with the following goals: 1) avoid unnecessary or mistaken
foreclosures; 2) encourage fair treatment of borrowers and
more timely outcomes; 3) provide greater transparency to
borrowers about foreclosure prevention decisions and
outcomes; and 4) provide borrowers with a remedy against
servicers who fail to comply with the law.
2. Background The language of SB 1275 was developed by staff
of Housing and Economic Rights Advocates (HERA), a
statewide, not-for-profit legal service and advocacy
organization. HERA drafted the proposal that formed the
SB 1275 (Leno), Page 7
basis for SB 1275, in response to its frustrations over the
treatment received by borrowers from their servicers, and
their belief that many borrowers who are eligible for loan
modifications are failing to be offered those modifications,
before being foreclosed on by their lenders. HERA, and many
other persons and organizations who advocate for borrowers,
has seen all of the following: borrowers told that they
cannot be helped until they become delinquent, then told
they cannot be helped because they are delinquent; borrowers
put on hold by their servicers for lengthy periods of time;
borrowers disconnected after long waits on hold; servicers
losing or misplacing borrowers' loan modification paperwork,
sometimes repeatedly; servicers giving borrowers conflicting
answers regarding the status of their loan modification
application; servicers willing to provide borrowers verbal
denials regarding their eligibility for a loan modification,
but unwilling to provide a written denial letter; servicers
unwilling to explain to borrowers the reasons they were
denied a loan modification; servicers foreclosing on
borrowers who are still being considered for a loan
modification; and servicers unwilling to consider options
other than foreclosure, after a borrower is denied a loan
modification.
The federal Making Home Affordable Program was developed by
the U.S. Department of the Treasury (Treasury), at the
urging of President Obama, in an effort to help borrowers
avoid foreclosure. The program includes several components,
such as the Home Affordable Modification Program (HAMP),
Home Affordable Refinancing Program (HARP), Second Lien
Modification Program (2MP), and Home Affordable Foreclosure
Alternatives (HAFA) Program.
Since its introduction in February 2009, HAMP has become the
cornerstone of most servicers' loss mitigation efforts. Any
financial institution that received Troubled Asset Relief
Program (TARP) funding must comply with HAMP, as must any
financial institution that voluntarily agrees to participate
in the program (something that, to date, over 100 financial
institutions have agreed to do). Furthermore, although
loans owned or guaranteed by Fannie Mae and Freddie Mac are
not required to be run through the HAMP program by their
servicers, both government-sponsored enterprises (GSEs) have
issued directives to their servicers that essentially
duplicate the HAMP program.
SB 1275 (Leno), Page 8
Thus, for all intents and purposes, nearly every borrower who
contacts their servicer to discuss options for avoiding
foreclosure must be run through the HAMP eligibility
process, before the servicer may consider that borrower for
other forms of loss mitigation or for foreclosure.
The primary exception to this general rule involves borrowers
whose loans are serviced by small depository institutions,
such as credit unions and community banks, or by other small
lenders. Because very few of these institutions took TARP
money, and very few have signed up to participate in HAMP,
borrowers whose loans are serviced by these types of
institutions are often evaluated individually by their
lenders, using the lender's in-house loss mitigation
programs. Staff notes, however, that the number of
borrowers who fit into this "non-HAMP" category is extremely
small. The vast majority of borrowers in California, who
have mortgages, hold loans serviced by financial
institutions that are covered by HAMP or that are covered by
nearly identical GSE HAMP-like loss mitigation programs.
The Making Home Affordable Program has been modified,
augmented, and clarified several times since its
introduction, through the issuance of Supplemental
Directives. Treasury issued ten Supplemental Directives
during 2009 (two of which were significantly modified during
2010), and has so far issued three Supplemental Directives
during 2010, the most recent of which were issued on March
26, 2010. More Supplemental Directives, and more
modifications to existing Supplemental Directives, are
likely, as Treasury works with servicers and housing
advocates to help refine and improve its Home Affordable
programs.
Many of these Supplemental Directives are significant for SB
1275, because they share the same goal as this bill, and
require actions by servicers that are very similar to the
actions required by this bill. Yet, because this bill was
drafted before the issuance of the most recent Supplemental
Directives, its language is now inconsistent with the
language of the recent Directives. Further amendments to
this bill will be necessary, to avoid conflicts between
state law and the Making Home Affordable program.
3. Support SB 1275 is strongly supported by consumer groups,
housing counseling organizations, and organized labor. All
SB 1275 (Leno), Page 9
of these groups see SB 1275 as a way to prevent unnecessary
foreclosures in California.
HERA, the group that drafted the proposal which formed the
basis for SB 1275, writes that a number of obstacles stand
in the way of achieving large-scale reductions in the number
of foreclosures in California. One major obstacle is the
difficulty that homeowners in financial distress have in
getting reviewed for and receiving sustainable loan
modifications. "Borrowers and housing counselors throughout
the State report that they regularly face seemingly
insurmountable obstacles when they contact loan servicers
for assistance. These include delays of many months to over
a year in processing applications; financial and other
documentation lost by the servicer; repeated requests from
the servicer for the borrower to send in additional
documentation or to send in the same documentation over and
over again; miscalculations or misreading of borrower income
leading to mistaken denials; misapplication and
misrepresentation of investor guidelines and restrictions
leading to mistaken denials; inconsistent, inaccurate and
contradictory information provided to borrowers about their
rights and obligations; foreclosures conducted while a
modification application is pending (or while a trial plan
is in effect) because the servicer failed to instruct the
foreclosure trustee to postpone the sale; and unnecessary
foreclosures conducted after an erroneous denial.
"In the vast majority of cases, borrowers and their advocates
are confronted with an overwhelming lack of information and
communication from the servicer - about the status of their
applications, the documentation they need to provide, and,
in the event a borrower is notified that an application has
been denied, about the reasons for the denial. This lack of
transparency makes it nearly impossible for borrowers to
figure out where they are in the review process or assess
whether a denial is erroneous."
HERA believes that SB 1275 will ensure that no homes are
unnecessarily foreclosed on, if they can be saved from
foreclosure under existing programs. If there has been a
mistake in a servicer's review of a borrower for a loan
modification, SB 1275 will give the borrower and servicer
enough time to correct those errors, before the borrower
loses his or her home. HERA goes on to state, "SB 1275 will
not, however, require servicers to modify a loan where the
SB 1275 (Leno), Page 10
borrower does not qualify for assistance under an already
existing modification program. It will not require
servicers to assist so called "strategic defaulters,"
borrowers who are not in financial distress but voluntarily
stop making payments on their mortgage because keeping the
home is no longer in their financial best interest."
Consumers Union (CU) writes, "By requiring servicers to screen
borrower's for eligibility for a federal HAMP loan
modification, or it's own modification program, before
filing a notice of default, eligible borrowers have an early
opportunity to enter into a loan modification to stay on
track with their mortgage payments before falling further
behind and entering the foreclosure pipeline." CU also
supports the provisions of the bill that require clearer
notices to at-risk homeowners about the opportunity to apply
for a loan modification before the foreclosure process
begins; require detailed, clear, and timely denial
explanation letters to be sent to borrowers who are found
ineligible for a loan modification; and provide borrowers
with legal remedies to void foreclosure sales and/or obtain
statutory damages, if the provisions of the bill are
violated.
The Center for Responsible Lending (CRL) believes that SB 1275
"would fulfill the promise of prior foreclosure-prevention
legislation." By providing more specific requirements and
transparency around existing requirements for
pre-foreclosure communications with homeowners, the bill
will ensure that borrowers are assessed for loan
modifications before entering the foreclosure process.
That, in turn, will result in more consistent treatment of
borrowers and fewer foreclosures.
CRL believes that placing the bill's requirements at the
pre-NOD stage is crucial to the bill's success, for several
reasons. First, requiring the servicer to determine the
borrower's qualification for such options at the pre-NOD
stage is consistent with the original intent of SB 1137.
Requiring an evaluation of loan modification eligibility
pre-NOD also increases efficiency, by requiring servicers to
record only one set of documents with the county recorder's
office. Second, requiring a servicer to complete its
foreclosure avoidance inquiry prior to filing a NOD reduces
costs, by avoiding needless filing fees and legal costs.
Third, by delaying the initiation of the foreclosure process
SB 1275 (Leno), Page 11
until after foreclosure alternatives are evaluated, the bill
provides a stronger incentive for servicers to process their
evaluations more efficiently. Fourth, placing the bill's
requirements at a later stage in the foreclosure process
(such as prior to the notice of sale) would not provide the
homeowner with sufficient time to enforce their rights upon
a violation of the bill by a servicer. Fifth, avoiding
unnecessary NOD filings is in the public interest, to
protect borrowers from scams. NODs are public records that
have long been used by foreclosure rescue scammers and other
real estate scammers as a way to target stressed and
vulnerable homeowners.
Finally, while CRL strongly supports SB 1275, it supports two
amendments, to clarify and tighten the bill and further its
goals. First, CRL would like the bill to include an
explicit requirement that the servicer send the borrower a
letter detailing the reasons for denying a loan modification
or other request. The bill currently requires the servicer
to certify that it has sent such a letter, but does not
directly require the servicer to send the letter. Second,
CRL believes that courts should be authorized to award
attorneys' fees and costs, upon a court finding that a
servicer has not materially complied with the substantive
requirements of the bill.
Several housing counseling and consumer advocacy
organizations, including the California Reinvestment
Coalition, CALPIRG, Coalition for Quality Credit Counseling,
Consumer Credit Counseling Service of the North Coast,
Neighborhood Housing Services of Silicon Valley, Contra
Costa Interfaith Supporting Community, and many others, sent
very similar letters, in which they assert that existing law
has failed to prevent avoidable foreclosures in significant
numbers. Stories abound regarding lost paperwork,
miscalculations of income leading to mistaken denials,
unclear, irrelevant, or inconsistent grounds for denials,
foreclosures occurring even while borrowers are under
consideration for a loan modification, and foreclosures
occurring even after borrowers have successfully completed a
trial modification. "No one benefits - not the servicer,
not the investors, not the homeowners, not the community,
and not the economy -- when a home is sold in foreclosure
that was previously being saved through a loan
modification."
SB 1275 (Leno), Page 12
4. Opposition The Civil Justice Association of California
(CJAC) opposes SB 1275, on the basis that the bill imposes a
host of detailed new requirements on lenders, creating new
obligations for them to fulfill before they foreclose. Any
violation of the law by a lender, no matter how technical,
is enforceable by a lawsuit to stop the foreclosure. CJAC
notes that California's nonjudicial foreclosure process is
already highly regulated. There is no need to insert
lawyers and lawsuits into the process.
A coalition of financial services and building industry trade
groups, together with the California Chamber of Commerce,
sent a joint letter of opposition. "While we endeavor to
understand the intricacies of this measure and its impact,
we argue that the bill exemplifies an overly complicated
formula that will be layered onto recently enacted borrower
outreach efforts to further frustrate and prolong existing
foreclosure and loss mitigation efforts." The coalition
believes that SB 1275 will add to the complexity of the loss
mitigation process for servicers and create a series of
procedural traps that will lead to ever-increasing
litigation. In addition, they observe that SB 1275 would
inappropriately intervene in pending litigation that has
resulted from enactment of SB 1137.
The coalition also observes that, given recent changes to
HAMP, and given the likelihood of new changes to the program
in the near future, SB 1275 is unnecessary. The coalition
cites recently-released Supplemental Directives, including
Directive 09-08, released in November 2009, which, effective
January 1, 2010, requires servicers to provide borrowers
with a written denial explanation letter, if they are found
ineligible for a HAMP modification; and Directive 10-02,
released on March 26, 2010, which, effective June 1, 2010,
prevents a servicer from foreclosing on a borrower until the
borrower has been evaluated, and eligibility has been
determined under HAMP.
Finally, the coalition concludes that, "how this measure
interacts mechanically and chronologically with recent state
and federal regulatory and statutory changes is unclear."
The bill will result in compliance hurdles and will be a
detrimental distraction to industry's efforts to help its
customers.
5. Questions
SB 1275 (Leno), Page 13
a. Changes to the HAMP program and its sister
programs (such as 2MP and HAFA) are being released
frequently by the U.S. Department of the Treasury.
How can the California Legislature ensure that this
bill does not create a set of requirements, which end
up in conflict with the rules of federal foreclosure
avoidance programs?
6. Prior and Related Legislation:
a. Key prior legislation, including SB 1137
(Perata), Chapter 69, Statutes of 2008, SB 7
(Corbett), Chapter 4, 2009-2010 Second Extraordinary
Session, and AB 7 (Lieu), Chapter 5, 2009-2010 Second
Extraordinary Session are described in the Existing
Law section of this analysis. Related, pending
legislation is summarized below;
b. AB 1639 (Nava), 2009-2010 Legislative Session:
Would establish the Mediated Mortgage Workout
Program, as specified. Pending a hearing in the
Assembly Banking & Finance Committee;
c. AB 2024 (Blumenfield), 2009-2010 Legislative
Session: Would require any lender or servicer that
rejects a loan modification request to send a
notification to the borrower via certified mail,
specifically stating the reasons why the loan
modification request was rejected. Pending a hearing
in the Assembly Banking & Finance Committee;
d. AB 2236 (Monning), 2009-2010 Legislative
Session: Would require a mortgagee, trustee,
beneficiary, or authorized agent to include the name
and contact information of the entity that has the
authority to modify the terms of a borrower's loan, on
all notices informing a borrower that he or she either
failed to make a required minimum payment or failed to
make a payment when due. Pending a hearing in the
Assembly Banking & Finance Committee;
e. AB 2678 (Fuentes), 2009-2010 Legislative
Session: Would prohibit a mortgagee, trustee,
beneficiary, or authorized agent from giving notice of
sale, if the mortgagee, trustee, beneficiary, or
SB 1275 (Leno), Page 14
authorized agent is currently in negotiations to
modify the loan that is the subject of the notice of
sale. Would also require borrowers to be informed,
every time a foreclosure sale is postponed. Pending a
hearing in the Assembly Banking & Finance Committee.
POSITIONS
Support
Alliance of Californians for Community Empowerment
California Alliance for Retired Americans
California Capital Financial Development Corporation
California Coalition for Rural Housing
California Conference Board of the Amalgamated Transit Union
California Conference of Machinists
California Human Development Corporation
California Labor Federation
California Reinvestment Coalition
CALPIRG
Causa Justa:Just Cause
Center for Responsible Lending
Coalition for Quality Credit Counseling
Community Financial Resources
Community Housing Works, San Diego
Consumer Credit Counseling Service of the North Coast
Consumer legal Services in East Palo Alto
Consumers Union
Contra Costa Interfaith Supporting Community Organization
Council on Aging Silicon Valley
East LA Community Corporation
East Palo Alto Council of Tenants Education Fund
Housing and Economic Rights Advocates
Inland Fair housing and Mediation Board
International Longshore and Warehouse Union
JOLT, Coalition for Responsible Investing
Law Foundation of Silicon Valley
Neighborhood Housing Services of Orange County
Neighborhood Housing Services of Silicon Valley
Novadebt
Oakland Community Organizations
Opportunity Fund
Orange County Fair Housing Council, Inc.
Professional and Technical Engineers, IFPTE Local 20
Public Counsel
Rural Community Assistance Corporation
SB 1275 (Leno), Page 15
Sacramento Gray Panthers
Sacramento Housing Alliance
Sacramento Mutual Housing Association
Southern California housing Rights Center
The Mission Economic Development Agency
United Food & Commercial Workers Western States Council
UNITE-HERE
Vallejo Neighborhood Housing Services, Inc.
Vermont Slauson Economic Development Corp.
Yolo Mutual Housing Association
Oppose
California Bankers Association
California Building Industry Association
California Chamber of Commerce
California Financial Services Association
California Independent Bankers
California Land Title Association
California Mortgage Association
California Mortgage Bankers Association
Civil Justice Association of California
Securities Industry and Financial Markets Association
Consultant: Eileen Newhall (916) 651-4102