BILL ANALYSIS                                                                                                                                                                                                    






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


          SB 1427 (Price)
          As Amended April 19, 2010
          Hearing Date: May 4, 2010
          Fiscal: No
          Urgency: No
          BCP
                    

                                        SUBJECT
                                           
                         Foreclosures: Property Maintenance

                                      DESCRIPTION  

          Existing law requires legal owners to maintain vacant  
          residential properties that were purchased at a foreclosure  
          sale, permits government entities to impose civil fines of up to  
          $1,000 per day per violation, and provides that the provision  
          does not preempt local ordinances.  This bill would, instead,  
          state that existing law does preempt local ordinances.

          This bill would additionally provide that:
           Fines and penalties imposed for failure to maintain a property  
            in foreclosure, as specified, are the obligation of the owner  
            of record at the time of violation.
           The costs of nuisance abatement measures taken by a  
            governmental entity with regard to property that is subject to  
            a notice of default shall be the obligation of the legal owner  
            of that property and treated as a tax lien.
           The costs of nuisance abatement measures shall not exceed the  
            actual and reasonable costs of nuisance abatement, and state  
            that a governmental entity shall adopt a schedule of costs for  
            nuisance abatement measures prior to collection of those  
            costs.

                                      BACKGROUND  

          There are many negative side effects that a foreclosure can have  
          upon a community, including the possibility that the property  
          will be damaged by the borrower who was unable to avoid  
          foreclosure, or that a vacant property will fall into disrepair,  
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          attract vandals, and pose a health and safety risk.    
          Deteriorating, blighted properties may also depress surrounding  
          property values.  


          In response to those concerns, SB 1137 (Perata, Corbett,  
          Machado, Chapter                                  69, Statutes  
          of 2008), required legal owners to maintain vacant residential  
          properties that were purchased at a foreclosure sale.  To  
          enforce that maintenance requirement, government entities were  
          given the authority to impose a civil fine of up to $1,000 per  
          day per violation.  Under the provisions of SB 1137, government  
          entities are required to provide notice of their intent to  
          impose a fine, if corrective action is not commenced within 14  
          days and completed within 30 days.  Those anti-blight provisions  
          sought to encourage the repair of foreclosed homes, while  
          providing a penalty should residences not be repaired in the  
          time allowed.  To ensure that local governments had the  
          authority to enact stronger, custom ordinances that responded to  
          unique issues within their community, SB 1137's blight provision  
          specifically did not preempt local ordinances.


          Contrary to that provision of SB 1137, this bill would, instead,  
          provide that the above-described blight provision does preempt  
          local ordinances, thus wiping out an unknown number of local  
          ordinances.  The bill would also enact several provisions  
          addressing liability for the cost of fines, penalties and  
          nuisance abatement, and ensure that the costs of nuisance  
          abatement not exceed actual and reasonable costs as well as  
          requiring a governmental entity to adopt a schedule of costs for  
          nuisance abatement measures.


                                CHANGES TO EXISTING LAW
           
           Existing law  provides that anything that is injurious to health,  
          indecent or offensive to the senses, obstructs the free use of  
          property, or unlawfully obstructs free passage is a nuisance.  
          (Civ. Code  Sec. 3479.)

           Existing law requires a legal owner to maintain vacant  
          residential property purchased by that owner at a foreclosure  
          sale, or acquired by that owner through foreclosure under a  
          mortgage or deed of trust.  A governmental entity may impose a  
          civil fine of up to one thousand dollars ($1,000) per day for a  
                                                                      



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          violation.  If a government entity chooses to impose a fine  
          pursuant to this section, it shall give notice of the alleged  
          violation, as specified, and notice of intent to assess a civil  
          fine if action to correct the violation is not commenced within  
          14 days and completed within 30 days.  (Civ. Code Sec. 2929.3.)

           Existing law  requires the governmental entity to provide the  
          legal owner with not less than 30 days to remedy the violation  
          prior to imposing a civil fine and requires that the entity  
          provide a hearing and opportunity to contest any fine imposed.   
          The governmental entity may provide less than 30 days' notice to  
          remedy a condition before imposing a civil fine if the entity  
          determines that a specific condition of the property threatens  
          public health or safety, provided that notice of that  
          determination and time for compliance is given.  (Civ. Code Sec.  
          2929.3 (a)(2), (c).)

           Existing law  states that the above provisions shall not preempt  
          any local ordinance, and prohibits a governmental entity from  
          imposing both the fines specified above and a local ordinance.   
          (Civ. Code Sec. 2929.3(e),(h).)

           This bill  would, instead, state that the above provisions do  
          preempt local ordinances.

           This bill  would additionally state that the fines and penalties  
          imposed for failure to maintain a property subject to a notice  
          of default, or a property that has not been purchased at a  
          foreclosure sale, or acquired through foreclosure under a  
          mortgage or deed of trust, are the obligation of the owner of  
          record at the time of violation, and permit a lien to attach to  
          the parcel upon recordation.

           This bill  would provide that the costs of nuisance abatement  
          measures taken by a governmental entity with regard to property  
          that is subject to a notice of default shall be the obligation  
          of the legal owner of that property and treated as a tax lien.

           This bill  would state that the costs of nuisance abatement  
          measures shall not exceed the actual and reasonable costs of  
          nuisance abatement, and that a governmental entity shall adopt a  
          schedule of costs for nuisance abatement measures prior to  
          collection of those costs.

                                        COMMENT
           
                                                                      



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          1.   Stated need for the bill  

          According to the sponsor, the California Association of  
          Realtors:

            SB 1427 will require cities to provide an REO owner with  
            notice of violation of an abandoned property maintenance  
            ordinance and as well as an opportunity to correct the  
            violation before fines can [be] assessed for failing to  
            maintain the post-foreclosure property.  In addition, the  
            bill specifies that the costs of nuisance abatement measures  
            taken by cities must be actual and reasonable, and requires  
            cities to adopt a schedule of such costs.

            These changes to existing law are needed to provide lenders  
            with clear notice of an abandoned property maintenance  
            ordinance violation, the opportunity to correct the  
            violation before fines can be assessed, and a clear  
            understanding of exactly how much each nuisance abatement  
            measure taken by the local city will cost should the lender  
            fail to correct the violation themselves.  

            Realtors are caught between local cities and lenders.  With  
            a post-foreclosure property, the asset manager hired by the  
            lender is often a Realtor trying to preserve the property  
            and/or arrange a sale of the REO [Real Estate (lender)  
            Owned].  Due process and clarity in the assessment and  
            collection of nuisance abatement costs provides fairness to  
            everyone, including Realtors.  Moreover, fairness in the  
            assessment and notice process increases the likelihood that  
            the property will be maintained.  Selling the home to an  
            individual that will maintain the property is the best  
            solution to the blight problem which can devalue homes in a  
            neighborhood.




          2.   Local ordinances  

          In order to address the serious issue of blight in communities  
          plagued by foreclosure, SB 1137 permitted local governments to  
          assess fines and penalties against legal owners who fail to  
          maintain vacant foreclosed homes.  That provision was included  
          in response to reports of abandoned foreclosed homes becoming  
          overgrown and diminishing the value of surrounding properties,  
                                                                      



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          public safety issues relating to trespassers and drug use, and  
          swimming pools filled with mosquitoes that may spread disease.   
          SB 1137 also required governmental entities to provide notice  
          and up to 30 days to cure the alleged violation.  To allow local  
          governments to enact their own custom ordinances that are  
          tailored to their unique situations, SB 1137 provided that its  
          blight provision did not preempt local ordinances.

          Contrary to the original intent of SB 1137, this bill would,  
          instead, provide that SB 1137's blight provision does preempt  
          local ordinances.  That preemption could potentially wipe out  
          numerous local ordinances that are currently used by cities to  
          address foreclosure blight.  The Center for Responsible Lending,  
          in opposition, asserts that local ordinances that address blight  
          should not be preempted, and that "[g]iven the extent of the  
          crisis and the accompanying blight in neighborhoods across the  
          State, combined with increased crime and reduced revenues for  
          localities to respond, these localities should be given the  
          right and power to confront these issues as they deem  
          appropriate." The Alliance of Californians for Community  
          Empowerment (ACCE), in opposition, expresses similar concerns  
          and asserts that preemption of local ordinances would put the  
          ability of cities and counties to create solutions to blight in  
          jeopardy.

          In response to concerns regarding preemption, the sponsor states  
          that their intent was to ensure that those local ordinances do  
          include a provision that provides the property owner with notice  
          and an opportunity to address the problem.  (CAR's letter in  
          support of the bill asserts that: "Cities will still be able to  
          have vacant property maintenance ordinances; however, the  
          ordinances will have to be consistent with state law with regard  
          to the notice and curing provisions.")  To address the concerns  
          about preemption of entire local ordinances and effectuate the  
          sponsor's intent, the author offers the following amendments to,  
          instead, require government entities to provide a notice and  
          opportunity to correct the violation prior to assessing fines  
          and penalties.  That approach is consistent with SB 1137's  
          requirement that local governments provide notice and an  
          opportunity to remedy prior to assessing fines and penalties.   
          From a public policy standpoint, that provision would encourage  
          owners of properties to correct maintenance issues in an  
          expedient manner so that they would not incur a fine or penalty  
          - in other words, the intent of the provision is to encourage  
          correction of blight, not to provide a revenue stream.   
          Committee staff notes that it would be in the discretion of the  
                                                                      



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          local government entity to determine how to provide the notice  
          and opportunity to cure.



             Author's amendment: 

            Strike out Section 1, and insert:

            Prior to imposing a fine or penalty for failure to maintain a  
            vacant foreclosed property that is subject to a notice of  
            default, or that has been purchased at a foreclosure sale or  
            acquired through foreclosure under a mortgage or deed of  
            trust, a governmental entity shall provide the owner of that  
            property with a notice of violation and an opportunity to  
            correct the violation.

          Consistent with SB 1137's blight provision, the following  
          additional amendment is suggested to ensure that the provision  
          of notice and an opportunity to correct does not apply if a  
          condition of the property threatens public health or safety.   
          That amendment is essential to ensure that local governments  
          have the authority to take immediate action to protect the  
          surrounding community.

             Suggested amendment:  

            Add the following language to the above amendment:

            This section shall not apply if the entity determines that a  
            specific condition of the property threatens public health or  
            safety.

          3.   Fines, penalties, and nuisance abatement costs  

          This bill additionally seeks to codify that nuisance abatement  
          costs are the obligation of the legal owner and shall be treated  
          as a tax lien against the property in a foreclosure sale.  The  
          sponsor asserts that the intent of that provision is to allow  
          those costs to survive foreclosure (essentially creating a  
          super-lien), and to hold the entity receiving the property after  
          the foreclosure sale liable for those costs under the theory  
          unjust enrichment.  Despite those assertions, it should be noted  
          that this provision would essentially hold a third party liable  
          for the failure of the homeowner to take care of their property  
          - even after the foreclosure sale, that homeowner currently  
                                                                      



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          remains personally liable for costs incurred in nuisance  
          abatement.  Committee staff also notes that the actions which  
          are taken to abate a nuisance are things such as removing  
          mosquitoes that pose a risk to surrounding properties and would  
          not include improvements, such as installing granite  
          countertops, that actually enhance the resale value of the  
          property.  In response to concerns about the application of the  
          above provision and the creation of a super-lien with greater  
          priority than other creditors, the author offers the following  
          amendment to strike that provision as well as Section 2 of the  
          bill that relates to fines and penalties.

             Author's amendment:  

            On page 8, strike out lines 24 through 36, inclusive.
          4.   Costs of nuisance abatement procedures, schedule of costs  

          The remaining provisions of the bill relate to nuisance  
          abatement costs for homes which are either in foreclosure, or  
          that have been purchased at a foreclosure sale.  Under existing  
          law, cities and counties may establish a procedure for the  
          abatement of a nuisance. (Gov. Code Secs. 25845, 38771 et seq.)   
          If the owner fails to pay the costs of abatement, those costs  
          may be assessed against the parcel and a lien may be recorded.  

          Specifically, those two provisions would: (1) impose a  
          requirement that the cost of nuisance abatement measures  
          assessed to property owners not exceed the actual and reasonable  
          costs of abatement; and (2) require a governmental entity to  
          adopt a schedule of costs for nuisance abatement measures prior  
          to collection.  The sponsor, CAR, asserts that both of those  
          provisions are intended to ensure that the costs which are  
          assessed to property owners are not excessive and reflect the  
          actual costs of abatement.

          First, by codifying that the assessed cost of nuisance abatement  
          measures shall not exceed the actual and reasonable costs of  
          abatement, this bill would ensure the amount charged to  
          homeowners reflects the costs charged are those expended by the  
          government entity.  It also encourages those entities to not  
          incur excessive (i.e. unreasonable) costs that are then the  
          burden of a homeowner in financial distress.  Similarly,  
          requiring the governmental entity to adopt a schedule of costs  
          for nuisance abatement measures prior to collection would ensure  
          that a standard cost is set - those preset costs would ensure  
          fair, equal application of the nuisance abatement ordinance  
                                                                      



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          across all parties.  Given that nuisance abatement measures may  
          take various forms depending on the property - mowing the lawn,  
          draining the pool, boarding up the home - the sponsor should  
          continue to work with Committee staff and representatives from  
          local governments to ensure that it is feasible to create a  
          schedule of costs for those activities.

          Due to the author's amendment in Comment 3, the following  
          clarifying amendment is required to the language regarding the  
          costs of nuisance abatement, and the schedule of costs.  That  
          amendment also clarifies that the provision refers to  
          assessments or liens for those costs of abatement.

             Clarifying amendment  :

            On page 8, strike 37 through 49, inclusive, and on page 9,  
            strike out lines 1 through 2, inclusive, and insert:

            (a) An assessment or lien to recover the costs of nuisance  
            abatement measures taken by a governmental entity with regard  
            to a property that is subject to a notice of default, or that  
            has been purchased at a foreclosure sale or acquired through  
            foreclosure under a mortgage or deed of trust, shall not  
            exceed the actual and reasonable costs of nuisance abatement.
            (b) A governmental entity shall adopt a schedule of costs for  
            nuisance abatement measures described in subdivision (a) prior  
            to collection of those costs

          5.   Mockup of changes  

          For ease of the Committee, the following mockup is provided that  
          reflects the above author's amendments, suggested amendment, and  
          clarifying amendment:

          Strike out contents of bill and insert:
           
               SECTION 1.  Section 2929.4 is added to the Civil Code, to  
          read:

               2929.4.  Prior to imposing a fine or penalty for failure to  
          maintain a vacant foreclosed property that is subject to a  
          notice of default, or that has been purchased at a foreclosure  
          sale or acquired through foreclosure under a mortgage or deed of  
          trust, a governmental entity shall provide the owner of that  
          property with a notice of violation and an opportunity to  
          correct the violation. This section shall not apply if the  
                                                                      



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          entity determines that a specific condition of the property  
          threatens public health or safety.

               SEC. 2. Section 2929.45 is added to the Civil Code, to  
          read:

               2929.45.  (a) An assessment or lien to recover the costs of  
          nuisance abatement measures taken by a governmental entity with  
          regard to a property that is subject to a notice of default, or  
          that has been purchased at a foreclosure sale or acquired  
          through foreclosure under a mortgage or deed of trust, shall not  
          exceed the actual and reasonable costs of nuisance abatement.
               (b) A governmental entity shall adopt a schedule of costs  
          for nuisance abatement measures described in subdivision (a)  
          prior to collection of those costs.


           Support  :  None Known

           Opposition  :  Alliance of Californians for Community Empowerment;  
          Center for Responsible Lending

                                        HISTORY
           
           Source  :  California Association of Realtors

           Related Pending Legislation  :  None Known

           Prior Legislation  :  SB 1137 (Perata, Corbett, Machado, Ch. 69,  
          Stats. 2008), required legal owners to maintain vacant  
          residential properties that were purchased at a foreclosure  
          sale.  

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