BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 585
                                                                  Page  1

          Date of Hearing:   April 27, 2011

               ASSEMBLY COMMITTEE ON HOUSING AND COMMUNITY DEVELOPMENT
                                 Norma Torres, Chair
                     AB 585 (Fong) - As Amended:  April 25, 2011
          
          SUBJECT  :   Property taxation: manufactured homes: Department of 
          Housing and Community Development: information to assessor.

          SUMMARY  :   Requires the Department of Housing and Community 
          Development (HCD), by March 1, 2012, to provide a complete list 
          to each county assessor of all manufactured homes sited within 
          the county, including those manufactured homes not subject to 
          property tax that pay an in lieu fee to HCD, in a standard text 
          or comma delimited format.

           EXISTING LAW  

          1)Makes all manufactured homes and mobilehomes sold new on or 
            after July 1, 1980, subject to property tax. In addition, 
            current law allows the owner of a manufactured home or 
            mobilehome sold new prior to July 1, 1980, to elect to be 
            subject to property tax. This election, once made, is 
            permanent. (Revenue and Taxation Code Section 5801).

          2)Requires manufactured homes and mobilehomes not subject to 
            property tax to pay an annual license fee to HCD (Health and 
            Safety Code Section 18115 and 18116).


          3)Requires all manufactured homes and mobilehomes subject to 
            property tax to pay registration fees to HCD at the time of 
            original registration and upon any subsequent sale, resale, or 
            transfer of title (Health and Safety Code Section 10875.5).



          4)Requires all manufactured homes and mobilehomes not subject to 
            property tax to pay annual registration fees to HCD (Health 
            and Safety Code Section 10875.5).



          5)Requires HCD, upon the original registration of a manufactured 
            home or mobilehome, to establish a permanent title record and 








                                                                  AB 585
                                                                  Page  2

            issue a certificate of title to the legal owner and a 
            registration card to the registered owner (Health and Safety 
            Code Section 18090.5). 


          6)Requires HCD to furnish to the county assessor of the county 
            in which a manufactured home is sited, on or before the last 
            day of each calendar month, a listing of all new registrations 
            and titles to manufactured homes sited, or to be sited, in 
            that county (Revenue and Taxation Code Section 5841).

          7)Requires HCD to report twice a year, on or after January 1 and 
            on or after July 1, to the auditor of each county the address 
            of each manufactured home and mobilehome within the county for 
            which license fees were paid to HCD during the preceding 
            six-month period and the amount paid.


          8)Requires the Franchise Tax Board, the Department of Motor 
            Vehicles, the Department of Housing and Community Development, 
            and any county assessor to exchange or otherwise provide to 
            one another any information relevant to the regulations, 
            titling and taxation of manufactured homes (Revenue and 
            Taxation Code Section 5842).

           FISCAL EFFECT  :   Unknown

           COMMENTS  :   

          Most mobilehomes in California are subject to property tax. 
          Those that are not pay a license fee in lieu of property tax to 
          HCD on an annual basis. Under current law, HCD is responsible 
          for titling and maintaining title records for all mobilehomes in 
          the state. All new mobilehomes are subject to initial 
          registration with HCD, and this registration must be renewed 
          upon changes in ownership.  The registration on all mobilehomes 
          not subject to property tax must be renewed with HCD annually. 
          Because of its responsibilities relative to titling and 
          registration of mobilehomes, HCD is the only state entity with 
          access to information on all mobilehomes in the state.

          Current law requires HCD to provide monthly lists to county 
          assessors of all new registrations and titles to mobilehomes 
          sited within the county. In practice, HCD provides this 
          information twice a month. The California Assessors' Association 








                                                                  AB 585
                                                                  Page  3

          reports that in the past, HCD's bi-monthly reports were not 
          always accurate and may have omitted some new registrations or 
          titles. County assessors believe that HCD has addressed the 
          problems with its reporting and that the information they are 
          now receiving is accurate. However, because of the problems in 
          the past, assessors report that some mobilehomes that should be 
          on the local tax rolls are not. 

          AB 2526 (Fong) of 2010, sponsored by the Santa Clara County 
          Assessor, attempted to address the issue by stating the intent 
          of the Legislature to enact legislation to require owners and 
          operators of mobilehome parks to provide, upon the request of 
          the county assessors, a statement containing the decal number, 
          registered owner, situs address, and mailing address of all 
          mobilehomes located in the park. In pursuing the legislation, 
          the sponsor discovered that park owners do not necessarily have 
          this information, but HCD does. The sponsor approached HCD and 
          dropped the bill when HCD agreed to provide a one-time list to 
          each county assessor of all mobilehomes within the county, both 
          those that should be paying property tax and those that pay the 
          in lieu fee to HCD, that could be used to bring the local tax 
          roll up to date.

          When HCD provided the information to county assessors in the 
          fall of 2010, it was in PDF format. Such a format cannot be 
          imported into assessors' databases. With the provided PDF, 
          assessors would have to manually go through the list in order to 
          check it against the local tax roll. For counties in which there 
          are thousands of mobilehomes, this process would be 
          time-consuming and cumbersome. The assessors went back to HCD 
          and asked for the data to be provided in Excel or some other 
          standard text or comma delimited format, similar to the format 
          in which HCD provides the bi-monthly updates to assessors on new 
          titles and registrations, but thus far HCD has been unwilling to 
          do so.

          AB 585 would require HCD to provide each county assessor, by 
          March 1, 2012, with a list of all mobilehomes within the county, 
          both those subject to property tax and those that pay the in 
          lieu fee to HCD, in a standard text or comma delimited format 
          that can easily be imported into assessors' internal systems.  
          The list would allow assessors to cross-check the accuracy of 
          the local tax roll and make sure that all mobilehomes homes that 
          should be paying property tax are being billed. 









                                                                  AB 585
                                                                  Page  4

          The California Assessors' Association, the sponsor of this bill, 
          argues that assessors need a full listing of mobilehomes that 
          should be on the county tax roll and that HCD is the only entity 
          that has the information.  According to the assessors, erroneous 
          information has caused escape assessments resulting in undue 
          hardship to taxpayers who may have to pay several years of back 
          taxes once errors are discovered.  In addition, if errors are 
          discovered after the statute of limitations has passed, revenue 
          that is critical to schools and local governments is lost. 

           Double referred  : The Assembly Committee on Rules referred AB 585 
          to the Committee on Housing and Community Development and 
          Revenue and Taxation.  If AB 585 passes this committee, the bill 
          must be referred to the Committee on Revenue and Taxation.
           
          REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          California Assessors' Association (sponsor)
          Santa Clara County Assessor
          Western Manufactured Housing Communities Association

           Opposition 
           
          None on file
           
          Analysis Prepared by  :    Anya Lawler / H. & C.D. / (916) 
          319-2085