BILL ANALYSIS                                                                                                                                                                                                    �



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          CONCURRENCE IN SENATE AMENDMENTS
          AB 1151 (Feuer and Blumenfield)
          As Amended July 12, 2011
          Majority vote 
           
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          |ASSEMBLY:  |79-0 |(May 31, 2011)  |SENATE: |38-0 |(August 31,    |
          |           |     |                |        |     |2011)          |
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           Original Committee Reference:    P.E.,R. & S.S.  

           SUMMARY  :  Amends the California Public Divest from Iran Act 
          (Act) to clarify that pension boards must divest pension funds, 
          as specified, unless to do so would fail to satisfy a fiduciary 
          responsibility; modify the types of companies that fall within 
          the scope of the bill; and, require that certain findings and 
          determinations must be made in noticed public hearings.  
          Specifically,  this bill  :  

          1)Provides that the boards of California Public Employees' 
            Retirement System (CalPERS) and California State Teachers' 
            Retirement System (CalSTRS) (boards) shall not invest public 
            employee retirement funds in a company which has specified 
            business operations in Iran, as identified by the boards 
            through publicly available information, if the company meets 
            either of the following criteria:

             a)   The company is invested in or engaged in business 
               operations with entities in the defense or nuclear sectors 
               of Iran, or has an investment of $20 million or more in the 
               energy sector of Iran, including a company that provides 
               oil or liquefied natural gas tankers, or products used to 
               construct or maintain pipelines used to transport oil or 
               liquefied natural gas, for the energy sector of Iran, and 
               that company is subject to sanctions under relevant federal 
               law; or, 

             b)   The company has demonstrated complicity with an Iranian 
               organization that has been labeled as a terrorist 
               organization by the United States (U.S.) government. 

          2)Requires the boards to annually review their investment 
            portfolios based on publicly available information.
             








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          3)Requires that the boards' determination as to whether a 
            company is subject to, or remains subject to, divestment be 
            based on credible information available to the public and 
            supported by findings adopted by a roll call vote in open 
            session during a properly noticed public hearing of the full 
            board.  Requires further that all proposed findings of the 
            boards shall be made public 72 hours before they are 
            considered by the full board, and the boards shall maintain a 
            list of interest parties who shall be notified. 

          4)Provides that if a company fails to take substantial action, 
            as defined, within one year, then the boards shall not make 
            additional, or renew, investments in that company, and, 
            thereafter, the boards shall liquidate investments in this 
            company within 18 months in a manner consistent with its 
            fiduciary responsibilities. 

          5)Specifies that nothing in this bill would require the boards 
            to take an action pursuant to the above provisions if the 
            boards determine, in good faith and based on credible 
            information available to the public, that an action would fail 
            to satisfy the fiduciary responsibilities of the board as 
            described in the California constitution.  However, any 
            determination that an action would fail to satisfy fiduciary 
            responsibilities shall be made in a public hearing of the full 
            board that is properly noticed and offers an opportunity for 
            public comment, as specified.

          6)Eliminates existing exemptions from the Act for companies 
            engaged in certain humanitarian, educational, religious, 
            journalistic, or welfare activities. 

           The Senate amendments  change the phrase "breach of fiduciary 
          duty" to "fail to satisfy the fiduciary responsibilities," in 
          order to maintain consistency with the relevant constitutional 
          language. 
           
          AS PASSED BY THE ASSEMBLY  , this bill was substantially similar 
          to the version approved by the Senate.
           
          FISCAL EFFECT  :  According to the Senate Appropriations 
          Committee, according to CalSTRS, the changes being proposed to 
          the California Public Divest from Iran Act would not 
          significantly affect the pension system, and would not adversely 
          impact the board's fiduciary duties or responsibilities.  There 








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          would be an increase in administrative requirements for 
          compliance, however, those costs would be minor.  CalPERS 
          indicates that they incurred costs of $550,000 to comply with 
          the monitoring requirements in the initial implementing 
          legislation (AB 221 (Anderson), Chapter 671, Statutes of 2007), 
          and that the system would incur unknown, additional expenses 
          beyond those initial costs for implementation of this bill.
           
          COMMENTS  :  Existing law prohibits the boards of CalPERS and 
          CalSTRS (boards) from making new investments in companies that 
          do business in Iran's energy sector and generally requires the 
          boards to liquidate existing investments in such companies.  
          This bill seeks to clarify that these actions are required 
          unless doing so would fail to satisfy of the boards' 
          constitutionally-mandated fiduciary responsibilities.  In 
          addition, this bill would require that certain board 
          determinations be adopted by a roll call vote at a noticed 
          public hearing.  

          AB 221 (Anderson) Chapter 671, Statutes of 2007, enacts the 
          California Public Divest from Iran Act.  This legislation 
          prohibits the boards from investing public employee retirement 
          funds in companies that have specified energy- or 
          defense-related operations in Iran.  In addition, AB 221 
          required the boards to independently review publicly available 
          information regarding companies with business operations in Iran 
          and, based on that review, to notify such companies that they 
          must take "substantial action" to reduce or eliminate 
          investments in Iran or face the prospect of withdrawal of public 
          pension funds.  If the company fails to satisfactorily take 
          substantial action within a year, then the boards are required 
          to liquidate investments in that company within 18 months.  

          Existing law, however, contains a significant loophole:  it 
          specifies that CalPERS and CalSTRS are only required to divest 
          funds to the extent that it is "consistent" with their fiduciary 
          responsibilities.  The authors of this bill point to recent 
          legislative oversight hearings which found that CalPERS has 
          "increased investments in several energy companies doing 
          business in Iran, while decreasing investments in other energy 
          companies which do not do business in Iran."  Arguably, one of 
          the reasons CalPERS has not been as successful in achieving 
          divestment as one might hope is a byproduct of the somewhat 
          vague standard that requires divestment only if doing so is 
          "consistent" with a board's fiduciary responsibilities.  It is 








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          not clear what "consistent" means in this context, and the word 
          "consistent" has no meaning in case law defining the scope of 
          fiduciary duties.  For example, would an action be 
          "inconsistent" with fiduciary responsibilities only if it rose 
          to the level to a "breach" of fiduciary responsibility, or is 
          something less than a legal breach "inconsistent" with that 
          responsibility?  

          In order to clarify this issue, this bill would clearly state 
          that a board is required to take a divestment action unless to 
          do would breach or otherwise fail to satisfy a fiduciary 
          responsibility.  In addition, this bill seeks to increase 
          greater accountability and transparency by requiring that 
          certain board findings and determinations be adopted at a 
          noticed public hearing.  Specifically, existing law requires the 
          boards to request that a notified company take "substantial 
          action," as specified, toward curtailing business in Iran and 
          requires the boards to determine a company's compliance at 
          90-day intervals.  This bill would require that the 
          determinations be based on credible information available to the 
          public and be adopted by a roll call vote at a properly noticed 
          public hearing of the full board.  In addition, this bill would 
          require that any determination that an action would fail to 
          satisfy a fiduciary responsibility similarly be adopted by a 
          roll call of the full board following a presentation and 
          discussion of findings in an open session, during a properly 
          noticed public hearing. 

          According to the authors, even though existing law requires 
          California public pension funds to divest from companies doing 
          business with Iran, "CalPERS continues to invest in companies 
          with interests in Iran and has failed to satisfactorily comply 
          with statutorily mandated reporting requirements to the 
          Legislature."  In support of this position, the authors point to 
          a 2010 legislative oversight hearing showing that CalPERS has 
          "increased investments in several energy companies doing 
          business in Iran, while decreasing investments in other energy 
          companies that do not do business with Iran."  In addition, the 
          authors contend that CalPERS required report to the Legislature 
          failed to adequately explain why CalPERS continues to invest in 
          companies that do business with Iran.  
           

          Analysis Prepared by :    Thomas Clark / JUD. / (916) 319-2334 









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