BILL ANALYSIS                                                                                                                                                                                                    �



                                                                      



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          |SENATE RULES COMMITTEE            |                  AB 1216|
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                                 THIRD READING


          Bill No:  AB 1216
          Author:   Fuentes (D)
          Amended:  6/22/11 in Senate
          Vote:     21

           
           SENATE TRANSPORTATION & HOUSING COMMITTEE  :  5-3, 6/14/11
          AYES:  DeSaulnier, Kehoe, Lowenthal, Pavley, Simitian
          NOES:  Gaines, Harman, Huff
          NO VOTE RECORDED:  Rubio
           
          ASSEMBLY FLOOR  :  50-27, 5/19/11 - See last page for vote


           SUBJECT  :    Preservation of existing affordable housing

           SOURCE  :     California Rural Legal Assistance Foundation


           DIGEST :    This bill allows tenants who live in affected 
          affordable housing units, the Department of Housing and 
          Community Development, the local public housing authority, 
          and the city or county in which the development is located 
          to bring an action in court to enforce the preservation 
          right-of-first refusal law.  

           ANALYSIS  :    Since the 1960s, developers have constructed 
          at least 425,000 units of affordable rental housing in 
          California with the assistance of federal, state, and local 
          subsidies that require owners to maintain rents at 
          affordable levels for a specified period of time.  Examples 
          of such subsidies include project-based Section 8, Federal 
          Housing Administration mortgages, low-income housing tax 
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          credits, state loans and grants, and city and county 
          redevelopment funds.  The affordability restrictions on 
          assisted units typically last 30-55 years, depending on the 
          program.  

          Once affordability obligations expire, owners may preserve 
          the affordability of the units by renewing assistance or by 
          refinancing with new public subsidies, or they may convert 
          the development to market rate.  Under some federal 
          programs, owners can also terminate affordability 
          restrictions early by prepaying the underlying mortgage or 
          opting out of the rental assistance contract.  According to 
          the state-chartered California Housing Partnership 
          Corporation, California has already lost more than 20,000 
          units of housing affordable to low-income households to 
          market rate conversions, and 82,000 more units are 
          considered "at risk" of conversion in the next five years.  


          In order to "preserve" the long-term affordability of these 
          at-risk units, current law prohibits a property owner from 
          converting an affordable property to market rate without 
          first providing notice to tenants, local and state 
          governments, and potential preservation purchasers (i.e., 
          those who may wish to purchase the development in order to 
          preserve the affordability restrictions) at least one year 
          in advance.  

          In addition, during this one-year notice period, current 
          law also provides preservation purchasers with limited 
          priority to purchase the property if the owner is inclined 
          to sell.  This is known as the "preservation right-of-first 
          refusal law."  Prior to or concurrent with the delivery of 
          the 12-month notice described above, the owner must notify 
          prospective preservation purchasers who have contacted the 
          owner directly or who are on a list maintained by the 
          Department of Housing and Community Development (HCD) of 
          the opportunity to submit a purchase offer.  The owner is 
          not required to accept any offer but may only accept offers 
          from preservation purchasers for 180 days after the 
          purchase offer notice.  If the owner rejects a purchase 
          offer during this time, the owner must give the 
          preservation purchaser who made the offer an opportunity to 
          match and preempt any offer from a non-preservation 

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          purchaser accepted during the second 180 days after the 
          purchase offer notice.  These requirements and priorities 
          also apply if an owner seeks to sell or otherwise dispose 
          of a property that is eligible for conversion in the next 
          five years.  

          In general, an owner is exempt from both the notice and 
          preservation right-of-first refusal laws if he/she or a 
          successor owner agrees to retain existing tenants and 
          extend the affordability of the units for at least 30 
          years.  If an owner ultimately sells to a non-preservation 
          purchaser, he/she must certify under penalty of perjury 
          that he/she has complied with the notice and preservation 
          right-of-first refusal laws.

          If an owner fails to comply with the notice law, tenants 
          who live in affected affordable housing units, HCD, the 
          local public housing authority, and the city or county in 
          which the development is located may bring an enforcement 
          action.  If an owner fails to comply with the preservation 
          right-of-first refusal law, only a preservation purchaser 
          may enforce the law.  

          This bill allows tenants who live in affected affordable 
          housing units, HCD, the local public housing authority, and 
          the city or county in which the development is located to 
          bring an action in court to enforce the preservation 
          right-of-first refusal law.  In addition, this bill 
          provides that a seller's failure to record the 
          certification of compliance shall not affect the rights of 
          a purchaser or encumbrancer who acts in good faith and is 
          unaware of the violation.  Lastly, this bill clarifies the 
          definition of "termination" as it applies to the 
          right-of-first refusal law to mean an owner's "failure to 
          extend or renew its participation" in a federal, state, or 
          local government subsidy program rather than an owners 
          "decision not to extend or renew its participation."  

           Comments
           
          The conversion of affordable housing units to market rate 
          increases rents and displaces low-income families.  State 
          law aims to prevent the loss of affordable units with the 
          notice and preservation right-of-first refusal laws.  If an 

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          owner fails to provide the notice, however, there is little 
          chance to prevent these units from converting to market 
          rate.   The entities that currently have the right to 
          enforce the provisions, primarily affordable housing 
          developers, have little way of knowing that they had the 
          right to make a purchase offer for an assisted housing 
          development if they never received the notice from the 
          owner.  Even if they do become aware that an owner has 
          failed to follow the law, they may be reluctant to sue for 
          fear of alienating the owner with whom they are trying to 
          negotiate the purchase of the property.  Expanding 
          enforcement authority to include affected tenants as well 
          as affected public agencies is a way to ensure greater 
          compliance with the right-of-first-refusal law and, 
          ultimately, the preservation of precious affordable 
          housing.

           Previous Legislation
           
          AB 2019 (Fuentes), Session of 2007-08, contained similar 
          provisions to this bill.  Governor Schwarzenegger vetoed AB 
          2019 with the following 
          message:

            "This bill would give tenants the ability to initiate 
            legal action against an owner of publicly subsidized, 
            rent-restricted, or assisted housing if the owner fails 
            to provide the proper legal notice when the owner decides 
            to remove the property from the subsidized housing 
            market.

            "This measure, while well intentioned, attempts to 
            achieve this goal by expanding the number of individuals 
            who have standing to initiate legal action and enforce 
            current notification requirements.  This could increase 
            overall litigation throughout the state.  In addition, 
            owners, who may have simply been unaware of the 
            notification requirements, may face excessive and 
            unnecessary delays or court cost prior to the sale or 
            transfer of their property.  These types of delays and 
            burdens could discourage potential buyers of the 
            affordable housing development and increase the chances 
            that individuals who own, or are considering the purchase 
            of, affordable housing units will choose not to enter the 

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            market."

           FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  No   
          Local:  No

           SUPPORT  :   (Verified  6/22/11)

          California Rural Legal Assistance Foundation (source)
          City of Santa Monica
          Western Center on Law and Poverty

           
          ASSEMBLY FLOOR  :  50-27, 5/19/11
          AYES:  Allen, Ammiano, Atkins, Beall, Block, Blumenfield, 
            Bonilla, Bradford, Brownley, Buchanan, Butler, Charles 
            Calderon, Campos, Carter, Cedillo, Chesbro, Davis, 
            Dickinson, Eng, Feuer, Fong, Fuentes, Furutani, Galgiani, 
            Gatto, Gordon, Hall, Hayashi, Roger Hern�ndez, Hill, 
            Huber, Hueso, Huffman, Lara, Bonnie Lowenthal, Mendoza, 
            Mitchell, Monning, Pan, Perea, V. Manuel P�rez, 
            Portantino, Skinner, Solorio, Swanson, Torres, 
            Wieckowski, Williams, Yamada, John A. P�rez
          NOES:  Achadjian, Bill Berryhill, Conway, Cook, Donnelly, 
            Fletcher, Beth Gaines, Garrick, Grove, Hagman, Halderman, 
            Harkey, Jeffries, Jones, Knight, Logue, Mansoor, Miller, 
            Morrell, Nestande, Nielsen, Norby, Olsen, Silva, Smyth, 
            Valadao, Wagner
          NO VOTE RECORDED:  Alejo, Gorell, Ma


          JJA:kc  6/22/11   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE

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