BILL ANALYSIS                                                                                                                                                                                                    �






                             SENATE JUDICIARY COMMITTEE
                             Senator Noreen Evans, Chair
                              2011-2012 Regular Session


          SB 4 (Calderon and Vargas)
          As Amended April 7, 2011
          Hearing Date: April 26, 2011
          Fiscal: No
          Urgency: No
          BCP:jg
                    

                                        SUBJECT
                                           
                                      Mortgages

                                      DESCRIPTION  

          This bill would require, on and after April 1, 2012, that a 
          notice of non-judicial foreclosure sale contain: (1) language 
          notifying potential bidders of specified risks involved in 
          bidding on the property; and (2) a notice to the property owner 
          informing the owner about how to obtain information regarding 
          any postponement of the sale. 

          This bill would additionally require a trustee handling the 
          foreclosure to make a good faith effort to provide up-to-date 
          information regarding sale dates and postponements, as 
          specified.

                                      BACKGROUND  

          Foreclosures in California are generally non-judicial, meaning 
          that they are accomplished without court involvement.  The first 
          step in the foreclosure process is the filing of a Notice of 
          Default, which generally occurs after three or more months of 
          delinquency.  The foreclosing entity must then generally wait at 
          least three months before noticing the sale of the property, 
          which must be posted, published, and filed with the county 
          recorder.  The sale date contained in the Notice of Sale may be 
          postponed by public proclamation (given at the time and date of 
          sale) for a total of up to 365 days.  If the property is 
          actually sold at auction to the highest bidder, that bidder is 
          generally required to pay in cash or check, and takes the 
          property subject to any outstanding senior liens.
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          This bill seeks to address two different issues that have arisen 
          regarding foreclosure sales by inserting two separate 
          disclosures into the Notice of Sale.  First, this bill would 
          inform homeowners that their sale date may be postponed, give 
          them information on how to receive updated information about 
          that sale, and impose new duties on trustees consistent with 
          that disclosure.  Second, this bill would inform a bidder that 
          placing the highest bid does not automatically entitle him or 
          her to clear ownership of the property.

                                CHANGES TO EXISTING LAW
           
           Existing law  regulates the non-judicial foreclosure of 
          properties pursuant to the power of sale contained within a 
          mortgage contract.  To commence the process, existing law 
          authorizes the trustee, mortgagee, or beneficiary to record a 
          Notice of Default and generally requires three months to lapse 
          before noticing the sale of the property. (Civ. Code Secs. 2924, 
          2924f.) 

           Existing law  requires the Notice of Sale to be posted, 
          published, and filed with the county recorder at least 20 days 
          before the sale of the property. (Civ. Code Sec. 2924f.)   
            
          Existing law  governs the manner in which the sale must be 
          conducted and permits the sale to be postponed at any time prior 
          to completion of the sale.  Any postponements may not exceed a 
          total of 365 days from the date set forth in the Notice of Sale. 
           If the sale is postponed for a total of more than 365 days, the 
          sale must be re-noticed. (Civ. Code Sec. 2924g.)

           Existing law  requires notice of each postponement and the reason 
          therefore to be given by public declaration by the trustee at 
          the time and place last appointed for sale.  That declaration 
          must set forth the new date, time, and place of sale, as 
          specified.  (Civ. Code Sec. 2924g(d).)

           This bill  would, on and after April 1, 2012, require the notice 
          of sale to contain substantially the following language if the 
          property is between one and four single-family residences:

            NOTICE TO POTENTIAL BIDDERS: If you are considering bidding 
            on this property, you should understand that there are risks 
            involved in bidding at a trustee auction. Placing the 
            highest bid at a trustee auction does not automatically 
                                                                      



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            entitle you to free and clear ownership of the property. If 
            you are the highest bidder at the auction, you are or may be 
            responsible for paying off all liens senior to the lien 
            being auctioned off, before you can receive clear title to 
            the property. You should also be aware that the lien being 
            auctioned off may be a junior lien. You are encouraged to 
            investigate the existence, priority, and size of outstanding 
            liens that may exist on this property by contacting the 
            county recorder's office or a title insurance company, 
            either of which may charge you a fee for this information. 
            If you consult either of these resources, you should be 
            aware that the same lender may hold more than one mortgage 
            or deed of trust on the property.

            NOTICE TO PROPERTY OWNER: The sale date shown on this notice 
            of sale may be postponed one or more times by the mortgagee, 
            beneficiary, trustee, or a court, pursuant to Section 2924g 
            of the California Civil Code. The law requires that 
            information about trustee sale postponements be made 
            available to the public, as a courtesy to those not present 
            at the sale. If you wish to learn whether your sale date has 
            been postponed, and, if applicable, the rescheduled time and 
            date for the sale of this property, you may call �telephone 
            number for information regarding the trustee's sale] or 
            visit this Internet Web site �Internet Web site address for 
            information regarding the sale of this property], using the 
            file number assigned to this case �case file number]. 
            Information about postponements that are very short in 
            duration or that occur close in time to the scheduled sale 
            may not immediately be reflected in the telephone 
            information or on the Internet Web site. The best way to 
            verify postponement information is to attend the scheduled 
            sale.

           This bill  would provide that nothing in the above disclosures is 
          intended to modify or create substantive rights or obligations 
          for any person providing, or specified in, either of the 
          required notices.  
           
          This bill  would require the mortgagee, beneficiary, trustee, or 
          authorized agent to make a good faith effort to provide 
          up-to-date information regarding sale dates to persons who 
          request that information, and to make that information available 
          free of charge.  That information may be made available via an 
          Internet Web site, phone recording, or any other means that 
          allows 24 hour a day access, as specified; disruption of those 
                                                                      



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          methods for reasonable maintenance or due to a service outage is 
          not deemed to be a violation of the good faith standard.

           This bill  would provide that failure to comply with the above 
          provisions shall not invalidate any sale that would otherwise be 
          valid, and that the information required to be provided above 
          does not constitute the public declaration required to postpone 
          a trustee sale.

                                        COMMENT
           
          1.   Stated need for the bill  

          According to the author:

            Most residential real property foreclosures in California 
            are conducted nonjudicially, using a process set forth in 
            the Civil Code (Civil Code Sections 2924 et seq.)  Although 
            the nonjudicial foreclosure rules are very precisely 
            described in law and have been clarified many times by the 
            courts, the process can be quite confusing to the 
            uninitiated.  Two groups in particular -- homeowners who 
            have received a notice of trustee sale and individuals who 
            bid at a trustee sale, hoping to acquire a good deal on 
            residential real property - are particularly at risk, both 
            emotionally and financially, if they fail to thoroughly 
            understand the key rules that govern their situations.
            Two of the most common sources of confusion among these 
            groups involve: 1) the rules for postponing foreclosure 
            sales; and 2) the obligations of a bidder who places the 
            high bid at a foreclosure sale.
            . . .  
            SB 4 adds two informative paragraphs to the Notice of 
            Trustee Sale, a document which must be provided to 
            homeowners, filed with a county recorder, posted in a public 
            place, and published in a newspaper of general circulation, 
            before a home may be sold at foreclosure.  These informative 
            paragraphs - one intended for homeowners facing the sale of 
            their home, and the other intended for potential bidders at 
            the foreclosure sale - are designed to help alleviate some 
            of the most common sources of confusion experienced by 
            homeowners and bidders, regarding the non-judicial 
            foreclosure sale process.  

          The United Trustees Association, in support, states that their 
          members "support the bill because it provides greater 
                                                                      



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          information on the foreclosure process, which can be 
          mystifying to those not conversant with it."

          2.   Informing homeowners of the new sale date  

          For homeowners in foreclosure, the trustee sale represents the 
          conclusion of the non-judicial foreclosure process and the time 
          at which ownership of the home is officially transferred to 
          another party.  After the home is sold, the former homeowner no 
          longer has the legal right to remain in the residence and may be 
          evicted by the new owner.  The issue that arises for many 
          homeowners facing the potential sale of their home is that they 
          do not know whether the house was sold on the noticed date, or, 
          if the sale date was continued.  The homeowner does receive the 
          Notice of Sale that states the proposed date and time of the 
          sale, but that initial sale date is frequently postponed by the 
          trustee or foreclosing financial institution.  When those sales 
          are postponed, the trustee must give a public declaration of 
          postponement at the time and place at which the sale was to 
          occur, and set forth the new date, time, and place of sale.  
          Existing law does not require the Notice of Sale to be renoticed 
          (mailed to the homeowner) unless the sale has been postponed for 
          at least 365 days. 

          Since homeowners rarely attend the foreclosure sale of their 
          home and, as a result, are not aware of the public declaration, 
          the author's office notes that it is extremely common for 
          property owners to be caught by surprise when their home is sold 
          months after they receive the Notice of Sale.  For example: a 
          homeowner could have asked for a continuance of the sale date in 
          order to receive more time to complete a short sale, or the 
          financial institution could have continued the sale to ensure 
          that the necessary documents were in order before proceeding.  
          If the sale is continued multiple times, the owner could easily 
          lose track of the next sale date and, at some unknown time in 
          the future when the trustee or foreclosing institution elects 
          not to postpone the sale, the home could be sold unbeknownst to 
          the homeowner.  The author also notes that:

            Most homeowners who receive Notices of Sale in the mail are 
            unaware of the postponement rules.  If a few days pass, 
            following the sale date and time listed in their notice of 
            sale, and there is no knock on the door from someone with an 
            official-looking piece of paper, ordering them to leave 
            their home, most homeowners breathe a sigh of relief, and 
            believe that they have avoided the loss of their home.  They 
                                                                      



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            are often unaware that the date and time of their 
            foreclosure sale was merely postponed, and equally unaware 
            how they might learn when that new sale date and time have 
            been scheduled.  

          This bill seeks to address the above issues by including a 
          disclosure in the Notice of Sale that informs the homeowner 
          that: (1) the sale date may be postponed; (2) information 
          about postponements must be made available to the public; and 
          (3) the owner may call a telephone number listed in the 
          notice, or visit a specified Internet Web site, to receive 
          more information.  To help ensure that accurate information is 
          available to the homeowner, the bill would require the trustee 
          (or mortgagee, beneficiary, or authorized agent) to make a 
          good faith effort to provide up-to-date information regarding 
          sale date and postponements.  That information must be 
          available free of charge, and may be made available on an 
          Internet Web site, 24-hour telephone recording, or other means 
          that provides 24 hour a day, seven day a week no cost access 
          to the information.

          Staff notes that while the above disclosure would appear to 
          help homeowners who would otherwise be unaware of the sale 
          date of their home, the best way for a homeowner to receive 
          that information would be to attend the noticed sale.  The 
          proposed notice seeks to convey that fact to homeowners 
          clearly stating: "The best way to verify postponement 
          information is to attend the scheduled sale."

           3.   Notice to potential bidders regarding senior liens  

          For individuals who seek to buy properties at trustee sale 
          (non-judicial foreclosure) auctions, the auction offers the 
          potential for getting a good "deal" on a home, but carries 
          significant risks if the bidder has not done extensive research 
          on the property.  Although bidders may look at the home and the 
          neighborhood, it is essential for them to also do a title search 
          on the property to see if there are any senior liens that are 
          not going to be wiped out by the foreclosure sale.  (Liens 
          junior to the foreclosing lien are removed as a result of the 
          foreclosure sale, but senior liens remain intact.)  If the 
          bidder purchases a home subject to a senior lien, the bidder 
          must satisfy that senior lien or face foreclosure of their 
          interest by that lien.  The author notes that:

            Most individuals understand that they must come to an 
                                                                      



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            auction, prepared to pay cash or bring cashier's checks in 
            the full amount they bid.  However, unsophisticated bidders 
            incorrectly believe that their "winning" bid entitles them 
            to free and clear ownership of the property that is the 
            subject of the sale; these bidders are often unaware that, 
            under the law, their "winning" bid entitles them only to 
            whatever interest in the property was held by the 
            foreclosing beneficiary.  

            The implications of purchasing whatever interest in the 
            property was held by the foreclosing beneficiary are 
            particularly important, when the note being foreclosed upon 
            is junior to other recorded liens on the property.  In a few 
            recent instances, a lender foreclosed on a junior lien, and 
            an unwitting bidder purchased that junior lien at the 
            foreclosure sale, only to learn that they were now 
            responsible for satisfying the outstanding, senior lien(s) 
            on the property, before they could take clear title.  In 
            both known instances, neither "winning" bidder was able to 
            afford to pay off the outstanding senior lien(s) against the 
            property, and both ended up losing all of the money - 
            several hundred thousand dollars - that they had bid at the 
            foreclosure sale.  

          This bill seeks to warn bidders of the risks associated with 
          bidding on the property by adding a disclosure to the Notice of 
          Sale which informs the bidder that: (1) placing the highest bid 
          doesn't entitle the bidder to free and clear ownership; (2) 
          highest bidders may be responsible for paying off senior liens 
          in order to receive clear title; (3) the bidder is encouraged to 
          investigate the existence, priority, and size of outstanding 
          liens that may exist; and (4) the same lender may hold more than 
          one mortgage or deed of trust on the property.  The proposed 
          disclosures appear to be common-sense precautions that a 
          potential bidder should take before attempting to purchase a 
          property at a foreclosure sale.  From a policy standpoint, it is 
          preferable for a home to be sold at auction to an individual for 
          his or her primary residence as opposed to going back to the 
          financial institution and remaining vacant for a significant 
          period of time.  

          It should also be noted that while the pitfalls this bill seeks 
          to warn bidders of are legal, it is unfortunate that a lender 
          who holds both a first and a second mortgage would foreclose on 
          the second instead of the first - any bidder who purchases the 
          second would be on the hook to pay off a potentially significant 
                                                                      



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          lien on the property.  Essentially, that lender would receive 
          the money paid by the bidder at the sale and still have the 
          potential to take the property back, once again, by foreclosing 
          on their senior lien.  As an example of that exact situation 
          (which this bill seeks to warn potential bidders of), the San 
          Francisco Chronicle's August 2, 2010 article, Winning bid on 
          mortgage buys family heartache, reported that:

            Roberta and Randall Strand took $97,606 out of their 
            paid-off house to buy a foreclosed home at a courthouse 
            auction. Five months later, they found out they actually 
            bought the second mortgage, and that the bank planned to 
            foreclose on the first mortgage, leaving them out in the 
            cold. The family received and recorded a "trustee's deed 
            upon sale" in November 2009, shortly after the auction, 
            without realizing that they had bought a second mortgage.
            . . .
            "Apparently, unbeknownst to us, Wachovia sold us a worthless 
            second mortgage that was part of a piggyback loan made to 
            the previous owners," Roberta Strand said. "Both loans were 
            originated, signed and recorded on the same date. Rather 
            than foreclose on both loans at the same time, Wachovia 
            chose to foreclose, market and sell the worthless junior 
            lien, purporting it to be the real property, which is what 
            we purchased."

            Wells Fargo, which owns Wachovia, said in a statement: "We 
            believe the foreclosure auction of the property on which the 
            Strand family bid was done correctly, and are confident the 
            legal resolution to this matter will bear that out."


           Support  :  California Bankers Association; United Trustees 
          Association

           Opposition  :  None Known

                                        HISTORY
           
           Source  :  Author

           Related Pending Legislation  :  None Known

           Prior Legislation  :  None Known
                                          
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