BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  SB 903
                                                                  Page  1

          Date of Hearing:   June 22, 2011

            ASSEMBLY COMMITTEE ON PUBLIC EMPLOYEES, RETIREMENT AND SOCIAL 
                                      SECURITY
                              Warren T. Furutani, Chair
                SB 903 (Anderson) - As Introduced:  February 18, 2011

           SENATE VOTE  :   39-0
           
          SUBJECT  :   Public retirement systems: investments: Iran.

           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 be a breach of fiduciary 
          duty and requires that this determination be made in a properly 
          noticed public hearing of the full board with an opportunity for 
          public comment.  

           EXISTING LAW  :

          1)Pursuant to the State Constitution, as amended by Proposition 
            162 (The California Pension Protection Act of 1972), provides 
            that the boards of administration of California's public 
            retirement system have "plenary authority and fiduciary 
            responsibility for investment of monies and administration of 
            the system."

          2)Pursuant to the State Constitution, as amended by Proposition 
            162, which added Constitutional language providing that the 
            Legislature also retained its authority to prohibit certain 
            investments by a retirement board where it is in the public 
            interest to do so, and provided that the prohibition satisfies 
            the standards of fiduciary care and loyalty required of a 
            retirement board pursuant to this section."

          3)Provides, pursuant to the State Constitution, that "the 
            members of the retirement board of a public pension or 
            retirement system shall discharge their duties with respect to 
            the system solely in the interest of, and for the exclusive 
            purpose of providing benefits to, participants and their 
            beneficiaries, minimizing employer contributions thereto, and 
            defraying reasonable expenses of administering the system."

          4)Provides, pursuant to the Bagley-Keen Open Meeting Act, that 
            nothing in the Act shall be construed to prevent a state body 








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            that invests retirement, pension, or endowment funds from 
            holding closed sessions when considering investment decisions.

          5)Establishes the California Public Divest from Iran Act (Act), 
            created by AB 221 (Anderson), Chapter 671, Statutes of 2007, 
            which prohibits the boards of the California Public Employees' 
            Retirement System (CalPERS) and the California Teachers' 
            Retirement System (CalSTRS) from investing public employee 
            retirement funds in companies with business operations in the 
            defense or nuclear sector of Iran, or that are involved in the 
            development of Iranian petroleum or natural gas resources and 
            are subject to specified federal sanctions.

          6)Requires the CalPERS and CalSTRS boards to sell or transfer 
            any assets in a company with business operations in Iran until 
            the federal government removes Iran from its list of countries 
            determined to provide supports for acts of terrorism, and the 
            President determines and certifies that Iran has ceased 
            specified efforts regarding nuclear materials and 
            technologies.

          7)Does not require the boards of CalPERS and CalSTRS to divest 
            investments and take other prescribed actions, as specified, 
            unless they determine in good faith that the action is 
            consistent with their fiduciary duties.

           FISCAL EFFECT  :   Unknown.

           COMMENTS  :   According to information provided to the Committee 
          by CalPERS, the federal government recently enacted the 
          Comprehensive Iran Sanctions, Accountability, and Divestment Act 
          of 2010, to strengthen existing federal law imposing sanctions 
          on Iran by generally tightening investment thresholds and 
          definitions.  The act also tightens export prohibitions to 
          countries that are deemed to be diversion points for 
          weapons-related technology being sold to Iran.  It further 
          shields certified investment companies, and their executives, 
          from civil, criminal, or administrative action resulting from a 
          decision to divest in Iran's energy sector.  Finally, the act 
          expresses the sense of Congress that it is not a breach of 
          fiduciary responsibility for a pension plan, governed by the 
          Employee Retirement Income Security Act of 1974 (ERISA), to 
          divest from Iran's energy sector, if the divestment 
          determination 1) is reached using credible, publically available 
          information, and 2) does not provide a lower rate of return or 








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          provide a higher rate of risk.  However, these safe harbor and 
          fiduciary responsibility provisions do not apply to CalPERS or 
          CalSTRS since neither are governed by ERISA.

          As the act relates to Iran divestment, it authorizes state and 
          local governments to divest their assets in companies with more 
          than $20 million invested in the Iranian energy sector, which is 
          intended to prevent legal challenges based on federal 
          preemption.

          According to the author, "In recent legislative oversight 
          hearing in 2010, and in the annual reports issued by CalPERS and 
          CalSTRS, the divestment process required by law lacks adequate 
          accountability and transparency in the decision-making process 
          to - contrary to the clear and undeniable intent of the law, and 
          expressed will of the Legislature - still remain invested in the 
          Islamic Republic of Iran."

          Supporters state, "SB 903 would require CalPERS and CalSTRS to 
          establish a transparent and effective process for determining 
          whether companies with which it invests have complied with 
          California law mandating divestment from the energy and military 
          sectors of Iran.  It is critical, now more than ever, that we 
          support and strengthen our commitment made with the passage of 
          AB 221 several year ago to force the government of Iran to stop 
          sponsoring state terrorism, attacking its own people - including 
          vicious attacks on trade unionists - and developing nuclear 
          weapons." 

          CalPERS states they have fully implemented the Act from the time 
          it became effective on January 1, 2008.  "CalPERS has submitted 
          each report to the Legislature on time with all the required 
          information.  In addition, CalPERS Board Members and staff have 
          testified on numerous occasions to provide updates and 
          information to the Legislature.  CalPERS' 2010 Report on Iran 
          Divestment describes its implementation of the Act during the 
          year, including the active engagement of companies as required 
          by the Act, and the significant number of portfolio companies 
          curtailing their activities in Iran or withdrawing from Iran.  
          It noted that companies' withdrawal from Iran accelerated 
          through the imposition of economic sanctions on Iran by the 
          United Nations, the European Union, Japan, South Korea, and the 
          United States.  Examples of major multinationals which withdrew 
          from Iran in 2010 include Royal Dutch Shell, which announced 
          that it has agreed to terminate its investments and avoid any 








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          new activity in Iran's energy sector in full compliance with the 
          newly expanded U.S. legislation.  Likewise, France's Total SA, 
          Norway's Statoil ASA, Brasil's Petrobras and Italy's Eni Spa 
          have also agreed to end all investments in Iran.  CalPERS has 
          been calling for withdrawal by these companies since the 
          inception of the Act, and has actively engaged their senior 
          management and boards through correspondence and in person 
          meetings.

          "The Report also noted that withdrawals by these major 
          multinational corporations reduced the value of CalPERS 
          portfolio holdings in companies subject to the Act from $2 
          billion to approximately $300 million, prompting CalPERS to 
          commission a new fiduciary analysis to establish the impact of 
          potential divestment on the portfolio, while it continues to 
          identify companies potentially subject to the Act, to notify 
          them of the law's provisions, and call for their taking of 
          substantial action or withdrawal from Iran.  

          "In May 2011, the Board decided to divest from remaining 
          companies doing business in Iran and Sudan. This action could 
          only be taken as the fiduciary analysis shows there will be no 
          impact on portfolio risk and minimal trading costs, which will 
          be offset by modifying compliance activities.  CalPERS will 
          continue to identify, monitor and rigorously engage companies in 
          its portfolio and review their status under the Act."

          CalPERS is opposed to the bill, stating, "CalPERS must protect 
          its right to discuss investment decisions in closed session.  If 
          analyses regarding due diligence and investment strategy were to 
          be made in open session, there could be immediate, unintended 
          consequences in the public and private markets.  Due to this 
          possible negative market impact, it is imperative that CalPERS 
          retain the ability to analyze and make investment decisions in 
          closed session."

          According to CalSTRS, they recently had 29 investments 
          identified as having ties to Iran.  "Only seven of those 
          companies were subject to the restrictions under the Act, and 
          CalSTRS has divested all seven from its portfolio.  CalSTRS 
          identified 19 companies having ties to Iran that do not meet the 
          requirements for divestment.  The remaining three companies were 
          reviewed to determine if they met the criteria for divestment, 
          and two were determined to have not met the criteria, while one 
          continued to be undetermined.  CalSTRS continues its engagement 








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          activities with the remaining undetermined company and plans to 
          meet with the company's management this year.  While the status 
          of this company is being determined, CalSTRS has restricted any 
          further investment.

          "CalSTRS continues to monitor and engage companies identified as 
          having ties to Iran and report annually to the Legislature as 
          mandated by the California Public Divest from Iran Act. To date, 
          CalSTRS has not made a determination that taking action as 
          specified in Chapter 671 (the Act) would be in conflict or be a 
          breach of its fiduciary duty.

          CalSTRS is opposed to the bill stating, "This measure would 
          require that any determination that an action would be a breach 
          of fiduciary duty be made in a public hearing of the full board 
          after proper public notice and an opportunity for public 
          comment.  The public hearing requirement runs counter to the 
          Bagley-Keene Open Meeting Act, as the consideration of whether 
          or not a potential decision violated the board's fiduciary duty 
          under current law would be conducted in closed session. 
          Specifically, it is in conflict with Government Code Section 
          11126 that authorizes a state body that invests retirement, 
          pension, or endowment funds to consider investment decisions in 
          closed sessions.

          "If the board were to debate the fiduciary responsibility of a 
          specific investment in open session with the required notice 
          period, the investment would be exposed to a potentially 
          negative market impact, which could result in losses for the 
          Teachers' Retirement Fund. This action would not serve to 
          maximize the investment and would run counter to the board's 
          fiduciary responsibility of maximizing the income for the fund."

          This bill is similar to AB 1151 (Feuer and Blumenfield), of this 
          year, that amends the Act to, among other things, clarify that 
          pension boards must divest pension funds, as specified, unless 
          to do so would breach a fiduciary duty; 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.

           REGISTERED SUPPORT / OPPOSITION  :

           Support 
           








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          AMVETS, Department of California
          Anti-Defamation League
          California Conference of Machinists
          California State Commanders Veterans Council
          California Teamsters Public Affairs Council
          Jewish Public Affairs Committee
          Military Officers Association of America, California Council of 
          Chapters
           
            Opposition 
           
          California Public Employees' Retirement System

           Analysis Prepared by  :    Karon Green / P.E., R. & S.S. / (916) 
          319-3957