BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 2026
                                                                  Page 1

          Date of Hearing:   April 30, 2014

               ASSEMBLY COMMITTEE ON HOUSING AND COMMUNITY DEVELOPMENT
                                   Ed Chau, Chair
                    AB 2026 (Stone) - As Amended:  April 21, 2014
           
          SUBJECT  :   Mobilehome parks: sales.

           SUMMARY  :   Creates a standard that mobilehome park owners must  
          use in determining a prospective mobilehome purchaser's  
          financial ability to pay the rent and park charges and the  
          likelihood a purchaser will comply with park rules and  
          regulations.  Specifically,  this bill  :  

             1)   Requires that, upon request of a prospective purchaser  
               of a mobilehome that will remain in the park, management  
               must provide a list of the information it requires in order  
               to determine if the person will be acceptable as a  
               homeowner in the park, together with a copy of the current  
               written procedures, standards or requirements that  
               management will use to evaluate the purchaser's  
               application.

             2)   Requires that, for purposes of approving a mobilehome  
               purchaser, a purchaser is presumed to have the financial  
               ability to pay the rent and park charges if he or she has  
               been approved by a state or federally chartered financial  
               institution for a loan to purchase the mobilehome that the  
               purchaser intends to occupy, and written documentation of  
               this approval has been provided to park management.

             3)   Provides that, where the purchaser has not been approved  
               for a loan to purchase the mobilehome, management must  
               determine the purchaser's financial ability to pay the rent  
               and charges of the park based upon consideration of all  
               asset and income producing information provided by the  
               purchaser.   

             4)   Provides that management's income standard for a  
               prospective purchaser must not exceed a multiplier of three  
               times the purchaser's income over the projected  
               housing-related expenses of the proposed mobilehome  
               tenancy.

             5)   Provides that a purchaser who demonstrates sufficient  








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               monthly income from all sources that meets or exceeds the  
               income standard disclosed by management is presumed to have  
               the financial ability to pay the rent and charges of the  
               park.

             6)   Prohibits park management from withholding approval of a  
               purchaser on the basis that the purchaser will not comply  
               with the rules and regulations of the park unless  
               management provides the purchaser with documentary evidence  
               that the purchaser has failed to comply with the rules and  
               regulations during a previous tenancy within the three  
               years preceding the application for tenancy.

             7)   Prohibits park management from withholding approval of a  
               mobilehome purchaser solely because the purchaser owns  
               another mobilehome or real property residence, and  
               prohibits management from requiring that the mobilehome be  
               the sole residence of the purchaser.

             8)   Clarifies that, if a purchaser's application is denied,  
               management must notify the purchaser in writing of the  
               specific reason or reasons for the denial.

             9)   Provides that, if a purchaser's application is denied,  
               the selling homeowner and the purchaser may, within five  
               business days of receiving the denial, request an in-person  
               meeting with management.  This meeting must take place  
               within ten days, at which time management must reconsider  
               its denial based upon any additional information the  
               purchaser provides.

             10)  Provides that, if the approval of a purchaser is  
               withheld for any unauthorized reason, the management or  
               owner may be held liable for all damages to both the  
               selling homeowner and the prospective purchaser proximately  
               resulting therefrom.

             11)  Provides that, if a mobilehome that will remain in the  
               park is transferred or sold, management may only require  
               repairs or improvements to the exterior of the mobilehome  
               as determined following an inspection by the appropriate  
               enforcement agency.

           EXISTING LAW:  









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             1)   Regulates, pursuant to the Mobilehome Residency Law  
               (MRL), the rights, responsibilities, obligations, and  
               relationships between mobilehome park management and park  
               residents.  (Civil Code Section 789, et seq.)

             2)   Provides that the management of a mobilehome park may  
               require prior approval of a purchaser of a mobilehome that  
               will remain in the park.  (Civil Code Section 798.74)

             3)   Provides that management cannot withhold approval of a  
               purchaser's application for residency if the purchaser has  
               the financial ability to pay the rent and charges of the  
               park, unless management reasonably determines that the  
               purchaser, based on his or her prior tenancies, will not  
               comply with the rules and regulations of the park.  (Civil  
               Code Section 798.74)

             4)   Authorizes management to require the purchaser to  
               document the amount and source of his or her gross monthly  
               income or other means of support, but prohibits management  
               from requiring personal income tax returns in order to  
               obtain approval for residency in the park.  (Civil Code  
               Section 798.74)

             5)   Provides that a park management or owner may be held  
               liable for all damages if the approval of a prospective  
               purchaser is withheld for any unauthorized reason.  (Civil  
               Code Section 798.74)

             6)   Provides that, in the case of a sale or transfer of a  
               mobilehome that will remain in the park, management may  
               require repairs or improvements to the exterior of the  
               mobilehome if they are based upon or required by a local  
               ordinance or state statute or regulation, or a rule or  
               regulation of the mobilehome park implementing such a law.   
               (Civil Code Section 798.73.5)

             7)   Exempts any mobilehome that is not the principal  
               residence of the homeowner and that has not been rented to  
               another party from rent control.  (Civil Code Section  
               798.21)

             8)   Specifies that a mobilehome is considered the homeowners  
               principal residence unless the homeowner is receiving a  
               homeowner's exemption for another property or mobilehome in  








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               California, or unless a review of public records reasonably  
               demonstrates that the principal residence of the homeowner  
               is out of state.  (Civil Code Section 798.21)

           FISCAL EFFECT  :   Unknown

           COMMENTS  :   

          More than 700,000 people live in California's approximately  
          4,700 mobilehome parks. The cost to move a mobilehome ranges  
          from $2,000 to upwards of $20,000 depending on the size of the  
          home and the distance traveled.  A mobilehome owner whose home  
          is located in a mobilehome park does not own the land the unit  
          sits on, and he or she must pay rent and fees for the land and  
          any community spaces.  In order to sell a mobilehome located in  
          a park, potential buyers must be approved by park management.  
          Homeowners trying to sell their home are therefore reliant on  
          park management to approve the buyer so that the sale can be  
          completed. 

           Purpose of the bill:
           
          According to the author, park management is not limited in the  
          number of potential buyers they can reject, which places  
          pressure on homeowners to find a buyer that qualifies under the  
          standards set in place by management. The author explains that  
          "most standards are not set or regulated by the state and can  
          vary widely from park to park.  As a result, responsible and  
          trustworthy potential buyers can be unfairly turned away." This  
          bill "seeks to protect home owners from unreasonable standards  
          set by mobilehome park owners" by standardizing certain aspects  
          of the approval process for a potential buyer, including  
          defining the phrase "financial ability to pay."

           Mobilehome parks' right of prior approval:
           
          There is a delicate balance between a mobilehome park's interest  
          in who resides in the park and a homeowner's right to sell his  
          or her own property.  Mobilehomes are not truly mobile, in that  
          it is often cost prohibitive to relocate them.  Selling a  
          mobilehome is a three-party transaction, as the park owns the  
          land under the mobilehome and has an interest in who will  
          purchase the home and live in the park.  If a park resident is  
          unable to find a purchaser that meets the park's requirements,  
          that resident most often either sells the home to the park owner  








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          at below fair market rates or incurs the high expense of moving  
          the home to another park.  

          Existing law authorizes parks to require the right of prior  
          approval of a purchaser of a mobilehome that will remain in the  
          park.  Approval may be withheld if management determines that  
          the purchaser does not have the financial ability to pay the  
          rent and charges of the park, or if management reasonably  
          determines, based on the purchaser's prior tenancies, that he or  
          she will not comply with the park's rules and regulations.  AB  
          2026 clarifies and standardizes the framework for management's  
          right of prior approval of a purchaser, making the process more  
          predictable for buyers and sellers.  
            
           A purchaser's financial ability to pay rent and park charges:
           
          AB 2026 requires that, upon request of any prospective homeowner  
          that will remain in the park, management must provide a list of  
          the information they will require to determine if the person  
          will be acceptable as a homeowner in the park.  Any income  
          standard set by the park cannot exceed a multiplier of three  
          times the purchaser's income over the projected housing-related  
          expenses in connection with the proposed tenancy.  Management  
          must consider all income and asset information provided by the  
          purchaser in considering his or her financial ability to pay.

          This bill also shifts the burden, in two specific circumstances,  
          to the park to demonstrate why a purchaser does not financially  
          qualify to live in the park.  First, it creates a presumption of  
          a purchaser's financial ability to pay if the purchaser provides  
          documentation that he or she has been approved by a state or  
          federally chartered financial institution for a loan to purchase  
          the mobilehome that the purchaser intends to occupy. Second,  in  
          the event that a purchaser has not been approved for a loan to  
          purchase a mobilehome, a purchaser who demonstrates sufficient  
          monthly income from all sources that meets or exceeds the park's  
          income standard is presumed to have the financial ability to pay  
          the rent and charges of the park.  However, these presumptions  
          do not mandate that a park accept a purchaser that meets these  
          specifications.  Rather, it shifts the burden to the park to  
          demonstrate why the purchaser does not financially qualify.   
          Management is still authorized to require the purchaser to  
          document the amount and source of his or her gross monthly  
          income or other means of support. 
          








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           A purchaser's compliance with rules and regulations of the park:
           
          Under existing law, management may deny a purchaser's  
          application if it reasonably determines, based on the  
          purchaser's prior tenancies, that he or she will not comply with  
          the park's rules and regulations.  AB 2026 narrows this  
          provision by prohibiting park management from withholding  
          approval of a mobilehome purchaser on the basis unless  
          management provides the purchaser with documentary evidence that  
          the purchaser has failed to comply with the rules and  
          regulations during a previous tenancy within the three years  
          preceding the purchaser's application for tenancy.

          While the intent behind this section is to standardize the  
          application process and provide a needed level of  
          predictability, it does not address the scenario where a park  
          may already be familiar with a prospective purchaser's previous  
          tenancies due to a prior eviction from the park.  The Committee  
          may wish to take an amendment, stated below in the Committee  
          amendments section, providing that a park may deny a purchaser  
          on this basis if he or she has been evicted from the same park  
          where he or she is applying for residency at any time preceding  
          the purchaser's application.

           Post-denial procedure:
           
          AB 2026 also makes changes to the law relating to a prospective  
          purchaser's rights if his or her application is denied.  Under  
          existing law, there is no right to a post-denial meeting. This  
          bill clarifies that management must notify the prospective  
          purchaser in writing of the specific reason or reasons for the  
          denial.  The bill also provides that, if a prospective purchaser  
          is denied, the selling homeowner and the purchaser may, within  
          five business days of receiving the denial, request an in-person  
          meeting with management.  This meeting must take place within  
          ten days, and management must reconsider its denial based upon  
          any additional information provided by the prospective  
          purchaser. 

           Liability:
           
          AB 2026 also provides that, if management denies a prospective  
          purchaser for any unauthorized reason, the management or owner  
          may be held liable for all damages to both the selling homeowner  
          and the prospective purchaser proximately resulting therefrom.








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           Repairs:

           Under existing law, upon the sale or transfer of a mobilehome,  
          management may require repairs or improvements to the exterior  
          of the mobilehome so long as the repair or improvement is based  
          upon or required by a local ordinance or state statute or  
          regulation relating to mobilehomes, or a rule or regulation of  
          the park implementing such a law.  AB 2026 provides that  
          management may only require repairs or improvements as  
          determined following an inspection by the appropriate  
          enforcement agency.  Nearly 70 local enforcement agencies  
          throughout the state have assumed enforcement powers from the  
          Department of Housing and Community Development (HCD).  In those  
          jurisdictions that have not assumed enforcement powers, HCD  
          conducts mobilehome inspections.  There is a fee associated with  
          these inspections that varies depending on the enforcement  
          agency.

           Sole residence requirement:
           
          AB 2026 prohibits park management from withholding approval of a  
          mobilehome purchaser solely because the purchaser owns another  
          mobilehome or real property residence, and prohibits management  
          from requiring that the mobilehome that is the subject of the  
          purchase be the sole residence of the purchaser as a condition  
          of granting approval. This would apply to, for example, a  
          situation where a purchaser is in the process of selling his or  
          her previous home while purchasing a mobilehome.  This bill  
          would not affect the existing provision of the MRL that provides  
          an exemption to rent control for mobilehomes that are not the  
          principal residence of the homeowner.
          
           Arguments in Support:

           Supporters contend that most park standards for prospective  
          purchasers are not regulated by the state and can vary widely  
          from park to park.  As a result, responsible and trustworthy  
          potential purchasers can be unfairly turned away as a result of  
          the park management approval process.  In supporters' view,  
          current law is too vague and has led to numerous problems  
          statewide for manufactured homeowners.  A lack of fair standards  
          creates an unfair dynamic that invites abuse, as homeowners who  
          are prevented from completing a sale are often forced to sell  
          their homes at steep discounts, usually to the park. Supporters  








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          point to examples of park failing to fairly evaluate buyers and  
          setting unreasonably high standards that frustrate sale  
          completion.  In supporters' view, AB 2026 restores balance to  
          the selling-in-park process.
           
          Arguments in Opposition:

           Opponents argue that the bill would place the responsibility to  
          approve or disapprove tenancy in the hands of financial  
          institutions, and have concerns that financial institutions only  
          have an interest in determining that a borrower can repay the  
          loan on a mobilehome, but have no interest in the mobilehome  
          park community as a whole.  In opponents' view, AB 2026 removes  
          management's ability to filter out a prospective bad tenant,  
          which would be a disservice to current residents and potentially  
          lead to a costly eviction action.  Certain opponents also  
          expressed concerns that requiring an official inspection for  
          repairs upon resale could be cost-prohibitive.

          The Committee may wish to accept the amendments below, which  
          make the following substantive changes:

             1)   Provides that a park may deny a purchaser's application  
               if the purchaser has been evicted from the same park where  
               he or she is applying for residency at any time preceding  
               the purchaser's application for tenancy.

             2)   Clarifies that, if management denies a purchaser due to  
               a reasonable determination of noncompliance with park rules  
               and regulations, based on the purchaser's tenancies during  
               the previous 3 years, it shall provide the prospective  
               purchaser with documentary evidence supporting this  
               determination in the written rejection of the purchaser's  
               application.

             3)   Deletes the requirement that management may only require  
               repairs or improvements as determined following an  
               inspection by the appropriate enforcement agency.

             4)   Deletes the language added to the subsection relating to  
               a park's liability, if it denies a purchaser for any  
               unauthorized reason, providing that management is liable to  
               both the seller and the buyer.

           Committee Amendments:








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             1)   On page 3, in line 15, restore the language  
               "  mobilehome."  and in lines 15 through 17, strike out  
               "mobilehomes, as determined following an inspection by the  
               appropriate enforcement agency, as defined in Section 18207  
               of the Health and Safety Code. "

             2)   On page 4, in line 20, strike out "support" and insert:

                support, but in no event shall the income standard exceed a  
               multiplier of three times the purchaser's income over the  
               projected housing-related expenses to be paid by the  
               purchaser in connection with the proposed mobile home  
               tenancy.
                
             3)   On page 4, in line 39, strike out "disclosed by", on  
               page 5, in line 1, strike out "management pursuant to  
               subdivision (d)" and insert: 

                established pursuant to subdivision (a)
                
             4)   On page 5, in line 6, strike out "management provides  
               the purchaser with documentary", strike out lines 7 to 9,  
               inclusive, and insert: 

                either of the following apply:
                      (A)  The prospective purchaser has been evicted from  
               the same park where he or she is applying for residency at  
               any time preceding the purchaser's application for tenancy.
                      (B)  Management reasonably determines, based upon the  
               prospective purchaser's 
               prior tenancies within the three years preceding the  
               purchaser's application, that the prospective purchaser  
               will not comply with the rules and regulations of the park.  
                If management withholds approval on this basis, it shall  
               provide the prospective purchaser with documentary evidence  
               supporting this determination in the written rejection of  
               the purchaser's application pursuant to subdivision (e).     

                
             5)   On page 5, in line 24, after "ability" insert: 

                to pay
                
             6)   On page 5, in line 25, strike out "The income standard  








                                                                  AB 2026
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               shall not" and strike out lines 26 to 28, inclusive

             7)   On page 5, in line 39, after "10" insert:

                 business
                
             8)   On page 5, in line 40, strike out "denial based upon  
               any", on page 6, strike out line 1 and insert: 

                denial, including the consideration of any additional  
               information relevant to the application provided by the  
               prospective homeowner.
           
             9)   On page 6, in lines 4 through 5, strike out "to the  
               selling homeowner and the prospective homeowner"  
          

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          Golden State Manufactured-Home Owners League (co-sponsor)
          Western Center on Law and Poverty (co-sponsor)
          California Rural Legal Assistance Foundation (co-sponsor)
          Educational Community for Homeowners (ECHO)
          California Senior Legislature
          Bay Federal Credit Union
          Senior Citizens Legal Services
          City of Capitola
          City of Watsonville
          County of Santa Barbara
          Homeowners Organized To Maintain Equity (H.O.M.E.)
          Northern Santa Barbara County Manufactured Homeowners Team
          Residents of mobilehome parks (3)





           Opposition 
           

          Western Manufactured Housing Communities Association (WMA)
          California Mobilehome Parkowners Alliance (CMPA)
          A V Ranchos Mobile Home Park








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          Arbor Mobile Home Park
          Bal Trailer Court
          Beachwood Mobile Home Park
          Belmont Shores Mobile Estates
          Bessire and Casenhiser, INC
          Birtcher Anderson Realty Management
          Boulders At The Lake MHP
          Camellia Village Mobil Home Estates
                                                                      Casa De Santiago
          Castle City Mobile Home Park
          Civic Justice Association of California
          Clayton Regency Mobile Home Park
          Corona La Linda Mobilehome Community
          Crane Lakeside Park and Resort, Inc.
          Crestview
          Del Ray Estates
          Delta Hawaii Mobile Home Park
          Desert Sands Estates
          Diamond K
          Donner Creek Mobile Park
          Eagle City Mobile Estates
          El Dorado Mobile Home Park
          El Rancho Verde
          Evans Management Services (EMS)
          Fernwood Mobile Home Community
          Garden Terrace Estates
          Garden West Estates
          Glenwood Park
          Grecian Isle
          Haven Management Services
          Holiday Island Mobile Home Park
          Hometown America Communities
          Huntington Harbor Village
          Imperial Manor Mobile Home Community
          Imperial Village MHP
          Investment Property Group (IPG)
          J & C Management, INC
          Lake Los Serranos Company
          Lakehills Estates
          Lamplighter Mobile Home Park
          Leisure Lake Mobile Estates
          Los Amigos Mobile Home Park
          Mission Mobile Manor
          Morehead Park
          Morro Palms Mobile Lodge








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          Mountain View Estates
          N & K Commercial Property
          Oak Tree Ranch
          Ojai Valley Estates
          Olive Lane Mobile Estates
          Orchard Trailer Park, INC.
          Palo Mobile Estates
          Park Lane Mobile Home Estates
          Peach Mobile Estates
          PHTRE, LP
          Ramble Greek Inc.
          Rancho Bonita Mobile Home Park
          Rancho Del Rio Estates
          Rancho La Siesta
          Rancho Riverside MHC
          Rancho San Jose MHC
          Rancho Santa Paula
          Rancho Santa Ynez Mobile Estates
          RDPH Properties, Inc.
          Redwood Village Mobile Home Estates
          Resident Owned Parks (ROP)
          River Ranch Mobile Home Park
          RoadRunner Club
          San Roque MHP
          San Vicente
          Snug Harbor Mobile Home Park, LLC
          Spanish Ranch 1
          Stonegate Estates
          T & L Property Management
          The Boulder at the Ranch I
          The Boulders at the Ranch II
          The Caritas Corporation
          The Willows at Bethel Island
          Trade Winds Mobile Estates
          Villa Corona Mobile Home Park
          Vista De Santa Barbara
          Woodland Park Mobile Estates
          Individual Owners and Managers of Mobilehome Parks (37)
           
          Analysis Prepared by  :    Rebecca Rabovsky / H. & C.D. / (916)  
          319-2085 












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