01.13.11
Posted in Bankruptcy, Litigation, Real Estate Law, Taxation Law at 08:48 by Administrator
Q. I own a California home, but like many residential properties, the value of my home has declined so much that I now owe much more on it than what it is worth. I have two mortgages on this property, a “first” and a fairly sizable “second” loan. Fortunately, I have access to a modest amount of cash, which I could use as a down payment on a new home. I am considering the purchase of a new house to use as my principal residence, so I can take advantage of the current “buyers’ market” for residential housing. If I purchase a new home, I would consider converting my current home into a rental property. What are the possible legal issues associated with this strategy?
A. Your idea sounds like a good one. It is also an idea many homeowners in your situation are considering. However, there are at least three potential complications associated with the strategy you describe.
Because you are “upside down” with respect to your current home, that is, you owe more against that property than it currently is worth, chances are that the rent it will generate will not be sufficient to pay the mortgages. Thus, it is likely you will have a monthly loss associated with that property, a loss which you will have to cover from other income or assets.
This likelihood of negative cash flows creates the possibility of the first legal issue: eventual foreclosure.
Second, in the event of a foreclosure on your current California home/prospective rental property, you may or may not be exposed to a deficiency judgment with respect to the first loan. A deficiency judgment is a civil judgment for the difference between the amount owed on a property and the amount ultimately obtained for that property at a foreclosure sale.http://earlelaw.com/news_family.html.
Regardless of the status of your first loan, there is a significant likelihood that you may be subject to a deficiency judgment with respect to the second, or junior, loans on this property.
Any California deficiency judgment obtained against you will be valid for 10 years, and can be renewed for additional 10 year periods.
Furthermore, a deficiency judgment can be recorded as a lien against your new home, or against any other interest in real property which you may own, purchase, or acquire. Any lien recorded against a parcel of real property must, of course, be satisfied before that property can be sold.
Third, there are potential tax consequences, relating to the cancellation of debt, which might require that you pay income tax on any deficiency amount related to a foreclosure, even if a deficiency judgment is not obtained.
Whether you are a home/property owner who is in the undesirable position of deciding what to do with a distressed property, or a lender (institutional or private) who owns distressed loans, you would be well-advised to consult with an attorney before embarking on a course of action designed or intended to mitigate your monetary loss.
*Anthony F. Earle, Esquire is a California attorney and real estate broker who maintains a practice in the Silicon Valley area of northern California. He can be reached at: anthony.earle@earlelaw.com. This article is intended for information and educational purposes only, and is not intended to constitute legal advice.
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01.07.11
Posted in Family Law, Litigation, Real Estate Law at 14:53 by Administrator
Q. My spouse purchased a house, taking title as the sole owner. In order to assist my spouse in acquiring title to the house, I signed a quitclaim deed in reliance on my spouse’s oral promise to add my name to the title after the purchase had been completed. My spouse never did add my name to the title and now, we are contemplating divorce. If we do divorce, will the court consider the house to be my spouse’s separate property or will the house be considered marital property?
A. The situation you describe is quite common. Husbands and wives often purchase real property during marriage, while taking title to the acquired property in the name of only one spouse. Typically, this is done to facilitate financing, where the interest rate on the loan obtained to finance the property is lower if only one spouse’s name is on the title.
As a general matter, the law presumes that title to property is held in the manner described in the deed. California Evidence Code § 662. This presumption may be rebutted with clear and convincing evidence, a standard which is higher than the preponderance of the evidence standard which applies to most civil cases, but lower than the beyond a reasonable doubt standard which applies in criminal cases.
Married persons may, of course, purchase property from third parties. Married persons may also enter into transactions between themselves. However, different legal rules apply to these very different types of transactions. When married persons, either individually or jointly, purchase property from third parties, “normal” contract rules apply: transactions are presumed to have been made at “arms length” and no special relationship usually exists between buyer and seller.
In California, spouses owe each other a “fiduciary duty”, California Family Code § 721, which is the highest duty the law can impose on one’s relations with another. This duty owed by each spouse to the other is that of the highest good faith and fair dealing, and requires that neither take any unfair advantage of the other.
To give effect to this fiduciary duty, California law presumes that any interspousal transaction that advantages one spouse over the other was the product of undue influence. Undue influence, in turn, comes in many legal flavors, one of which is the use of confidence or authority to obtain an unfair advantage. California Civil Code § 1575. A spouse who gained an advantage over the other spouse may rebut this presumption by a preponderance of the evidence.
The presumption relating to transactions between spouses, created by Family Code § 721, trumps the presumption relating to title, created by Evidence Code § 662.
Thus, in the situation you describe, a California court should find that the house is community property, subject to equal division. Your spouse, however, is entitled to reimbursement of any of your spouse’s separate property funds which were used, for example, for the down payment which was needed to purchase the house.
The legal issue described above was addressed by the California Court of Appeal in Starr v. Starr, B219539 (Second Appellate District; filed September 30, 2010, published October 15, 2010). A copy of the court’s opinion may be downloaded without charge at: http://earlelaw.com/news_family.html.
*Anthony F. Earle, Esquire is a California attorney and real estate broker who maintains a practice in the Silicon Valley area of northern California. He can be reached at: anthony.earle@earlelaw.com. This article is intended for information and educational purposes only, and is not intended to constitute legal advice.
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12.22.10
Posted in Litigation, Real Estate Law at 10:29 by Administrator
Q. I own a California home which currently is worth less than what I owe on the loan which is secured by the property. Will the new California short sale deficiency law make it easier for me to negotiate a short sale agreement with my lender?
A. California Senate Bill (SB) 931, which makes it unlawful for mortgage lenders to require borrowers, as a condition of approving or accepting “short sale” agreements, to repay deficiencies, has been signed into law and, on January 1, 2011, will become section 580e of the California Code of Civil Procedure.
For purposes of section 580e, a “short sale” is defined as a transaction in which a mortgage lender agrees to release its security interest in a parcel of real property, while accepting less than the outstanding balance due on the loan which is secured by that property. A “deficiency” is the difference between the outstanding amount due on the mortgage loan and the lower amount which is realized from the sale of a property which has declined in value.
Section 580e provides, in relevant part: “No judgment shall be rendered for any deficiency under a note secured by a first deed of trust or first mortgage for a dwelling of not more than four units, in any case in which the trustor or mortgagor sells the dwelling for less than the remaining amount of the indebtedness due at the time of sale with the written consent of the holder of the first deed of trust or first mortgage.”
Section 580e will apply to residential properties consisting of one to four units, which need not be owner-occupied. Unlike prior law, section 580e will apply to refinanced loans as well as purchase money loans. However, section 580e will apply only to first loans, and not to second or other junior loans. The protections of section 580e also will not be available in cases in which the borrower has committed fraud.
Although the provisions of section 580e may, at first, appear to be favorable to owners of distressed residential properties, section 580e may actually make it more difficult for these borrows to convince lenders to accept short sale agreements.
Under prior law, lenders could use short sale agreements to convert what had become partially worthless secured loans (”underwater” mortgage loans) into a potentially valuable unsecured loans (short sale agreements with a deficiency repayment clause). Because section 580e purports to eliminate the ability of lenders to attempt to mitigate their losses in this fashion, there will be less incentive for lenders to accept short sale agreements.
In the end, section 580e may actually cause an increase in the number of California foreclosures, especially in cases where a deficiency judgment is otherwise allowed by law.
*Anthony F. Earle, Esquire is a California attorney and real estate broker who maintains a practice in the Silicon Valley area of northern California. He can be reached at: anthony.earle@earlelaw.com. This article is intended for information and educational purposes only, and is not intended to constitute legal advice.
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12.17.10
Posted in Real Estate Law, Taxation Law at 18:43 by Administrator
Q. My spouse and I are interested in buying our first home. Considering the current downturn in the economy in general and the real estate market in particular, what should we consider when purchasing a residence?
A. Depreciation in the value of residential real property, combined with mortgage interest rates which currently are at near historic lows, make this an excellent time to purchase real estate.
For example, a recent search of multiple listing service (MLS) listings for single family residences (SFRs) in the Silicon Valley area of northern California revealed that a 3-bedroom, 2-bath home (3/2) can be purchased for $750,000. The MLS also contains listings for 3/2 SFRs starting at about $500,000 and exceeding $1 million.
If one were to make a ten percent down payment on a $750,000 SFR, a loan for the balance would be needed in the amount of 675,000. Assuming a 30 year loan with an interest rate of 5%, monthly payments of principal and interest would be approximately $3,624. Interest on the mortgage would be deductible for income tax purposes (IRS Publication 936, Home Mortgage Interest Deduction), unless the mortgage interest deduction (MID) is removed from the tax code, as has recently been discussed in Congress.
Another recent search of MLS listings for the Silicon Valley area revealed that a four-unit residential property can be purchased for $1 million. Less expensive and, of course, more expensive four-unit complexes are also available.
Assuming a ten percent down payment, a loan of $900,000 would be needed to purchase a $1 million fourplex. Monthly principal and interest payments on a 30 year loan with an interest rate of 5% would be approximately $4,831. Interest attributable to units which are rented to tenants would be deductible for tax purposes as a business expense. See, Chapter 4, IRS Publication 535 (Business Expenses) and IRS Publication 527 (Residential Rental Property).
Assuming a fair market rental value of $1,200 per month for each unit, and a ten percent vacancy rate, rental income generated by three of the four units should be $3,240 per month. If you and your spouse used the fourth unit as your residence, your effective mortgage payment or “rent” would be $1,591 per month, which is $2,033 per month less than your mortgage payment would be if, as in the first example, you purchased a SFR.
You will, under each of the above examples, incur expenses for routine maintenance, property taxes, and insurance. These expenses will be mostly tax deductible if you own the fourplex, but mostly not tax deductible if you own the SFR. Additionally, if you own the fourplex, you will have an additional deduction for depreciation, a deduction which will not be available if you purchase the SFR.
Finally, when you and your spouse sell the fourplex, you should be able to take advantage of tax rules relating to “like-kind” exchanges, to defer capital gains tax. However, if you and your spouse purchase the SFR, the amount of capital gain which can be excluded from taxation may be limited.
The SFR will likely provide you and your spouse with a home that is more comfortable and aesthetically appealing than a fourplex, but becoming an owner of residential rental real estate should be a good first step on your road to financial prosperity and independence.
*Anthony F. Earle, Esquire is a California attorney and real estate broker who maintains a practice in the Silicon Valley area of northern California. He can be reached at: anthony.earle@earlelaw.com. This article is intended for information and educational purposes only, and is not intended to constitute legal advice.
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12.04.10
Posted in Real Estate Law at 08:52 by Administrator
Q. I have been attempting to obtain the assistance of a professional to help me negotiate a mortgage loan modification with my lender, but no one seems willing to help me. Why am I having difficulty obtaining the assistance that I need?
A. Prior to October 2009, it was lawful for both attorneys and non-attorneys to offer loan modification services to homeowners such as yourself. In this pre-October 2009 unregulated environment, some service providers committed fraud when working with homeowners who were seeking to modify their mortgage loans.
California responded to these abuses by passing a law which became effective during October 2009, and which states that only attorneys and licensed real estate brokers may offer loan modification services and that fees for such services may not be received by attorneys or brokers until they have “fully performed each and every service [they] contracted to perform.”
The actual and intended effect of the California law was to make it illegal for anyone other than an attorney or real estate broker to offer loan modification services. However, as is typical for California, it legislates a “right” with one hand, while simultaneously regulating that same “right” out of existence with the other hand. So it was with loan modifications: it made illegal the offering of loan modification services, while carving out an exception for lawyers and real estate brokers.
Then, with the same stroke of its legislative pen, California regulated out of existence this newly-created “right” for lawyers and real estate brokers to offer loan modification services by prohibiting the collection or receipt of advance fees for loan modification services. Whether it was intended or merely an unintended consequence is unclear, but the fact remains that the overwhelming majority of attorneys and real estate brokers are unwilling to offer loan modification services unless they can collect retainers or advance fees.
As goes California, so goes the nation. The Federal Trade Commission (FTC) recently issued its Mortgage Assistance Relief Services (MARS) Rule, which applies nationwide and states that providers of mortgage loan modification services may not collect fees “until homeowners have a written offer from their lender or servicer that [the homeowner] decide[s] is acceptable.”
The FTC’s MARS Rule will not have much affect in California. Although the MARS Rule contains an exception for attorneys if allowed by state law, California law expressly prohibits the collection of advance fees.
Thus, only attorneys in states where state law allows an attorney to collect advance fees for loan modification services are likely to continue accepting loan modification cases.
Neither California nor the federal government have explained why existing laws – both civil and criminal – which currently make fraud illegal are not sufficient to protect homeowners who seek loan modification services, or why increased penalties would not remedy any perceived deficiency in existing law.
So, rather than protect homeowners from unscrupulous service providers, California has prohibited all but attorneys and real estate brokers from providing loan modification services, and both California the federal government have prohibited the collection of fees prior to the completion of the loan modification process. Given this level of government control, it is not surprising that you are having difficulty finding a professional who is willing to help you with your loan modification.
Although it may be all but impossible to find an attorney who is still accepting loan modification cases, there still may be legal strategies an attorney can help you employ which might benefit you. As always, you should contact your attorney as soon as you become aware of a potential legal problem.
*Anthony F. Earle, Esquire is a California attorney who practices in the Silicon Valley area of northern California. He can be reached at: anthony.earle@earlelaw.com. This article is intended for information and educational purposes only, and is not intended to constitute legal advice.
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11.19.10
Posted in Litigation, Real Estate Law at 20:00 by Administrator
Q. I have seen conflicting news reports on how courts are handling residential home foreclosure cases in which the owner/borrower, in defending against foreclosure, has asked the court to require their lender to show the promissory note as a condition of being allowed to proceed with a foreclosure action. Why does there seem to be a lack of consistency in reports on this issue?
A. Promissory notes, such as notes used to finance real estate, are contracts. In exchange for lending money, borrowers promise to repay the borrowed money, with interest. So-called “show-the-note” litigation stems from the very simple idea that when a party to a contract sues to enforce the contract, the party bringing the lawsuit must prove to the court that a contract, in fact, exists and that the party being sued is in breach of that contract.
However, in California, foreclosure actions are not, technically, considered to be actions for breach of contract, even though breach of a promise to repay money which is secured by real estate may, itself, constitute breach of contract.
California has adopted a comprehensive statutory scheme for the regulation of foreclosure actions including, among other things, the “one form of action” rule and statutes relating to deficiency judgments, all of which restrict the legal options which are available in California to mortgage lenders who seek to enforce their mortgage contract rights.
Thus, California state courts, and federal district courts located in California when applying California law, have consistently held that California law does not require a foreclosing lender to “show-the-note” before proceeding with a foreclosure. Rather, such lenders can demonstrate a right to foreclose with other – and often more readily available – documents.
Some bankruptcy courts in California and elsewhere, however, have taken a different approach. In the case of In re Vargas, 396 B.R. 511 (C.D. CA, filed Oct. 21, 2008), bankruptcy judge Samuel L. Bufford held that Mortgage Electronic Registration System, Inc. (MERS) could not be released from bankruptcy’s automatic stay of all collection activity in order for it to foreclose on a home because the company had provided “no evidence as to who owns the note, or of any authorization to act on behalf of the present owner.” Reportedly, more than a dozen courts, including the Supreme Courts of Guam and Kansas, have cited Vargas favorably.
One explanation for the different treatment “show-the-note” cases have received in California state courts and federal district courts located in California, on the one hand, and, bankruptcy courts in California and elsewhere, on the other, is simply that federal bankruptcy law sets a higher legal standard than does California law when it comes to what procedures a lender must follow when foreclosing on a secured note.
Because a lender’s ability to foreclose may turn on upon which court (state/federal district or bankruptcy) or which law (state or bankruptcy) applies to a particular case, it is important to obtain legal representation prior to challenging a foreclosure action.
*Anthony F. Earle, Esquire is a California attorney who practices in the Silicon Valley area of northern California. He can be reached at: anthony.earle@earlelaw.com. This article is intended for information and educational purposes only, and is not intended to constitute legal advice.
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11.13.10
Posted in Litigation, Real Estate Law at 10:27 by Administrator
Q. I am a California homeowner who is facing foreclosure. I would like to try to obtain a loan modification so I can save my home. Are there any California state laws which might help me? What are my options if my lender violates California foreclosure law?
A. The California Foreclosure Prevention Act (FPA), which was enacted in February 2009, provides extra time for borrowers facing foreclosure to work out loan restructurings. In addition to the usual 90-day period which is required to complete a foreclosure, the FPA requires lenders delay foreclosures an additional 90 days and pursue alternative courses of action during that time.
Lenders, however, may obtain an exemption from the additional 90-day period by demonstrating to the commissioner of a state licensing agency that the lender has in place a foreclosure prevention program designed to keep owners in their homes, when possible.
It has been said that without a remedy, there is no right. So let us look at how the FPA can be enforced.
Manatu and Lucy Vuki lost their Buena Park, California home to foreclosure. When HSBC Bank, the Viki’s former lender and buyer of the Vuki’s property at the foreclosure sale, sought to evict the Vukis, the Vukis responded by suing HSBC Bank for having allegedly violated the FPA. As part of their litigation strategy, the Vukis petitioned the California Court of Appeal for a writ which, if granted, would have stopped or delayed the eviction.
The Court of Appeal found that enforcement of the FPA’s provisions is, by statute, committed to the commissioner of the relevant state licensing authority. The court noted that the FPA’s statutory language provides that: “[a]ny person who violates any provision of [the FPA] shall be deemed to have violated his or her license law as it relates to these provisions.” Because violation of the FPA constitutes a violation of professional licensing law, the court held that the FPA “makes enforcement a matter of losing a license.” Vuki v. Superior Court (HSBC Bank USA), G043544, Fourth Appellate District, Division Three (October 29, 2010).
In other words, homeowners/borrowers may not sue their lenders for violating the FPA, because the FPA is enforceable only by the state, through administrative actions taken against professional licenses.
Although there exists no private right of action for enforcement of the FPA, other legal options may be available to homeowners/borrowers who seek to prevent foreclosure. As with any legal matter, an attorney can be most effective if retained early in a case, rather than later.
*Anthony F. Earle, Esquire is a California attorney who practices in the Silicon Valley area of northern California. He can be reached at: anthony.earle@earlelaw.com. This article is intended for information and educational purposes only, and is not intended to constitute legal advice.
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11.11.10
Posted in Bankruptcy, Business Law, Constitutional and Civil Rights Law, Criminal Law, Family Law, Litigation, Real Estate Law, Trusts and Estates at 12:24 by Administrator
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Bankruptcy
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Trust and Estates
Review of basic legal documents during telephone consultations
10 percent discount on legal fees for matters not covered by the LAW Plan
For more information and to subscribe, please visit:
http://earlelaw.com/lawplan.html
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11.06.10
Posted in Bankruptcy, Real Estate Law at 10:09 by Administrator
Q. I am considering bankruptcy because I have a large amount of credit card debt. I also own a home and am currently working with my mortgage lender to modify the mortgage. How might a mortgage loan modification affect my bankruptcy filing?
A. Generally speaking, your lawyer should attempt to handle your bankruptcy case in a manner which will result in you being relieved of the greatest possible amount of debt. For consumers, this typically is done through the filing of either a Chapter 7 or Chapter 13 bankruptcy petition. The term “Chapter” as used in discussions of bankruptcy, relates to the area or “chapter” of the Bankruptcy Code which provides the legal authority for specific types of bankruptcy relief.
The difference between Chapter 7 proceedings and Chapter 13 proceedings is, in a nutshell, that Chapter 7 proceedings are usually completed within a few short months, with most, if not all, debt being completely discharged. Chapter 13 proceedings, on the other hand, may take three to five years to complete. In Chapter 13 proceedings, the debtor makes reduced monthly payments while the bankruptcy case is pending, with some portion of the total debt ultimately being discharged.
Chapter 7 proceedings are appropriate for debtors who possess few assets and have low income, relative to their debts. Debtors who own real property when seeking to file for bankruptcy generally must proceed under Chapter 13.
Several facts which might affect your bankruptcy case can be inferred from the statement that you are attempting to obtain a mortgage loan modification. First, you own real property, or at least an interest in real property. Second, the current fair market value of your real property might now be less than what is owed on the loan(s) which is secured by that property. Third, you have income.
In this situation, there are at least two questions which should be answered before you proceed with any bankruptcy filing. First, whether your case would qualify for Chapter 7 relief if you did not own a home. Answering this question is a very fact-specific endeavor which almost always will require the assistance of a lawyer. Second, whether it makes economic sense to modify the loan, that is, whether it will be economically beneficial for you to continuing owning the home if the lender(s) agrees to modify the loan. More information on “When Should You ‘Just Walk Away’ (From that House)?” can be obtained free of charge at: http://earlelaw.com/Newsletters-2009/EarleLaw-Newsletter-2009-42.pdf.
Although it is possible to convert a Chapter 13 bankruptcy filing to a Chapter 7 case, doing so will involve additional work and, if you are represented by an attorney, additional attorney fees. Thus, your question was a good first step in the process of preparing to file for bankruptcy.
*Anthony F. Earle, Esquire is a California attorney who practices in the Silicon Valley area of northern California. He can be reached at: anthony.earle@earlelaw.com. This article is intended for information and educational purposes only, and is not intended to constitute legal advice.
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10.30.10
Posted in Litigation, Real Estate Law at 08:08 by Administrator
Q. “Short sales” of residential properties – transactions where the amount a buyer pays for a property is less than the amount the seller owes on loan(s) secured by the property – are becoming increasing common. Do real estate brokers have a legal obligation to disclose to buyers that a transaction is a short sale?
A. Before answering your question, we should identify exactly whom the real estate broker represents. In cases where only one real estate broker is involved, there are three possibilities: the broker represents (1) only the seller, (2) only the buyer; or (3) both buyer and seller.
In the second and third scenarios – where a broker represents only the buyer, or both buyer and seller – the broker, as an agent for the buyer, has a well-established duty to disclose to the buyer any material fact concerning the transaction which the broker knows or reasonably should know. Any competent broker should easily be able to discover encumbrances – loans – which have been recorded against a property and, thus, are in the public record, and must disclose this information to the broker’s principal, the buyer.
But what about the case where a real estate broker represents only the seller? Must a broker in this situation disclose to the buyer facts which are in the public record? Stated differently, does a real estate broker who represents only the seller have a legal duty to perform due diligence for a buyer? If one were to examine well-settled principles relating to the law of agency relationships the answer should be: “No.”
However, that was not the result in Holmes v. Summer, G041906 (Cal.App.4th, filed October 6, 2010), where real estate broker Sieglinde Summer (Re/Max) represented the seller of a Huntington Beach residential property. The buyer, Holmes, was self-represented. The subject property was listed on a Multiple Listing Service for an asking price of $749,000, with Summer to receive a 3 percent sales commission.
Holmes offered to purchase the property for $700,000. The seller counter-offered at $749,000, and Holmes accepted. Loans encumbering the property totaled $1,141,000. The court’s opinion further tells us only that the purchase contract provided for a 30-day escrow and that “the property could not be transferred to [Holmes] free and clear of all monetary liens and encumbrances. . . .”
Holmes sued Summer, alleging various causes of action, all of which were predicated on the assumption that Summer – the seller’s broker – had a duty to disclose to Holmes – the self-represented buyer – that the total of all encumbrances exceeded the contract price for the property. A California state appeal court agreed with Holmes and reversed the trial court, which had dismissed the case after finding Summer owed no legal duty to Holmes.
When evaluating Holmes v. Summer, it is important to note this was not a case which involved false statements or affirmative concealment of facts. This simply was a case of non-disclosure where the self-represented buyer, who reasonably should have known the subject property was encumbered by loans, failed even to ask the seller whether the balance owed on the those loans exceeded the negotiated purchase price. If Holmes had bothered to ask, the seller, and the seller’s broker, Summers, would have been obligated to respond truthfully. So much for the doctrine of caveat emptor (let the buyer beware); the rule now appears to have completely changed to caveat venditor (let the seller beware).
And so much for the concept of a seller’s broker, at least in California. Even though the appeal court said that, “[b]y so holding, we do not convert the seller’s fiduciary into the buyer’s fiduciary,” any court decision which requires a seller’s broker to perform due diligence for a self-represented buyer does exactly that. So, with no foreseeable end in sight to governmental paternalism, and just in time for Halloween, we now must say to the California buyer’s broker, “R.I.P.”
*Anthony F. Earle, Esquire is a California attorney who practices in the Silicon Valley area of northern California. He can be reached at: anthony.earle@earlelaw.com. This article is intended for information and educational purposes only, and is not intended to constitute legal advice.
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