Scenarios / Prop 19 equalization loan

The Prop 19 parent-to-child equalization loan

Borrower: The trust — trustee signs in a fiduciary capacity On title: The trust, undistributed, at the time the bridge records Timing: Bridge in roughly 5–10 business days once authority is clear; the exit runs on a normal refinance clock after distribution. The one-year occupancy window runs from the transfer, independent of financing.
The fact pattern. The trust holds the family home; one child wants to keep it with the parents' factored base-year value, and the other beneficiaries want their shares in cash. Ordered casually, the buyout reads as a transfer between beneficiaries and the county reassesses; ordered correctly, the transfer stays parent-to-child with the exclusion analysis intact.

The structure depends on the property being encumbered and the other beneficiaries being equalized while the trust still holds title. If the property has already been distributed, start with the sibling-buyout scenario instead.

The structure, step by step

  1. Run the exclusion math before anything movesFactored base-year value plus the BOE-published exclusion amount against a defensible FMV; confirm the keeper is an eligible transferee who will occupy as a principal residence within one year; confirm the instrument permits non-pro-rata distribution and encumbrance. This is the same-day read.
  2. Third-party loan to the trustA private-money bridge is made to the trust, secured by the property while the trust holds title, sized to the equalization need plus costs. The trustee is the borrower; the acquiring child is not the source of funds.
  3. Equalize the other beneficiaries with loan proceedsThe non-keeping beneficiaries receive cash equal to their shares from the loan proceeds — money that reached the trust from a third-party lender, which is the fact the exclusion position stands on.
  4. Distribute the property, encumbered, to the keeperThe trustee deeds the property to the keeper subject to the loan as a non-pro-rata distribution. The transfer runs from parent (through the trust) to child — not sibling to sibling.
  5. File the claim and perfect occupancyThe keeper occupies as a principal residence, claims the homeowners' exemption within one year of transfer, and files the parent-child claim (BOE-19-P) inside its window.
  6. Exit refinance retires the bridgeThe keeper refinances in their own name on whatever documentation their income actually supports — designed on day one, originated at this same desk.
bridge to the trust equalizing cash non-pro-rata deed retires the bridge Private lender third-party funds The trust holds the home Other beneficiaries equalized in cash The keeper deed, subject to loan Exit refinance same desk

Why the sequencing is the whole game

Proposition 19 left one reliable way for a child to keep the family home at (or near) the parents’ assessed value when the other children want cash: the equalization has to happen while the property is still in the trust, with money that did not come from the keeper. Every piece of this structure exists to protect those two facts — the third-party loan to the trust, the equalizing distributions out of loan proceeds, the encumbered non-pro-rata deed, the occupancy and the claim on their statutory clocks.

Run casually — “deed me the house and I’ll cash you out” — the same economics produce a transfer between beneficiaries, a reassessment to market, and a property-tax bill that can be an order of magnitude larger, permanently. The county does not grade on intent.

This desk’s role is narrow and complete: confirm the math and the authority, fund the bridge to the trust on the private side, and underwrite the keeper’s exit refinance before the bridge ever records — one desk, both originations, no hand-off in the middle of the sequence. Your role stays what it should be: the instrument, the distribution plan, and the final word on the structure. Nothing records until counsel has seen the sequence in writing.

The traps

Equalization funded by the keeper

If the acquiring child's own cash — or a loan they personally take — pays the other beneficiaries, the purchased interests read as transfers between beneficiaries: reassessed, no exclusion. The equalizing money must reach the beneficiaries from a third-party loan to the trust.

The one-year occupancy clock

The family-home exclusion requires the keeper to make the home their principal residence and claim the homeowners' exemption within one year of the transfer. Filings have grace mechanics; the move-in itself does not.

The claim window

The parent-child claim (BOE-19-P) is due within three years of transfer or before a transfer to a third party, whichever comes first; later filings generally get prospective relief only. Calendar it at distribution, not at tax-bill time.

Below-FMV pricing turns into a gift

Equalize below a defensible fair market value and the difference is part gift — gift-tax reporting for the beneficiaries who took less, and a distorted record if anyone later audits the math. Price the buyout off an appraisal; an MLS-based read here comes same-day as a sanity check first.

Counsel's questions

Does the trust need express borrowing power?

Most modern instruments grant the trustee power to borrow and encumber. Where the instrument is silent or restrictive, the fix is usually beneficiary consents or court instruction — a counsel decision. Authority is the first thing checked in the same-day read, because it drives the whole timeline.

Can the keeper guarantee or co-sign the bridge?

Lenders sometimes ask. Whether any keeper involvement in the credit is compatible with the exclusion position is exactly the sequencing detail that gets reviewed with you before anything records — it is raised at the scenario stage here, never discovered at the closing table.

Is there anything left to exclude on a coastal Orange County home?

Often yes, partially. The excluded amount is the factored base-year value plus the BOE-published adjustment — $1,044,586 for transfers from February 16, 2025 through February 15, 2027. Above that, the excess adds to taxable value, but a partial exclusion on a low base is still routinely worth six figures of assessed value. The math gets run before the structure is priced.

What if a beneficiary is out of state or slow to respond?

That is an administration problem before it is a financing problem — the loan needs the distribution counsel actually intends, not unanimity for its own sake. Send the fact pattern; the structure memo will say what the financing side needs signed and by whom.

The two-minute versions

Presenter briefing Prop 19 equalization loan In production — scripts are drafted from this page's source file and recorded after Ken approves them.

60–90 seconds, addressed to counsel: the fact pattern, the structure, what to send.

Transcript

Published with the video.

Animated structure walkthrough Prop 19 equalization loan In production — scripts are drafted from this page's source file and recorded after Ken approves them.

60–120 seconds of motion graphics: the money flow, the timeline, the exit.

Transcript

Published with the video.

Have a prop 19 equalization loan file on your desk?

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