In Ziello v. Superior Court (1995) 36 Cal. App. 4th 321, the Court addressed the issue of whether a lender could assume control of earthquake insurance proceeds where the deed of trust did not require earthquake insurance and contained no reference to earthquake insurance proceeds. The Court concluded that "in the absence of special provisions in the loan documents, a trustor-borrower has no obligation to procure insurance for the benefit of the mortgagee against fire or other risk, and neither the trustor nor the beneficiary ordinarily has an interest in the proceeds of insurance obtained by the other on its own separate insurable interest" (id. at p. 326) and that "the agreement of the parties regarding the proceeds of required insurance has no application to proceeds of additional insurance borrower chose to obtain for her own benefit" (id. at p. 327). Although the insurance policy named the lender as loss payee, we held that "the fact that lender is named as the loss payee of the earthquake insurance does not determine its entitlement to the insurance proceeds. The loss payable endorsement in an insurance policy 'defines only the obligation of the insurer. The provision is intended to protect the insurer by permitting it to pay the named insured and to be thereafter free of claims by other persons who might have an interest in the lost property.' (Ferro v. Citizens Nat. Trust & Sav. Bank (1955) 44 Cal. 2d 401, 410 282 P.2d 849.) The rights of the parties do not depend on the interpretation of the loss-payable clause of the policy." (Ziello, at pp. 329-330.) In reaching our decision in Ziello, the Court discussed an earlier case, Alexander v. Security-First Nat. Bank (1936) 7 Cal. 2d 718 62 P.2d 735, which had been relied on by the trial court to reach a contrary conclusion. That case involved: (1) a contractual obligation to procure earthquake insurance; (2) a lease provision requiring the lessee to apply all insurance proceeds to repair the property. (Ziello v. Superior Court, supra, 36 Cal. App. 4th at p. 329.) The Court found Alexander distinguishable because "in our case Ziello there was no requirement to procure earthquake insurance, nor any broad provision as to the application of all insurance proceeds (whether required or not) to repair or reduce indebtedness." (Ziello, at p. 329.)