What is the test for an award of attorney's fees and costs under section 271 of the California Family Law Code?

Section 271, subdivision (a), provides: "Notwithstanding any other provision of this code, the court may base an award of attorney's fees and costs on the extent to which the conduct of each party or attorney furthers or frustrates the policy of the law to promote settlement of litigation and, where possible, to reduce the cost of litigation by encouraging cooperation between the parties and attorneys. An award of attorney's fees and costs pursuant to this section is in the nature of a sanction. In making an award pursuant to this section, the court shall take into consideration all evidence concerning the parties' incomes, assets, and liabilities. The court shall not impose a sanction pursuant to this section that imposes an unreasonable financial burden on the party against whom the sanction is imposed. In order to obtain an award under this section, the party requesting an award of attorney's fees and costs is not required to demonstrate any financial need for the award." The statute vests family courts with discretion to enforce the public policy of promoting settlement, while reducing costs through mutual cooperation. (In re Marriage of Falcone & Fyke (2008) 164 Cal.App.4th 814, 827-828.) An award of attorney's fees and costs under section 271 is reviewed for abuse of discretion. (Parker v. Harbert (2012) 212 Cal.App.4th 1172, 1177.)