HomeMy WebLinkAbout2/24/2026 Item 4a, Babbar
876
February 20, 2026
Mayor Erica A. Stewart
Members of the San Luis Obispo City Council
990 Palm Street
San Luis Obispo, CA 93401
Re: February 24 Study Session – Opposition to Rental Registry Proposal
Dear Mayor Stewart and Members of the City Council:
On behalf of the California Apartment Association (CAA) and our local rental
housing provider members, we respectfully express our opposition to the proposed
rental registry being evaluated at your February 24 study session.
While we share the City’s commitment to safe and well-maintained housing, a rental
registry presents significant fiscal, operational, and privacy concerns without clear
evidence that it will improve housing conditions or affordability.
Costs and Administrative Burden
A registry imposes avoidable costs on both the City and housing providers. City
staff would be saddled with an administrative and fiscal burden to ensure
compliance, troubleshoot technical issues and pursuing enforcement. The city would
need to cover the costs incurred at program launch without any guarantee of
recovering that cost. There is the burden on the owner since cities typically pass on
the cost of managing a registry onto housing providers in form of fees. This burden
also extends onto operations because a property owner would have to dedicate staff
to maintain compliance with a registry.
Other jurisdictions have found these programs to be resource-intensive. Those
jurisdictions have identified significant startup costs, ongoing annual expenditures,
and the need for multiple full-time employees to manage and enforce registry
programs. In some cases, cities ultimately declined to proceed due to budgetary and
staffing impacts. The State Legislature in California have rejected a statewide rental
registry on three separate occasions due to the cost and burden of creating a registry
and enforcing it.
Privacy and Legal Risks
A rental registry would create a centralized government database containing tenant
names, addresses, and rent amounts—often submitted without tenant consent. This
raises significant privacy concerns. How will the City respond if tenants object to
having their personal information included in a municipal database? Public
disclosure of rental data, whether through public records requests or other legal
mechanisms, could also disadvantage housing providers by exposing proprietary rent
information. In addition, unresolved questions remain regarding liability for the
compelled submission of tenant information over a tenant’s objection. Finally, no
municipal system is immune from cybersecurity breaches. A centralized database
containing confidential or proprietary information presents ongoing fiscal and data
security risks.
Existing Tools Are Sufficient
The City already possesses robust code enforcement authority to address
substandard housing. A registry duplicates existing mechanisms while expanding
bureaucracy. Even San Jose’s City Auditor raised concerns that registries create
significant burdens and that complaint-based systems may be more efficient and
cost-effective.
Alternatives
Rather than creating a new regulatory program, the City could enhance existing
property contact databases to ensure accurate points of contact. Provide educational
materials to tenants outlining applicable state and local protections. And focus
resources on targeted enforcement where complaints or violations occur.
These approaches advance accountability without imposing sweeping new
mandates.
For these reasons, CAA respectfully urges the Council to decline the creation of a
rental registry and instead prioritize policies that support housing production,
effective enforcement, and long-term affordability.
Thank you for your consideration.
Sincerely,
Anil Babbar
Senior Vice President of Public Affairs
California Apartment Association