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<br />Alcala, Abigail <br />From:Chip Ahlswede <Chip@aaoc.com> <br />Sent:Tuesday, November 7, 2023 2:24 PM <br />To:eComment <br />Subject:Comments from the Apartment Association of Orange County <br />_________________________________________ <br />525 Cabrillo Park Drive, Suite 125, Santa Ana, CA 92701 <br />Phone: (714) 245-9500 Fax: (714) 245-9505 <br />www.AAOC.com <br /> <br /> <br /> <br /> <br />November 7, 2023  <br /> <br />Mayor Amezcua and City Council  <br />20 Civic Center Dr.  <br />Santa Ana, CA 92701  <br /> <br />Re: Santa Ana Rent Registry  <br /> <br />Dear Mayor Amezcua and members of the Santa Ana City Council:  <br /> <br />Thank you for calling for a report from the city staff and consultants regarding the creation of the city’s rent registry. <br />While we appreciate that the report was given, we take serious issue with several of the assertions made in the report <br />and would like to correct them for the record.  <br /> <br />First, it should be noted that anything requested or contained within the registry itself is not visible to the public. While <br />the city has provided tutorials, understanding how the system operates isn’t provided. The city only provides a snapshot <br />– not an operation, which is where these problems become evident.  <br /> <br />Second, the Petris Act governing rent registries states the only tenant information the city has the authority to require is <br />the tenant’s name. That is where the city’s request should begin and end.   <br /> <br />Third, the Fair Housing Act prohibits the collection of information indicating a tenant’s nation of origin. The <br />registry requires submission of the tenant’s preferred language under penalty of perjury.  <br /> <br />Fourth, the Consumer Protection Act and the California Consumer Privacy Act require that notification and consent be <br />given when providing information that may be used by or shared with a third party. Property owners are required to <br />protect tenants’ privacy. As such there is no point at which a property owner would provide the information requested <br />by the city and should not be compelled to do so.  <br /> <br />Fifth, both federal and state laws dictate that property owners must provide tenants with copies of the documents <br />related to their tenancy. Accordingly, the city’s request for documents that must be provided to tenants includes all <br />documents related to those agreements.  <br /> <br />Functionally, the registry requires that all this information be entered to proceed, and the system does not allow <br />incomplete submissions.  <br />1 <br /> <br />