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October 31, 2023 <br />VIA EMAIL <br />City Council Members <br />22 Civic Center Plaza <br />Santa Ana, CA 92701 <br />Email: ��`-oRiR: tl.!.%�>,.�.2p2.:::::. <br />Paul Beard II <br />Partner <br />paul.bear& isherbroyles.com <br />Direct: 818-216-3988 <br />453 S Spring Street, Suite 400-1458 <br />Los Angeles, CA 90013 <br />www.FisherBroyles.com <br />Re: Nov. 7, 2023 Council Meeting / Discussion of Rent Re2istry <br />Dear City Council Members, <br />We represent a coalition of landlords and tenants in the City ("Coalition") that strongly <br />opposes the City's burdensome —and illegal —"rent registry" requirements, as codified in the <br />Santa Ana Municipal Code sections 8-3160, et seq., and as implemented by the City's Rental <br />Housing Board and Program Administrator (collectively, "Administrator"). <br />Landlords were informed that they would be required to provide sensitive and nonpublic <br />information to the City as part of their "rent registry" obligations. The demand for this information <br />is patently unconstitutional and, in some cases, violates the plain terms of the code. To avoid legal <br />action, the City Council should amend the law (as explained below) and direct the Administrator <br />to (1) immediately cease and desist from requiring landlords to divulge any and all nonpublic <br />information, and (2) purge all received information. <br />I. <br />Background <br />On August 15, 2023, the City of Santa Ana launched the rental registry program. Pursuant <br />to the Municipal Code sections 8-3160, et seq., all landlords in the City must complete and submit <br />a registration form for each rental unit no later than December 31, 2023. Section 8-3160(g) <br />specifies the contents of the required registration form: "1) Address of each Rental Unit including <br />identifying number or letter; 2) Number of bedrooms and bathrooms in the Rental Unit; 3) Name, <br />current address, and contact information of current Owners, authorized representatives and <br />property managers; 4) Date of assumption of ownership by current Owners; 5) Current Rent; 6) <br />Date and amount of last Rent Increase; and 7) Move -in date of current Tenant(s)." Notably, the <br />law does not require collection and reporting of tenants' personal information. <br />However, in addition to the items of information listed above, the law requires a landlord <br />to upload, through the City's "rent registry" portal, "[a]ny notices or documents required to be <br />