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Ms. Bennett October 3,2006 Page 2 The City shall issue a rental registration certificate to the property owner of each registered unit. The property owner must conspicuously post �he certificate in the main entry way or other conspicuous location of the rental property. Section 907. 03 — Regist�ation Requi�ements Section 907.03 provides that it is unlawful for a person to rent property for which an application for registration has not been filed. The draft Ordinance, however, does not state that it is unlawful for a person to rent property after the time that a registration has been suspended or revoked. We are assuming that the City intends to make it a violation if an owner rents the property after the registration has been suspended or revoked. Based on that assumption, we have added language to Section 907.03 to address this situation. Section 907.03 states, in relevant part, that "�i]nitial registration and renewal shall be made upon forms furnished by the City." The draft Ordinance, however, does not include a process for �he renewal of a registration. If the City intends for property owners to pay a registration fee on an annual, biannual, or some other periodic basis, we suggest that the process be set forth in the Ordinance. For example, the following language could be used: Rental property registrations shall be renewed [INSERT: annually, biannually, or selected time period] with a registration fee established by resolution of the city council to be paid by the owner of the rental property so registeredby January 1 of each year. Registration fees are not prorated and are the sole responsibility of the owner of each unit as of January 1 each year. Rental property registration shall be effective from January 1 through December 31 [INSERT: each year, each two-year period, or selected time period]. If the City does not intend to have a renewal process, then the word "renewal" should be struck from Section 907.03. Section 907. OS — Manne� of Regist�ation Section 907.05 states that initial application for registration of property which is not registered as residential rental property on the effective date of the Ordinance must be made by filing an application for registration before the property is used as residential rental property. The section does not provide a grace period for property owners who currently rent "residential rental property" as defined by the Ordinance but who are not currently required to register the property. In accordance with the current language, such property owners would ha�e to quit using the property as residential rental property until they have personally filed the registration