What does the City of LA require before I sell my apartment building?
Inside City of Los Angeles limits, the seller of an apartment building must order LADBS's Residential Property Report, also called the 9A, for $70.85 per parcel and deliver it to the buyer before the agreement of sale or the close of escrow. The 9A application carries a sworn declaration on six items, including smoke and carbon monoxide detectors and seismic gas shut-off valves, and LADWP needs a Certificate of Compliance for the toilets, showerheads and urinals before close of escrow. State and federal rules add a water heater bracing certification and, for housing built before 1978, a lead-paint disclosure. Above four units the Transfer Disclosure Statement drops away, but the duty to disclose flood, fire and earthquake hazards does not.
Answered by Shaya Lowenstein, a Los Angeles multifamily broker at Lyon Stahl Investment Real Estate, CA DRE 01942326, with 15 years in apartment buildings and land across Los Angeles County. His closed sales are published with addresses and recording dates, so anything claimed here can be checked against the county record.
| Item | Which buildings | Deadline | Code |
|---|---|---|---|
| Residential Property Report (Form 9, the 9A) | Any residential property inside City limits, one report per parcel | Delivered to the buyer before the agreement of sale or close of escrow; reusable for six months after issue | LAMC 96.300 |
| Water conservation devices and LADWP Certificate of Compliance | All property sold in the City | Fixtures before close of escrow; certificate filed before close of escrow and no more than 15 days after the inspection | Ordinance 172075, LAMC 122.03 |
| Security lighting and locks | Apartment buildings of three or more dwelling units | Declared on Form 9; the buyer's section has no later-install option | LAMC 91.8607 |
| Seismic gas shut-off or excess flow valve | Any building with fuel gas piping | Declared on Form 9; a buyer who takes it over must install it before the agreement of sale or close of escrow | LAMC 94.1217 on Form 9; 94.1216.2 in IB P/GI 2026-002 |
| Smoke detectors | Each sleeping room and the corridor serving it; hard-wired with battery backup at three or more units | Before the agreement of sale or close of escrow, or by the buyer within 30 days after close of escrow | LAMC 91.8603 |
| Carbon monoxide devices | Units with a fossil-fuel heater or appliance, fireplace or attached garage | Same as smoke detectors | LAMC 91.420.6.2.3 |
| Impact glazing or approved film on sliding glass doors | Sliding-type doors other than wardrobe, shower and French-type wooden doors | Same as smoke detectors | LAMC 91.6101 and 96.302 |
| Bars, grilles or shutters over sleeping-room escape windows | Sleeping rooms below the fourth story | Declared on Form 9; release must open from inside without a key | LAMC 91.1029 |
Source: LADBS, Application for Report of Residential Property Records and Pending Special Assessment Liens (Form 9) with Declarations Attachment; LADBS, Requirements When Selling; LADBS, Information Bulletin P/GI 2026-002, Regulations for Permits to Alter, Repair, or Add to an Existing Building or Sale of Existing Building (revised 08-03-2026); LADWP, Water Conservation & Ordinance (Retrofit on Resale Ordinance); LADWP, Certificate of Compliance, Municipal Water Conservation Ordinance (form revised 8/2/13); City of Los Angeles Ordinance 172075, LAMC 122.00 to 122.10, Water Closet, Urinal and Showerhead Regulations (approved June 15, 1998, as linked by LADWP)
| Filing | Building | Fee |
|---|---|---|
| LADBS Residential Property Report | Each parcel | $70.85 |
| LADWP Certificate of Compliance | Single-family dwelling, duplex or condominium | $15.00 |
| LADWP Certificate of Compliance | Triplex or apartment building, 1 to 3 floors | $25.00 |
| LADWP Certificate of Compliance | Apartment building, 4 to 9 floors | $50.00 |
| LADWP Certificate of Compliance | Apartment building, 10 floors | $75.00 |
| LADWP Certificate of Compliance | Apartment building, over 10 floors | $75.00 plus $5 per additional floor |
Source: LADBS, Application for Report of Residential Property Records and Pending Special Assessment Liens (Form 9) with Declarations Attachment; LADBS, Residential Property Report (LAMC 96.300); LADWP, Certificate of Compliance, Municipal Water Conservation Ordinance (form revised 8/2/13)
| Disclosure | One to four units | Five or more units | Law |
|---|---|---|---|
| Transfer Disclosure Statement | Required, with exemptions such as court-ordered transfers and foreclosure sales | Not required by 1102.3, which the Department of Real Estate describes as a one-to-four-unit rule | Civ. Code 1102.3 |
| Natural hazards (flood, fire, earthquake fault and seismic hazard zones) | Disclosed on the statutory Natural Hazard Disclosure Statement | Still disclosed, whatever the building's age | Civ. Code 1103 for the statement (1 to 4 units); PRC 2621.9 and 2694 for fault and seismic hazard zones |
| Homeowner's Guide to Earthquake Safety | Homes built before 1960 of conventional light-frame construction | Not used; the Commission's commercial guide covers 5 or more units | Gov. Code 8897.1 to 8897.5 |
| Commercial Property Owner's Guide to Earthquake Safety | Masonry building with wood-frame floors or roofs built before January 1, 1975, together with the Homeowner's Guide | Built before 1975 with precast (tilt-up) concrete or masonry walls and wood-frame floors or roofs | Gov. Code 8893.2, 8875.6 |
| Water heater bracing certification | Required, in writing | Required, in writing | H&S Code 19211 |
| Plumbing-fixture disclosure, buildings built on or before January 1, 1994 | One unit: Civil Code 1101.4. Two to four units: Civil Code 1101.5 | Civil Code 1101.5 | Civ. Code 1101.2 to 1101.9, as enacted by SB 407 (2009), including the 1101.9 local-ordinance exemption |
| Lead-based paint disclosure | Housing built before 1978 | Housing built before 1978 | 40 CFR 745 Subpart F |
Source: California Department of Real Estate, Reference Book, Chapter 20: Basic Contract Provisions and Disclosures in a Residential Real Estate Transaction; California Seismic Safety Commission, Homeowner's Guide to Earthquake Safety (2020 edition); California Seismic Safety Commission, Commercial Property Owner's Guide to Earthquake Safety (2022 edition); California Seismic Safety Commission, Earthquake Safety Guides (which guide covers which buildings); California Legislature, Senate Bill 407 (2009), Chapter 587, chaptered text adding Civil Code 1101.1 to 1101.9; eCFR, 40 CFR Part 745 Subpart F, Disclosure of Known Lead-Based Paint and/or Lead-Based Paint Hazards Upon Sale or Lease of Residential Property (version of 2026-09-30)
The Residential Property Report, or 9A.
LAMC 96.300 requires the seller of residential property inside the City of Los Angeles to apply for a Report of Residential Property Records and Pending Special Assessment Liens and to deliver it to the buyer before entering into the agreement of sale or before close of escrow. LADBS calls it Form 9 or the RPR, and the Bureau of Engineering's permit manual calls it the 9A report. Residential property means any parcel with a building used, or legally permitted to be used, in whole or in part for dwelling units, so the definition reaches apartments over ground-floor stores as well as a plain apartment building. The fee is $70.85 per report, paid with the paper Form 9 or through LADBS's online Residential Property Report System. LADBS wants a separate application and fee for each parcel and one Assessor Number per report. A report can be reused for six months after it is issued, but the seller still has to deliver a copy to the buyer. Once any work has been done on a request, LADBS warns that a refund may not be available, and that includes duplicate and canceled requests. Two cases need no report: property exempt from tax under the state Documentary Transfer Act, and the first sale of a residential building in a subdivision whose final map was recorded not more than two years earlier, other than a condominium conversion. Before applying, LADBS tells applicants to confirm the address is inside the City, for example by checking whether the seller has a current LADWP bill.
What the City Engineer's half of the report covers.
The 9A is two reports in one. Under LAMC 96.302 the owner or agent obtains a report of the Superintendent of Building and a report of the City Engineer, with contents set by LAMC 96.304. The Bureau of Engineering's manual lists the City Engineer's half item by item. It covers estimated pending special assessment liens for public improvements where the City Council has adopted an ordinance of intention, pending assessment liens for public maintenance of private streets, pending weed clearance liens, notices of record to repair sidewalks, Fire Department brush abatement orders, all recorded assessment liens known to the City Engineer except street lighting maintenance liens, applications for essential public utilities assessments, and whether a house sewer connection permit has been issued. When an item shows as not clear, the Bureau tells the customer to contact the department responsible for it, and it notes that LADBS may not update the system right away. Order the report before listing. A lien or a sewer-permit question found then is an errand to a City office, and the same question found in escrow lands in closing week.
The declarations, and which items a buyer can take over.
Form 9 comes with a Declarations Attachment that cannot be reworded or altered, and the owner signs it under penalty of perjury. Its first part covers six items: water conservation devices, security lighting and locks, seismic gas shut-off or excess flow valves, bars or grilles over sleeping-room escape windows, smoke and carbon monoxide detectors, and impact glazing or approved film on sliding glass doors. Every owner also completes a second part stating whether the parcel is over one acre and, if it is, how many protected trees are on it. The owner certifies that the detectors and the door glazing will be installed before the agreement of sale or the close of escrow, and promises to tell LADBS in writing within 10 days after installation. If the owner cannot complete every declaration, the buyer completes a buyer's section. That section lets the buyer take on the smoke and carbon monoxide detectors and the door glazing within 30 days after close of escrow. The buyer can also take on the gas valve, but its deadline stays before the agreement of sale or the close of escrow, and a buyer who misses it owes a noncompliance fee on top of other penalties. For water conservation devices and security lighting, the buyer's section offers only 'have been installed' or, for lighting, that the rule does not apply, so a buyer cannot take those two over on the form. The owner's section also authorizes LADBS to enter the property to verify the declarations, and LADBS charges a fee for any inspection needed to verify them. Settle which party takes which item in the purchase contract, before either one signs the attachment.
The devices LADBS lists, and why each one is permit work.
LADBS's selling page says all apartment buildings, meaning three or more dwelling units, shall be provided with security lighting and locks under LAMC 91.8607. That means exterior lighting in parking areas, walkways, recreation areas and at the entrance of each unit, interior lighting in recreation or service rooms and parking garages, and locks on all doors and windows leading into each unit. Smoke detectors go on the ceiling or wall of each sleeping room and of the corridor serving those rooms, and on each story or basement of a unit. In buildings of three or more units they must be hard-wired with battery backup, though hard-wired detectors installed before May 11, 1999 need no backup. Each unit with a fossil-fuel heater or appliance, a fireplace or an attached garage needs a carbon monoxide device approved by the State Fire Marshal and listed to UL2034. Any building with fuel gas piping needs a seismic gas shut-off valve or an excess flow valve. Form 9 and the selling page cite LAMC 94.1217 for it, and LADBS's 2026 bulletin cites 94.1216.2. Every sliding glass panel in a sliding door, other than wardrobe doors, shower doors and French-type wooden doors, needs impact hazard glazing or an approved film. Bars or grilles over the escape window of a sleeping room below the fourth story are allowed only with a release that opens from inside without a key, special knowledge or effort, and only in a building that has smoke detectors. LADBS's bulletin says security bars, permanently wired smoke detectors, gas shutoff valves and added light fixtures each need a permit and are subject to inspection. Hard-wiring detectors across a whole building is permit work with an inspection to schedule, so start it before the listing goes live.
LADWP's retrofit on resale.
LADWP says all residential and non-residential property sold in Los Angeles must comply with Ordinance 172075, which requires owners to upgrade indoor water fixtures before close of escrow. LADWP links the 1998 text of that ordinance, and later amendments to it are not covered here. In that text every urinal must have a flushometer valve of no more than one and one-half gallons a flush, every showerhead must be a low-flow model of no more than 2.5 gallons a minute, and from January 1, 1999 every toilet in a residential property must be a low consumption model, all before the agreement of sale or the close of escrow. LADBS's bulletin puts the low consumption toilet at an average of 1.6 gallons a flush. LADWP's certificate says residential properties must have ultra-low flush toilets before close of escrow, and that the certificate and fee must be filed with LADWP no more than 15 days after the inspection. The 1998 text also requires the seller to give the buyer written notice of these requirements and confirmation of compliance in the agreement of sale. The certificate has one signature line for a C-36 plumbing contractor, a B general contractor, a certified retrofitter or a real estate agent or broker, and lines for the seller and the buyer. The 1998 text is narrower for large buildings. It lets a broker or agent sign for a multi-family building only when it has 10 or fewer units, and a certified retrofitter only when it is three stories or fewer, so ask LADWP's Account Services Unit, (213) 367-9263 on the form, who may sign for a building over 10 units. The same text caps the charge for inspecting apartment units and certifying compliance at $25 per dwelling unit, and it bars an RSO landlord from recovering compliance costs through a rehabilitation or capital improvement rent adjustment. It also sets a surcharge on the water charges of a multi-family owner, meaning three or more units, who has not complied: 10% after 182 days, rising to 25% after 365 days, 50% after 547 days and 100% after 729 days. Each owner's compliance date runs from the day that owner takes title, so a buyer has reason to want the certificate filed before closing.
Civil Code 1101.5, and whether it reaches a Los Angeles sale.
Two Civil Code sections govern old plumbing fixtures at sale, and the one that reaches an apartment building is Section 1101.5. As SB 407 enacted the article in 2009, Section 1101.4 covers single-family property, a building of not more than one unit, and multifamily property is a building with more than one unit, so even a duplex falls under Section 1101.5. The article applies to property built and available for use on or before January 1, 1994, and excludes registered historical sites, property where a licensed plumber certifies that water-conserving fixtures are not technically feasible, and buildings whose water service is permanently disconnected. As enacted, Section 1101.5 required every noncompliant fixture in multifamily property to be replaced by January 1, 2019, and from that date requires the seller to disclose in writing that requirement and whether the property still has any noncompliant fixtures. The disclosure can sit inside other transaction documents. The noncompliant list is a toilet made to use more than 1.6 gallons a flush, a urinal made to use more than one gallon, a showerhead with a flow capacity over 2.5 gallons a minute and an interior faucet over 2.2 gallons a minute. Section 1101.9, as enacted, exempts a city that adopted an ordinance requiring retrofit of noncompliant fixtures before July 1, 2009, for as long as that ordinance stays in effect, and the City's retrofit-on-resale ordinance was approved June 15, 1998. Nothing in the bill or in the City pages cited here says whether that exempts a City of Los Angeles sale, so ask a real estate lawyer before leaving the disclosure out. If the state rule does apply, a filed LADWP certificate does not answer it by itself, because the City's 1998 text allows urinals up to one and one-half gallons and does not mention faucets.
Lead paint, water heaters and masonry buildings.
Federal lead disclosure applies to housing built before 1978 with no limit on unit count. It exempts housing for the elderly or persons with disabilities and any 0-bedroom dwelling, studios included, unless a child under 6 lives there or is expected to, and it does not apply to a sale at foreclosure. Before the buyer is bound, the seller hands over an EPA-approved pamphlet, discloses any known lead-based paint or hazards, and provides every available report, including reports on common areas and on other units when they were part of an evaluation of the building as a whole. The buyer gets 10 days to inspect unless the parties agree in writing on a different period or the buyer waives it in writing. The contract carries a signed attachment with the federal Lead Warning Statement, and the seller and any agent keep a copy for at least 3 years. The rule does not make the seller test, but a knowing violation makes the seller liable for 3 times the buyer's damages. Both of the state's earthquake safety guides, citing Health and Safety Code 19211, say water heaters must be anchored or strapped to resist falling in an earthquake and the seller must certify to the buyer that the water heater is properly braced. The Department of Real Estate describes that certification as written, given in the contract or another transaction document. The Commercial Property Owner's Guide adds a rule for older buildings. The seller of a building built before 1975 with precast (tilt-up) concrete or masonry walls, reinforced or unreinforced, and wood-frame floors or roofs must give the buyer a copy of that guide as soon as practicable before the transfer.
What drops away above four units, and what stays.
The Department of Real Estate describes the Transfer Disclosure Statement under Civil Code 1102.3 as a duty of a seller of one to four residential dwelling units. The Seismic Safety Commission writes its Homeowner's Guide to Earthquake Safety for single-family homes, duplexes, triplexes and fourplexes, and the duty to deliver it reaches homes built before 1960 with one to four units of conventional light-frame construction. Its Commercial Property Owner's Guide is written for commercial buildings and residential buildings with five or more units. None of that frees a five-unit seller from disclosure. The commercial guide says a seller, whatever the building's age, must disclose natural hazards that can affect the property, including flood, fire and earthquake hazards, and it names the Alquist-Priolo earthquake fault zones and the seismic hazard zones for landslides and liquefaction. It says its own Commercial Property Earthquake Risk Disclosure Report can be used to meet the seismic hazard zone requirement. This page does not cover what else a seller of five or more units must disclose about a building's condition, and that is a question for a real estate lawyer.
What this page leaves to other guides.
When LADBS serves a soft-story or non-ductile concrete retrofit order it files a certificate with the County Recorder, and the ordinance says transfer of title does not change the compliance dates, so the order is on the public record and its deadlines do not reset for a buyer. The City's base transfer tax applies to every document that conveys property in the City, and Measure ULA adds a further tax above a price threshold, which the ULA guide covers with its rates. Everything on this page from LADBS and LADWP applies inside City of Los Angeles limits only, so for a building in another city, ask that city's building department what it requires at sale.
EDUCATIONAL ONLY, NOT LEGAL OR TAX ADVICE. RATES, THRESHOLDS AND ORDINANCES CHANGE, AND SEVERAL OF THE FIGURES HERE DEPEND ON FACTS SPECIFIC TO YOU. CONFIRM ANYTHING YOU PLAN TO ACT ON WITH YOUR OWN ATTORNEY OR CPA, OR WITH THE AGENCY THAT SETS IT.
/// SOURCES
- LADBS, Application for Report of Residential Property Records and Pending Special Assessment Liens (Form 9) with Declarations Attachment
- LADBS, Residential Property Report (LAMC 96.300)
- LADBS, Requirements When Selling
- LADBS, Information Bulletin P/GI 2026-002, Regulations for Permits to Alter, Repair, or Add to an Existing Building or Sale of Existing Building (revised 08-03-2026)
- City of Los Angeles Bureau of Engineering, Permits Manual, Technical Procedure 03: Form 9 (Residential Property Reports) Processing (revised 06-12-2024)
- LADWP, Water Conservation & Ordinance (Retrofit on Resale Ordinance)
- LADWP, Certificate of Compliance, Municipal Water Conservation Ordinance (form revised 8/2/13)
- City of Los Angeles Ordinance 172075, LAMC 122.00 to 122.10, Water Closet, Urinal and Showerhead Regulations (approved June 15, 1998, as linked by LADWP)
- California Legislature, Senate Bill 407 (2009), Chapter 587, chaptered text adding Civil Code 1101.1 to 1101.9
- California Department of Real Estate, Reference Book, Chapter 20: Basic Contract Provisions and Disclosures in a Residential Real Estate Transaction
- California Seismic Safety Commission, Earthquake Safety Guides (which guide covers which buildings)
- California Seismic Safety Commission, Homeowner's Guide to Earthquake Safety (2020 edition)
- California Seismic Safety Commission, Commercial Property Owner's Guide to Earthquake Safety (2022 edition)
- eCFR, 40 CFR Part 745 Subpart F, Disclosure of Known Lead-Based Paint and/or Lead-Based Paint Hazards Upon Sale or Lease of Residential Property (version of 2026-09-30)
- City of Los Angeles Ordinance 183893, soft-story and non-ductile concrete retrofit (LAMC 91.9305, 91.9306.6, 91.9505.6), City Clerk copy
- LA Office of Finance, Real Property Transfer Tax and Measure ULA FAQ
Do I need a 9A report for an apartment building, or only for a house?
You need one for an apartment building inside City of Los Angeles limits. Form 9 defines residential property as any parcel with a building used, or legally permitted to be used, in whole or in part for dwelling units. LADBS charges $70.85 per report and wants a separate application and fee for each parcel.
Can I use a 9A report I ordered a few months ago?
Yes, for six months after it was issued. You still have to deliver a copy to the buyer before the agreement of sale or the close of escrow. Past six months, plan on ordering a new one.
Can the buyer take over the smoke detectors and other retrofits?
Some of them. On the Form 9 buyer's declaration, the buyer can take on the smoke and carbon monoxide detectors and the sliding-door glazing within 30 days after close of escrow. The buyer can take on the gas shut-off valve too, but it still has to go in before the agreement of sale or close of escrow, and a buyer who misses that owes a noncompliance fee. The water conservation devices and the security lighting and locks have no later-install option for the buyer.
Do I owe a Transfer Disclosure Statement on a 10-unit building?
Not under Civil Code 1102.3, which the Department of Real Estate describes as a duty of a seller of one to four residential dwelling units. You still owe the buyer the natural hazard disclosures, the written water heater certification, and the lead disclosure if the building was built before 1978. Ask a real estate lawyer what else you owe, including whether the Civil Code 1101.5 plumbing-fixture disclosure applies to a City of Los Angeles sale of a building built on or before January 1, 1994.
Does lead disclosure apply to a large apartment building?
Yes, if it was built before 1978. The federal rule covers housing built before 1978 with no unit-count limit. Its exceptions are housing for the elderly or persons with disabilities and 0-bedroom dwellings such as studios, unless a child under 6 lives there or is expected to. Reports on common areas, and on other units when they were part of a building-wide evaluation, go to the buyer too.
What should I do first if I plan to list in the next few months?
Order the 9A, since it stays usable for six months and anything not clear on its lien report has to be cleared with the department that placed it. Walk the building against the device list, because hard-wired smoke detectors, gas valves, security bars and added light fixtures each need an LADBS permit and inspection. Schedule the LADWP inspection so the certificate reaches LADWP within 15 days of it and before close of escrow. Then collect any lead reports, check the water heater straps and settle whether the Civil Code 1101.5 fixture disclosure applies, so the offering package carries them from the first day.
SHAYA LOWENSTEIN · LYON STAHL INVESTMENT REAL ESTATE · DRE #01942326 · (323) 944-2221