Washington Rental Registry Study — Report to the Legislature (Commerce, January 2024)
Summary
Washington Rental Registry Study, a report to the Legislature from the Washington State Department of Commerce dated January 2024, with a cover letter dated January 12, 2024. The study responds to a proviso in the 2023 operating budget (Section 129 of ESSB 5187) directing Commerce to report on the scope of work, cost estimates and implementation timeline for an online registry of rental units. It states that HR&A Advisors estimate it would take two years to implement a rental registry program, and that the program is estimated to cost anywhere from $3.9 – $6.4 million annually depending on design decisions. It states that Commerce does not make any recommendations about a potential state rental registry.
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“Washington Rental Registry Study — Report to the Legislature (Commerce, January 2024).”
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STATE OF WASHINGTON
DEPARTMENT OF COMMERCE
1011 Plum Street SE PO Box 42525 Olympia, Washington 98504-2525 360-725-4000
www.commerce.wa.gov
January 12, 2024
Ms. Sarah Bannister, Secretary of the Senate
312 Legislative Bldg.
PO Box 40482
Olympia, WA 98504-0482
Mr. Bernard Dean, Chief Clerk of the House of Representatives
338B Legislative Bldg.
PO Box 40600
Olympia, WA 98504-0600
Subject: Washington State Rental Registry Study
Enclosed is the study on a potential rental registry program in Washington conducted in response to the
proviso outlined in the 2023 operating budget.
To complete this study, Commerce contracted HR&A Advisors and Artesia Systems. The work was
shaped by stakeholder engagement, including input from local government representatives, housing
providers, and members of the public. HR&A Advisors led the analysis, while Artesia Systems provided
technical expertise for evaluations of an internally hosted software solution and survey of external
software solutions.
This report provides detailed information on potential costs, implementation timelines and scopes of work
for a statewide rental registry and one for the six most populous counties only. The report does not
advocate for or against creating a rental registry. Its sole purpose is to provide the information requested
in the proviso. Commerce does not make any recommendations about a potential state rental registry.
Key findings:
• A rental registry as described in the proviso would be first in the nation as it describes collecting
unit level and timely data.
• Existing local rental registries focus on specific objectives such as housing quality or business
licensure. Only two of the 17 existing registries in Washington collect rent amount data.
• Successful registries have a clear policy purpose, robust administrative support and enforcement
mechanisms.
Cost and timeline estimates and considerations:
• HR&A Advisors estimate that it would take two years to implement a rental registry program
with stabilization of the program reached ten years after initial launch.
• Depending on program design decisions it is estimated that the rental registry program will cost
anywhere from $3.9 – $6.4 million annually.
• Statewide implementation would be costlier but provides comprehensive coverage. Limiting
implementation to six large counties could reduce costs by 20–25%.
• Cost-reduction strategies, like multi-year registration cycles, could lower expenses but risk
reduced data quality and compliance.
Signed,
Tedd Kelleher
Acting Co-Assistant Director
Housing Division
Washington rental registry
study
Per Section 129 of the 2023-25 operating budget
January 2024
Report to the Legislature
HOUSING POLICY AND
STRATEGIC INITIATIVES UNIT Interim Director Diane Klontz
v3.5.1
Acknowledgments
Washington State Department of Commerce
Tedd Kelleher, Acting Co-Assistant Director,
Housing Division
Kirsten Jewell, Acting Director of Policy, Housing
Division
Augustine Sughrua, Housing Policy Senior
Coordinator, Housing Division
HR&A Advisors, Inc.
Judith Taylor, Partner
Jonathan Meyers, Partner
Sarah Kirk, Principal
Benjamin Cole, Senior Analyst
Francis Goyes Flor, Senior Analyst
Austin Amandolia, Analyst
Nisha Singh, Research Analyst
1011 Plum St. SE
P.O. Box 42525
Olympia, WA 98504-2525
www.commerce.wa.gov
For people with disabilities, this report is available on
request in other formats. To submit a request, please
call 7-1-1 and ask to be connected to 360-725-4000.
WASHINGTON RENTAL REGISTRY STUDY 2
Table of contents
Executive summary .........................................................................................................................................4
Introduction ....................................................................................................................................................7
Rental registry design ...................................................................................................................................10
Integration with existing registries ................................................................................................................16
Implementation timeline ...............................................................................................................................18
Cost estimates ..............................................................................................................................................19
Stakeholder engagement ..............................................................................................................................23
Appendix A: Detailed program design considerations ...................................................................................25
Appendix B: Stakeholder engagement summary ...........................................................................................45
Appendix C: Rental registry case studies ......................................................................................................55
Appendix D: Overview of existing rental registries.........................................................................................72
Appendix E: Rental housing market scan.......................................................................................................84
Appendix F: Program implementation timeline ..............................................................................................94
Appendix G. Rental registry financial requirements .......................................................................................98
Appendix H: Artesia report on technical requirements and considerations ..................................................113
WASHINGTON RENTAL REGISTRY STUDY 3
Executive summary
Overview
A rental registry is a program that creates an inventory of rental housing. At its most basic, a rental registry
collects information about rental housing. This can include information about the number and location of
rental homes; market data including housing type and cost; and information about the quality of homes.
Rental registries can produce data to support decisions and programs that help renters. In recent years, rents
have been rising across Washington, increasing affordability challenges for many renters. The state has
approximately 1,076,000 renter-occupied homes. Across regions, renters’ incomes are significantly lower than
the median income, and there are significant disparities in rentership by race.
Statutory authority
In 2023, the Washington State Legislature included a proviso in its operating budget (Section 129 of ESSB
5187) directing the Department of Commerce (Commerce) to develop a report and recommendations to create
or procure a registry of rental units. This report satisfies the requirements of the proviso:
Proviso - Section 129: (82) $215,000 of the general fund—state appropriation for fiscal year 2024 and $345,000 of
the general fund—state appropriation for fiscal year 2025 are provided solely for the department to produce a report
to the legislature detailing the scope of work, cost estimates, and implementation timeline to create or procure an
online registry of rental units in Washington state subject to state information system planning and oversight
requirements. The online rental unit registry must have the capacity to collect and report out timely information on
each rental unit in the state. Information to collect includes, but is not limited to, the rental unit's physical address,
identity of the property owner, monthly rent charged, and vacancy status. The scope of work must assume
integration with existing rental registries operated by local governments. Cost and timeline estimates must provide
two alternatives with one assuming statewide implementation and the other assuming implementation in the six
largest counties of the state. The department shall consult with landlord representatives, tenant representatives,
local governments operating existing rental registries, and other interested stakeholders as part of the process of
developing the scope of work and timeline for the online rental unit registry. The department must submit the report
to the legislature by December 1, 2024.
Key findings
A registry of all rental units in the state, such as the one described in
the proviso would be the first of its kind in the nation
The proviso describes a program that collects and reports timely unit-level data for all rental properties. It does
not specify a purpose for the data or for the proposed rental registry. Existing state-wide rental registries are
narrow in scope; they apply to a limited number of properties and support a specific objective, such as
abatement of lead paint.
Cost estimates and implementation timelines
Implementing and operating a state rental registry such as the one the proviso describes requires significant
staffing, infrastructure, and investment.
WASHINGTON RENTAL REGISTRY STUDY 4
Timing: Implementation of the rental registry program will require several years to build staff capacity,
program infrastructure, and public awareness. We estimate a two-year pre-launch phase to conduct
outreach and build capacity, followed by a two-year launch phase to begin operations and pursue
compliance through outreach and enforcement. The program would begin to reach stabilization in costs
and in compliance rate five years from initiation,
Cost: To secure high participation, a statewide program would require between about $3.9 and $6.4
million annually. Major categories of program cost include management and oversight of the program;
research and information technology (IT) requirements, including data storage, data management and
analysis, and reporting; outreach, marketing, and enforcement; and overhead. Program revenues may
offset many or all of these costs, but program revenue will be highly dependent on achieving compliance
through an extensive marketing, outreach, and enforcement effort. The program's ability to achieve cost
self-sufficiency through registration fees depends on the number of registrations and the fee per
registration. Financial stabilization is projected within five years of the program's initiation, assuming
approximately 75% compliance. At a $15 registration fee, program costs would be fully covered, with the
breakeven point potentially occurring earlier, as only 50% compliance is required. In contrast, a $10
registration fee would necessitate 80% compliance for self-sufficiency. If the registry were limited to the
six largest counties, the breakeven point would remain comparable.
Implementation geography: Implementation limited to the six largest counties would reduce pre-launch
and launch timelines by 3 to 6 months. It would reduce application volume and create efficiencies
resulting in a 20% to 25% reduction in cost. The six largest counties together account for approximately
74% of renter-occupied homes in the state. However, this option would exclude many parts of the state,
including much of central and western Washington and many rural areas.
Cost reduction strategies: There are a few options the state could pursue to reduce the cost of a rental
registry, with tradeoffs for data quality and effectiveness. These include requiring registration on a multi-
year cycle instead of annually, which would limit the timeliness of data, or minimizing staffing for data
analysis and outreach and enforcement, which would significantly reduce compliance and could reduce
the program’s financial sustainability. As another option, the state could minimize costs by pursuing a
data collection initiative focused on understanding specific rental market conditions and trends.
Stakeholder engagement
Engagement with a broad range of stakeholders through listening sessions and interviews provided valuable
input for the design of a state rental registry and context about the operations and perceptions of existing local
rental registries. Stakeholder input shaped the design recommendations and conclusions of this report.
Key stakeholder groups:
Tenants and their advocates find merit in a rental registry if it results in better housing quality or
transparency about property ownership and note that some existing registries have limited
effectiveness.
State and local government staff see value in producing detailed housing data and improving
communication with housing providers. Operators of existing rental registries prefer to retain their
programs but are open to sharing data with the state.
WASHINGTON RENTAL REGISTRY STUDY 5
Housing providers generally oppose a state rental registry. They see no value in added regulation and
view a new program as government overreach.
Best practices, opportunities and recommendations for a rental registry
in Washington
The most effective city- and county-level rental registries have a clear policy purpose, as well as large
administrative structures and enforcement measures. The rental registries that have the highest compliance
rates typically have been in operation for many years, have adequate staffing to support enforcement, and
have clear and costly penalties for noncompliance. These programs generally support the enforcement and
implementation of other housing policies or programs beyond data collection.
Compliance mechanisms that include incentives as well as regulatory or financial penalties, coupled with
enforcement, will be critical to achieving participation. The most effective rental registry programs set and
enforce clear penalties that make non-compliance expensive and burdensome for property owners and have a
regulatory mechanism by which they can compel compliance. For example, in Minneapolis, the city can attach
unpaid fees and penalties to the property’s tax bill. For properties that continue to be noncompliant, the city in
some cases can revoke the owner’s rental license for the property. In Washington, the state does not currently
have a regulatory relationship with all rental property owners and would have to create one to enable
enforcement, which may entail further discussion of policy implications for ongoing implementation and
maintenance of a rental registry.
The design of a rental registry program must also consider how best to meet its purpose while mitigating
unintended consequences. The purpose of a rental registry should inform the design of the program including
the types of data collected and the structure and implementation of the registry. The design of the program
will drive both the cost to operate it and its effectiveness at achieving the intended purpose. Cost and
effectiveness are also directly linked; a registry with low operating costs is likely to have limited enforcement
and low compliance. To ensure that the program does not increase affordability challenges for renters or
exacerbate existing inequities, minimizing costs to property owners – and by extension renters – should be a
design objective. This is particularly true if the rental registry does not support tenant protections.
Integrating data from existing rental registries will be possible, but incomplete. There are 17 cities in
Washington with existing rental registries, covering approximately 40% of rental homes in the state. These city-
level programs focus on ensuring housing quality. Only two collect data on rent, and most collect property-level
(rather than unit-level) data. Making changes to existing registries to accommodate unit-level data collection
would not be feasible. Most city programs collect data via a digital portal and could likely provide data for
integration into a statewide database with some adjustments. However, because most existing registries do
not collect rent or other unit-level data, the proposed program would need to impose a second registration on
some housing providers or lose a significant amount of data.
Introduction
Rental registries collect information about rental housing
A rental registry is a program that creates an inventory of rental housing. At its most basic, a rental registry
collects information about rental housing. This can include information about the number and location of
WASHINGTON RENTAL REGISTRY STUDY 6
rental homes; market data including housing type and cost; and information about the quality of homes. Rental
registries usually require property owners or managers to register any properties they operate as rental homes.
In many cases, registries charge a fee to offset the cost of operating the registry.
Rental registries are distinct from business licenses; however, some rent registry programs require a business
license as part of the registration process. In Washington, some residential rental businesses must obtain a
business license from the Department of Revenue, and many cities and counties in Washington require
business licenses and permits for all rental properties. Business licenses help state and local governments
enforce employment laws and collect taxes, though the state does not collect Business & Occupation (B&O)
taxes for residential rental properties. Business license applications collect business data, but do not collect
housing data.
Effective rental registries serve a specific policy purpose
Rental registries can serve a range of purposes, including informing policy decisions that relate to housing,
enabling engagement with property owners, and supporting regulation in the rental housing market. Though
some are focused on facilitating contact with property owners, such as to support first responders, many
support a specific goal such as enforcing another housing policy or improving housing quality.
A registry that collects detailed market data on all rental units in the state would be the first of its kind. Most
existing rental registries operate at the city or county level, though some state-level rental registries exist.
Existing state rental registries are often narrow in scope. For example, New York State’s rental registry applies
to rent-stabilized properties, and is therefore only applicable to some rental properties located in New York
City. Maryland’s rental registry focuses on lead abatement, so it only applies to older properties. Ohio requires
all counties over a certain size to establish rental registries, but it has limited effectiveness and does not
collect any data at the state level.
Local registries in Washington focus on ensuring the quality and
safety of rental housing
Rents have risen in all parts of Washington, and our housing stock is aging. This creates challenges with
affordability and housing quality. The state has approximately 1,076,000 renter-occupied homes. Across the
state, householders who identify as Black, Hispanic/Latino, Native Hawaiian and other Pacific Islander, or
Some other Race Alone are more likely to be renters than owners, while those who identify as White or Asian
are much more likely to be homeowners. Households who identify as American Indian and Alaska Native or as
Two or More Races are majority homeowners, but more likely to rent than White and Asian households.
Renters’ incomes are significantly lower than the median income. Single-family homes make up the largest
share of renter-occupied homes in each region, and 58% of renter-occupied homes are in buildings with fewer
than 10 units statewide. Renter occupied units also tend to be in buildings built prior to 1979, meaning that
many units are more than 40 years old. Average rents have increased by about 45% since 2015. Much of the
state’s housing stock faces challenges with aging and affordability.
Existing rental registries in Washington all have similar purpose and structure. In Washington, 17 cities,
including several of the largest cities in the state, already operate rental registries to address some of these
challenges. Appendix D provides an overview of existing city-level registries in Washington. The primary stated
purpose of these registries is ensuring that rental housing meets basic safety standards. Some programs state
secondary purposes such as data collection, support for property owners and tenants, support for first
responders, and housing preservation. Of the 17 rental registry programs, 11 require inspections on a recurring
WASHINGTON RENTAL REGISTRY STUDY 7
schedule, three programs allow property owners to self-certify the condition of the property, and three
programs have no inspection requirements at all. Because of the emphasis on inspection compliance and
property condition, data collection focuses on property address and owner information. Only two registries –
Olympia and Tacoma – collect rent data, and Olympia makes rent data voluntary.
Potential design and requirements of a state rental registry
Study background
In 2023, the Washington State Legislature included a proviso in its supplemental operating budget (Section
129 of ESSB 5187) directing the Washington State Department of Commerce (Commerce) to develop a report
and recommendations to create or procure an online registry of rental units in Washington. In spring 2024,
Commerce released a Request for Proposals (RFP) for consultants interested in supporting this work.
Commerce awarded HR&A the contract for a portion of this work, which included four objectives:
Objective A. Draft a comprehensive scope of work for a rental registry in Washington, identifying best
practices, opportunities, and recommendations for the rental registry's scope.
Objective B. Develop timelines for two scenarios: 1) a statewide registry rollout and 2) implementation
limited to the six largest counties.
Objective C. Estimate costs for statewide and county-level implementation, including both initial
implementation costs as well as ongoing expenses.
Objective D. Facilitate stakeholder engagement for the rental registry, including landlord and tenant
representatives, local governments with existing rental registries, and other interested stakeholders.
Artesia Systems' study of technical requirements
Under a separate agreement, Commerce engaged Artesia Systems to deliver several key components for the
online rental registry project. Their responsibilities included creating detailed documentation of both functional
and non-functional requirements for a Commerce-operated system, covering aspects such as data collection
methods, reporting capabilities, user access levels, and security measures. Based on these requirements and
Artesia’s experience with Commerce, they then developed cost estimates and implementation timelines for the
Commerce-operated base rental registry portal. Additionally, they researched external vendors to assess the
potential for procuring existing software solutions for the rental registry platform. Their work, included as
Appendix H of this document, informed our estimates related to cost estimates and implementation timelines.
Methods
To inform this report, HR&A employed a multi-faceted approach that included interviews with key stakeholders,
data analysis, listening sessions, and extensive research. We developed summaries of these methods and the
findings of this analysis in a series of background reports included as appendices to this report.
Appendix A outlines a detailed synthesis of relevant findings from various background reports and their
implications for the design of a rental registry program.
Appendix B provides a detailed summary of engagement activities and stakeholder input.
Appendix C provides an overview of the national case study research.
Appendix D provides an overview of existing city-level rental registries in Washington.
WASHINGTON RENTAL REGISTRY STUDY 8
Appendix E summarizes the methods and findings of this rental market scan.
Appendix F provides additional detail about implementation timelines.
Appendix G provides a more detailed explanation of the cost estimates.
Appendix H is Artesia Systems’ study of requirements for a Commerce-operated software platform.
WASHINGTON RENTAL REGISTRY STUDY 9
Rental registry design
The purpose of a rental registry has critical implications for its
design
Rental registries can serve a number of potential purposes. This could include increasing transparency and
communication with property owners or providing detailed market data and analysis to policymakers at both
the state and local levels to inform investment and policy decisions, or to track progress toward housing goals.
Most rental registries exist to support another larger housing goal or program, such as ensuring that rental
housing meets basic standards of safety and livability or to support tenant protection-focused policy.
The purpose of a rental registry should inform the design of the program including the types of data collected
and the structure and implementation of the registry. In turn, the design of the program will drive both the cost
to operate it and its effectiveness at achieving the intended purpose. Cost and effectiveness are also directly
linked: a rental registry with low operating costs is likely to have limited effectiveness due to low enforcement.
In this study, we consider the cost to create and operate the registry effectively.
The design of a rental registry program must consider how best to meet the goal or policy purpose for its
creation while mitigating unintended consequences, such as creating significant costs or regulatory burdens
which might impact administrators, property owners, and renters. The proviso describes a program that
collects unit-level data for all rental properties. It does not specify a purpose for the data or for the proposed
rental registry.
Program design, cost and effectiveness are closely related
To secure high participation, a statewide program such as the one described in the proviso would require
significant cost and complexity. The primary reason to create such a program would be to support the
implementation of another regulatory program or policy. If the state creates a rental registry, its design should
consider how it might support vulnerable renters’ needs and improve equitable outcomes for Washington
residents.
Outreach and enforcement mechanisms will shape participation
Extensive outreach to property owners will be critical to raise awareness of any rental registry put in place and
its requirements, and to encourage and reduce barriers to participation. Pre-launch and throughout early
operations, the state will need an extensive outreach campaign using direct mail, in-person and virtual
information sessions, partnerships with trade associations and other organizations, and marketing. This will
require significant investment and will require dedicated staff to provide outreach and respond to inquiries.
However, setting and enforcing clear penalties for non-compliance that make non-compliance expensive and
burdensome for property owners is the most impactful way to encourage participation. Though it is important,
outreach alone will not produce high participation in a rental registry. In order to secure compliance, the state
must create and aggressively enforce financial or regulatory consequences for non-compliance.
The rental registries that have the highest compliance rates typically have been in operation for many years,
have adequate staffing to support enforcement, and have clear and costly penalties for noncompliance. For
example:
WASHINGTON RENTAL REGISTRY STUDY 10
Seattle’s Rental Registration and Inspection Ordinance (RRIO) has been in operation since 2014 and has
an estimated compliance rate of about 90%. The Program has approximately nine full-time equivalent
(FTE) employees. The city contacts property owners of likely rental properties by mail and uses other
methods of marketing and outreach to let property owners know about program requirements. People
who receive a notice in error (for instance, owners who are not operating their property as a rental
property) can contact the city by phone or online to notify the city of the error. Property owners that do
not register receive a warning letter followed by a notice of violation letter. Noncompliant properties
accrue penalties of $150 per day for the first 10 days and $500 per day after the first 10 days. The city
Attorney’s office will file lawsuits to compel compliance from noncompliant property owners. The city
uses a portion of time for multiple program staff to pursue the enforcement process (this does not
include time the city Attorney’s office spends pursuing enforcement, or enforcement related to missed
inspections or inspection violations). After registrations fell during the COVID-19 pandemic due to a
suspension of the program, the city hired temporary research staff to investigate properties with lapsed
registrations.
Minneapolis’s Rental License Program has been in operation since 1998 and has an estimated
compliance rate of 92%. The city requires property owners to obtain a rental license for each rental
property they operate and submit to regular inspections. The licensing and inspections program is part
of a large city department and includes about 60 inspectors, analysts who work on the licensing program
and other initiatives, housing liaisons, and a dedicated enforcement team. In addition to providing
incentives for compliance such as reduced fees, the city charges a 25% late fee for rental license
renewals that are more than 15 days late. The city issues $500 citations to properties with unpaid license
fees in addition to the late fee costs. The city increases unpaid citations to $1,000 and assesses them to
property taxes for annual payment. Program staff identifies non-compliant properties through
complaints from the 311 system and property sale records. The city sets aside funds to support
temporary housing solutions for tenants in properties that fail inspections. Minneapolis also conducts
ongoing outreach to inform tenants and housing providers about the license program, including regular
engagement on renter’s rights, local committees with advocate groups, education classes for new
landlords, and door knocking in areas with a high volume of renters.
The state does not currently have a regulatory relationship with property owners, which will create
challenges to effective enforcement. The most effective rental registry programs, such as those described
above, have a particular regulatory mechanism by which they can compel compliance, such as property taxes
or business licenses. The state does not currently have a regulatory relationship with all rental property
owners. Some property owners require business licenses, but many do not. The state does not directly collect
property taxes, and it does not collect Business & Occupation (B&O) tax for residential rental property. To
enable effective enforcement, the state will need to pass legislation creating a regulatory mechanism to
compel compliance or work closely with county governments to attach penalties to property tax bills.
Commerce could also work with the Office of the Attorney General to develop protocols for enforcement.
Increased program complexity increases the cost and is likely to
decrease compliance
The program’s complexity (such as the number of and type of data points and other steps required for
registration) will have impacts on its costs, administrative and IT requirements, compliance, and effectiveness
at meeting its goals. Collecting more data creates more requirements for property owners to accurately track
WASHINGTON RENTAL REGISTRY STUDY 11
and report data, on administrators to support data gathering as well as reporting, and on the required IT
infrastructure to organize, store, and secure data.
Three primary design components each bring a level of complexity and cost to a rental registry program:
1. Collecting data directly from property owners: A rental registry requires significant program administrative
and IT infrastructure, including an online portal and database, outreach and marketing activities, and staff
to oversee these efforts as well as track compliance, respond to requests, and provide other administrative
services. There are other, lower-cost ways to gather data on housing markets, but they do not offer a
mechanism for direct communication to and from property owners.
2. Collecting data at the unit level versus the property level: Collecting unit-level data is more complex than
at the property-level data. Unit-level data would require a more complex IT structure (to manage more
records and track unit-level changes) and more administrative support to provide technical assistance to
property owners, perform data entry, and ensure quality control.
3. Collecting data annually versus on a multi-year cycle: There are more than 1 million rental homes in
Washington. Instead of requiring annual registration for every unit, a rental registry could, for example,
require registration every three years, so that approximately one-third of rental units must register each
year. This would significantly reduce the costs of running the program and the impacts on property owners.
Requiring more detailed data makes compliance burdensome and is likely to create inconsistency and
inaccuracy in reporting. This further suggests that a rental registry should only be as complex as is necessary
for the purpose it serves.
Minimizing costs to property owners – and by extension renters –
should be a design objective
Rental registries typically charge a registration fee to cover the costs of program administration. Rental
registration fees for existing city-level registries in Washington range from about $10 to $50 per unit per year,
excluding the cost of inspections. Housing providers could potentially pass registration fees on to their
tenants, either directly as a fee or indirectly as an increase in rent, though some studies suggest this is not a
common practice. Increasing costs or regulatory burdens for property owners could also lead to some of them
removing housing from the rental market, such as by operating the home as a short-term rental instead of
permanent housing. Because of these risks, a program with a high registration fee has the potential to
exacerbate affordability challenges for renters. Renters in Washington are disproportionately low-income and
people of color. This means that minimizing registration fees, particularly if the registry is not furthering
additional tenant protections, will be a critical component of ensuring that the program does not exacerbate
existing inequity.
In addition, the state would either require property owners that already pay city registration fees to pay a state
registration fee as well, or exempt property owners who pay city registration fees, which could create cost
imbalances between property owners in different districts.
To address these concerns, the state could minimize the registration fees as much as possible.
WASHINGTON RENTAL REGISTRY STUDY 12
Creating a registry requires design decisions with implications for
cost and effectiveness
Below we outline the major design elements that form the scope of work to design a rental registry program,
as well as the preliminary approach to meet the proviso requirements and produce relevant and useful market
data. Appendix A provides a more detailed summary of the relevant considerations, tradeoffs, and alternative
approaches for each design element.
Table 1: Applicability and scale of the rental registry
Design element Preliminary approach
Statewide implementation, or implementation limited to the six largest counties by population (Clark,
Implementation geography
King, Pierce, Snohomish, Spokane, and Thurston)
All types of residential rental housing, regardless of the property type or ownership type, including
mobile homes on a leased pad. Limited exceptions, including:
Owner-occupied homes, including owner-occupied single-family homes, owner-occupied units in
multifamily rental properties, and room rentals in owner-occupied homes.
Rental homes subject to
Short-term rentals, which the state already requires to obtain a business license through the
registration
Department of Revenue.
The registry should allow fee waivers for some properties, such as nonprofit-owned subsidized housing
and government-owned rental properties.
Table 2: Data collection
Design element Preliminary approach
Physical address
Property Property type (Single-family, Single-family with ADU, 2- to 4-unit property, 5+ unit property, mobile home)
information (categories subject to change)
Total number of rental units in the property (excluding owner-occupied units)
Property owner name, mailing address, email address, phone number
Owner identity
Property manager name, mailing address, email address, phone number (if different from owner)
For each unit:
Number of bedrooms
Occupancy status
Monthly base rent
Rent and vacancy Utilities included in rent
information Additional monthly/annual charges (or, total effective monthly cost)
Note: Collecting detailed data at the unit level will be a major driver of program cost and a potential barrier to
compliance, as complex data requirements could deter property owners or cause them to provide estimates or
incomplete information.
Inspection
None
requirement
WASHINGTON RENTAL REGISTRY STUDY 13
Table 3: Program administration
Design element Preliminary approach
Program
Department of Commerce
administrator
Charge a small per-unit registration fee of approximately $10 to $15. Provide a 50% discount for early registration.
Fee schedule
Note: Minimizing costs to property owners should be a design objective.
Create a secure online portal that allows easy registration and fee payment. Consider providing alternative
Registration
registration options (such as a paper form) for property owners with digital access barriers. Online and paper
process
materials should be available in multiple languages.
Annual registration of properties by a set date (e.g., March 1) without additional updates at the sale of a property or
Re-registration change in tenancy. Consider requiring re-registration on a multi-year registration cycle, such as every three years.
schedule
Note: Re-registration schedule will be a driver of program cost.
Pursue a multi-pronged approach to compliance, including:
Reducing regulatory barriers to registration as much as possible, through user-friendly registration, extensive
outreach and technical assistance, and enabling tenant reporting.
Providing financial incentives for compliance, by waiving fees during the startup period and providing early-
bird registration discounts (e.g., 50% discount for registration prior to the due date).
Making non-compliance expensive by setting and enforcing clear financial or regulatory penalties.
• Regulatory penalties: The state could disqualify non-compliant property owners from receiving state
assistance through Landlord Mitigation Programs. However, these programs have limited scale (for
instance, the tenancy preservation program is currently on hold due to insufficient funding, and the
landlord damage relief program applies only to tenants that receive a rental subsidy) and therefore this
type of penalty could have limited impact. The state would need to create a regulatory mechanism to
Compliance
compel registration, for example, by putting liens on properties, preventing property owners from
mechanisms
operating their rental properties, or working with Counties to attach fees and penalties to property tax
bills.
• Financial penalties: The state could charge a penalty fee that significantly increases the longer that a
property remains out of compliance. To enforce these penalties, the state would need to create a legal
framework for enforcement and pursue legal actions (including lawsuits) to compel payment of penalties
and registration of noncompliant properties. An alternative approach would be to work with County
governments to attach penalty fees to property tax bills to secure payment.
Note: Setting and enforcing clear penalties for non-compliance that make non-compliance expensive and
burdensome for property owners is the most impactful way to encourage participation. This will be a primary driver
of program cost.
Conduct early and ongoing outreach and education from the program’s pre-launch through implementation.
Include:
Partnering with rental and tenant associations to increase program awareness
Reaching housing providers directly through email and mail campaigns
Advertising the rental registry through online and print media
Outreach and
Providing in-person, online, and phone assistance to providers who need additional support
education
Technical assistance for housing providers to support compliance requirements
Note: Extensive outreach to property owners will be critical to raise awareness of any rental registry put in place
and its requirements and to encourage and reduce barriers to participation. This will be a primary driver of program
cost.
The purpose of the rental registry program should define the metrics for its success. Some metrics are likely to
include:
Program impacts and effectiveness
Metrics for
Number of properties and rental units registered, total and by submarket (e.g., city, county)
success
Estimated compliance rate, total and by submarket (e.g., city, county)
Annual increases in number of registered properties or rental units
Number of individuals accessing portal data, reports, or other data sources
WASHINGTON RENTAL REGISTRY STUDY 14
Design element Preliminary approach
Improved availability and visibility and of rental market data to stakeholders including local policymakers,
renters, and housing providers
Operational and financial efficiency:
Total Full-Time Equivalent (FTE) staff positions
Number of technical assistance inquiries
Average time to resolve inquiries
Program revenues, total and per unit registered
Operating cost, total and per unit registered
Table 4: Database requirements and data availability
Design element Preliminary approach
Based on the design approach above, the registry will have software requirements including:
The ability to collect, store, and track unit-level and property-level data
Database design and
A secure online portal capable of handling financial payments
information infrastructure
The ability to produce standardized data reports, and to develop new custom reports as
needed
Data availability could include:
Property owners and managers: Full property information for their property or properties via a
secure online portal
Data access and reporting Program administrators: Full database and data reports
Other public sector users: Anonymized data reports or aggregated data reports
General public: Online dashboard that allows access to partial rental registration information
(e.g., owner name and compliance) and market-level rental trends
Appendix H includes more detail on database requirements and data availability.
WASHINGTON RENTAL REGISTRY STUDY 15
Integration with existing registries
Existing rental registries in Washington all have similar purpose and
structure
Many of Washington’s largest cities already have residential rental registry programs. There are 17 cities in
Washington with existing rental registries, covering approximately 436,000 rental homes (about 40% of rental
homes in the state). The primary stated purpose of most of these registries is ensuring that rental housing
meets basic safety standards. Some programs state secondary purposes such as data collection, support for
property owners and tenants, support for first responders, and housing preservation. Cities with rental
registries include:
Aberdeen
Auburn
Bellingham
Bremerton
Burien
Kent
Lacey
Lakewood
Mountlake Terrace
Olympia
Pasco
Prosser
Renton
Seattle
Spokane
Tacoma
Tukwila
Integrating data from existing rental registries will be possible, but
incomplete
Excluding rental properties subject to local rental registries from a state rental registry program would result
in a significant loss of data. Existing rental registries cover approximately 40% of rental homes in the state, or
49% of homes in the six largest counties.
Existing rental registries focus on housing quality and most do not collect unit-level data or track market
data such as rent or vacancy rates. Only two registries – Olympia and Tacoma – collect rent data, and Olympia
makes rent data voluntary. Making changes to existing registries to accommodate unit-level data collection
and to collect data on rent and unit occupancy would not be feasible, according to interviews with operators of
existing registries. This means that if the state were able to access and integrate all existing registry data, it
would exclude a significant amount of rent and occupancy data.
The state could work with local governments to gather and integrate property address and owner information
to support outreach. To use existing registry data, a statewide program will require the capacity to work with
differences in data collection and storage. Each city has its own online web portal or other system for
WASHINGTON RENTAL REGISTRY STUDY 16
recording registry information and accepting fee payments. Cities have various practices regarding the storage
of this data, and very little data is available publicly, either at the property level or through reporting. The lack of
transparency makes it difficult to understand the compliance rates and scale of existing programs. It could
also make it difficult to collect and aggregate data from existing rental registries into a statewide registry.
Nonetheless, most city programs collect data via a digital portal and could likely provide data for integration
into a statewide database with some adjustments. The state should focus its integration efforts on Seattle,
Spokane, and Tacoma to minimize cost and data loss.
Because a state rental registry could impose a second registry on property owners in some cities, it will be
important to minimize the cost associated with the state program. Compliance with existing registries can be
costly and burdensome, particularly for owners with properties in multiple cities. The state should avoid adding
additional barriers for property owners as much as possible.
WASHINGTON RENTAL REGISTRY STUDY 17
Implementation timeline
Implementation of the rental registry program will require several
years to build staff capacity, program infrastructure, and public
awareness
Operational and administrative needs for the rental registry will vary across multiple phases of
implementation. The estimated timeframe to implement a rental registry will depend on the program’s
geographic focus. Based on our research, we anticipate that many of the steps needed to implement the
program are independent of the registry’s geographic focus (statewide implementation versus implementation
limited to the six most populous counties).
Table 5: Primary implementation activities by phase
Program design (year 0) Pre-launch (years 1 to 2) Launch (years 3 to 4) Stabilization (year 5 and ongoing)
Develop major data and
management systems Continue extensive outreach
Provide ongoing data
Finalize program Integrate data from and marketing
management, analysis, and
design county assessors and Manage program launch,
reporting
Enact legislative existing registries with technical assistance,
Provide ongoing outreach
measures to create and Develop informational data quality assurance, and
through direct mail and other
fund the program and marketing materials initial reporting
avenues
Prepare to hire a Conduct extensive Begin robust compliance
Continue robust compliance
program coordinator outreach and marketing efforts
activities
Hire staff and prepare for Grow operational capacity
launch
Implementation limited to the six largest counties provides some
timing efficiencies
Most implementation activities are independent of the program’s geographic scope, but a smaller geography
will reduce the timeline of some of implementation activities. A six-county program will involve a smaller set of
stakeholders in a contained number of locations. The state will have to collect and integrate data from six
county assessors instead of 39, which will reduce time. A six-county geography will also require less time to
conduct outreach. Because a six-county program will require slightly fewer staff, hiring during pre-launch and
launch will also take less time than hiring for a statewide implementation. We estimate that a six-county
approach will reduce the pre-launch and launch timelines by a total of approximately 3 to 6 months.
Appendix F contains additional details about program implementation timelines.
WASHINGTON RENTAL REGISTRY STUDY 18
Cost estimates
Operating this program would require significant staffing,
infrastructure, and investment
We conducted analysis that offers high-level cost estimates for a statewide rental registry with annual re-
registration requirements based on projected staff and material needs of such a program. We divided program
implementation into three phases: pre-launch, launch, and post-launch to stabilization. We assumed that this
rental registry will reach its maximum compliance rate of 75% after 10 years. Though Seattle’s registry
achieves over 90% compliance, we chose to assume a lower compliance rate due to the complexities of a
statewide registry, the significant increase in the number of units, and the much broader geographic scope.
Clear regulatory incentives and extensive outreach and enforcement efforts will be critical to achieve this
compliance. We present cost estimates as a range to account for different program design and resource
sharing decisions that might impact costs, and we test alternative options, like three-year re-registration cycles
and implementation limited to only the six largest counties, to explore strategies to reduce costs. We show all
costs in 2024 dollars.
A statewide program such as the one the proviso describes will require significant cost to implement and
operate effectively and with high compliance. We estimate that the program will cost approximately $2.5 to
$4.7 million per year for a four-year pre-launch and launch phase, and $3.9 to $6.4 million per year during post-
launch to stabilization. Major categories of program cost include:
Management and oversight of the program
Research and information technology (IT) requirements, including data storage, data management and
analysis, data input for paper registry applications, and reporting
Outreach, marketing, and compliance to educate renters and property owners about the program, provide
technical support, and pursue enforcement of non-compliant properties
Program overhead or the external costs to Commerce and other state agencies such as human resources,
payroll, and administrative costs.
Notably, these costs exclude potential legal costs incurred from collaboration with the state Attorney
General’s office for efforts to pursue enforcement through lawsuits.
Our cost estimates reflect a range of potential program design decisions, compliance rates, and outreach
methods, which will have impacts on program cost. One of the primary differences between the higher and
lower cost estimates is the potential to use existing county and city outreach and data functions to reduce
costs to the state. If the state can easily integrate county assessor’s data into its database, and partner with
cities with existing rental registries both to incorporate data where possible and to use existing city outreach
methods, this could reduce staff and marketing costs to the state. The high end of the cost estimates
assumes that the state’s program uses no city or county resources to operate its registry. Appendix G contains
additional detail about program cost projections.
Self-sufficiency at stabilization depends on fees and compliance
At stabilization, the rental registry could achieve self-sufficiency if it can achieve sufficient compliance
based on the per-unit registration fee. Compliance drives both program costs and revenues. Higher
compliance means more property owners pay registration fees, but it also means that there are more
applications that require more staff to review. While higher fees generate more revenue, they also impact
WASHINGTON RENTAL REGISTRY STUDY 19
costs. Our model assumes a 2.5% payment-processing fee, which means that higher fees incur higher
payment processing costs. Because of these variables, there is not a single point for fee or compliance at
which this program will become self-sufficient. Instead, different fees require different levels of compliance to
achieve self-sufficiency, as shown in the following matrix.
Table 6: Estimated annual deficit or surplus by unit fee and compliance rate
Per unit fee Compliance rate
10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
$5 -$4.2M -$4.0M -$3.8M -$3.6M -$3.4M -$3.2M -$3.0M -$2.7M -$2.5M -$2.3M
$10 -$3.8M -$3.2M -$2.6M -$2.0M -$1.4M -$801K -$201K $399K $1.0M $1.6M
$15 -$3.4M -$2.4M -$1.4M -$428K $565K $1.6M $2.6M $3.5M $4.5M $5.5M
$20 -$3.0M -$1.6M -$242K $1.1M $2.5M $3.9M $5.3M $6.7M $8.1M $9.5M
$25 -$2.6M -$842K $938K $2.7M $4.5M $6.3M $8.1M $9.8M $11.6M $13.4M
$30 -$2.2M -$55K $2.1M $4.3M $6.5M $8.6M $10.8M $13.0M $15.2M $17.3M
This matrix reflects the assumptions below. Any changes to these assumptions change the breakeven point
at which this program becomes self-sufficient.
This analysis reflects staffing at stabilization (year 6 and ongoing), not during the “launch” or “pre-launch”
periods. It excludes one-time software costs and other startup costs.
The program allows a 50% discount for early registration; we assume that 50% of units qualify for this early
registration discount each year.
The analysis assumes enforcement costs are fixed – i.e., enforcement costs do not increase if compliance
is lower than expected.
The analysis assumes an annual payment-processing fee of 2.5% multiplied by the number of units
renewing and the per-unit fee, including discounts.
The analysis assumes that some other operating costs – such as data analysis – scale with compliance.
The program is statewide.
The program requires annual re-registration.
With these assumptions, the program could produce enough revenue to cover most of its costs with a
minimal per-unit registration fee. With a $10 fee, the registry will be self-sufficient if it achieves 80%
compliance. With a $15 fee, the registry will be self-sufficient at 50% compliance. Our cost analysis assumes
75% compliance at stabilization, meaning a $15 fee will make the registry self-sufficient under these
assumptions. This fee is greater than the actual stabilized per-unit cost of about $8 at 75% compliance
because of the assumptions regarding discounts for early registration, which reduce per-unit revenue to $7.50
for those units that take advantage. If this registry were to apply only to the six largest counties, this breakeven
point remains comparable, requiring about 80% compliance with a $10 per-unit fee and 50% compliance with a
$15 per-unit fee. This is because the reduction in units associated with the six-county scenario reduces costs
and revenue proportionally. The additional efficiencies gained in the six-county scenario that do not scale with
compliance are not enough to shift the breakeven point.
WASHINGTON RENTAL REGISTRY STUDY 20
Importantly, actual compliance rates and uptake of incentives for early registration make actual program
revenue uncertain. The state must develop clear regulatory incentives and pursue extensive outreach and
enforcement to achieve the revenues we project, though outreach and enforcement beyond our projections will
further increase costs. The state should keep fees consistent most years to ensure predictability and consider
increasing costs every few years to account for increased program operating expenses due to enforcement
requirements, inflation, or other factors.
Implementation limited to the six largest counties creates notable
efficiencies
Limiting implementation to the six largest counties creates notable operating efficiencies but will exclude
many rural rental homes. The six largest counties (Clark, King, Pierce, Snohomish, Spokane, and Thurston)
together account for approximately 74% of renter-occupied homes in the state. A registry limited to these
counties would therefore cover almost three quarters of rental homes, while providing a significant reduction
in the geography required for outreach and marketing, and the number of counties the state would need to
coordinate with to incorporate assessor data and potentially to pursue enforcement measures. Together, the
reduced application volume, geographic focus, and staff efficiencies result in a 20% to 25% reduction in cost.
However, this option would exclude many parts of the state, including much of central and western
Washington and many rural areas.
Table 7: Summary of program cost by scenario
Timeframe Statewide Six counties
Pre-launch (years 1 to 2) $2.5 - $4.4 million $2.0 - $3.4 million
Launch (years 3 to 4) $3.0 - $4.7 million $2.4 - $3.7 million
Post-launch to stabilization (year 5 and ongoing) $3.9 – $6.4 million $3.1 - $4.8 million
To reduce costs, the state could consider several options
In the preceding sections, we outlined a design scope and cost estimates to provide the state with detailed
rental information by creating a rental registry program and conducting extensive outreach and enforcement to
achieve compliance. The state would require significant cost and effort to create this program and make it
effective. This investment will have the greatest value to the state if it advances clear policy goals.
There are a few options to creating a rental registry and gathering data about rental housing that could have
moderate to large impacts on costs to the state. These each require tradeoffs in effectiveness and the quality,
timeliness, and granularity of data.
Reduce costs by requiring registration on a multi-year cycle
The state could require re-registration every three years instead of annually, though this approach reduces
the timeliness of data. Requiring annual re-registration means that, at stabilization, every property owner will
need to re-submit unit data each year. This leads to a high volume of applications each year, and will require
ongoing data management, quality control, data entry for paper applications, and enforcement actions. By only
requiring re-registration every three years the state reduces annual applications to one-third of the volume.
This approach requires fewer program staff and results in an approximate 25% reduction in cost. However,
WASHINGTON RENTAL REGISTRY STUDY 21
with this approach some unit data, such as rents and vacancy, could be one or two years out of date. In
addition, a multi-year registration cycle might require higher fees to achieve self-sufficiency.
Reduce costs by minimizing outreach and enforcement activities
Reduce outreach and compliance functions. Depending on phase of implementation, outreach, marketing, and
compliance activities account for between 34% and 51% of total program cost. With limited outreach and
compliance, Commerce can reduce the rental registry’s cost significantly. However, this approach will result in
much lower compliance, which will make the rental registry significantly less effective and could reduce the
program’s financial sustainability.
Minimize costs by pursuing a data collection initiative
The state could focus on aggregating and analyzing existing rental market data or could develop a third-party
survey of rental housing. A rental registry might not be the most efficient approach to help the state and local
governments to better understand the rental market. Drawing on public and third-party data sources and
surveys, the state could produce market reports, dashboards, or other tools to help local governments
understand rental housing in their communities.
There is a range of available public and third-party market data, including property records from county
assessors throughout the state, data from the U.S. Census Bureau’s American Community Survey, databases
of subsidized and HUD-insured properties, and property listing services, as well as existing market data and
reports from the Washington Center for Real Estate Research (WCRER) that can support this initiative. Data is
likely to be statistically significant, particularly for sources like the American Community Survey (which relies
on large sample size surveys and statistical methods to produce estimates about income, housing type and
cost, and other market factors). Rather than having access to unit- or property-level information, this approach
would primarily provide data at the market level (e.g., zip code, census tract, city or county). Using County
Assessor data, the state could identify owner information for many rental properties. Some data is available in
real-time, while other data is available a year or two after sampling occurs. The state could develop an online
data dashboard or other tool for public users and local government partners.
To supplement existing data sources, the state could engage a third party to conduct a survey of rental
housing. This survey would likely occur on a multi-year cycle and could integrate existing data sources and
supplement them with survey methods. A survey would be a large undertaking but would provide statistically
significant sampling data for rental housing throughout the state. It would allow the state to specify particular
data for collection and analysis. The New York City Housing and Vacancy Survey, which the city conducts in
partnership with the U.S. Census Bureau, is an example of this model.
The primary reason to pursue a data collection initiative would be to develop specific data analysis and
reporting tools for market trends, which might otherwise be difficult to quantify. Compared to a rental
registry, a market study tool or dashboard is more straightforward to administer and is lower cost. It does not
require any direct outreach to property owners to collect information or ensure compliance. It would require
the state or a third party to develop new market analysis tools or refine existing analysis (such as the WCRER
reports) to meet policy needs, but would not require providing outreach, assistance, data hosting, and other
services to reach over 1 million rental homes. It would have minimal impact on property owners or renters.
Some of the data would be one or two years out of date but compared to a rental registry with low compliance,
it could provide a more accurate or complete picture of rental market trends.
WASHINGTON RENTAL REGISTRY STUDY 22
Stakeholder engagement
Facilitating broad stakeholder engagement was a core objective
Through interviews and listening sessions, we solicited input on the need for and potential design of a rental
registry from stakeholders including property owners and apartment industry representatives, tenants and
advocates, and local governments. This work included two primary activities:
Individual and small group interviews: We conducted 14 interviews with intermediary organizations,
including rental housing associations and other industry representatives (3 interviews), tenant advocacy
groups (2 interviews), local government staff (7 interviews), and housing authorities (2 interviews).
These interviews served two main purposes: they helped quickly survey stakeholders familiar with a
broad cross-section of perspectives on the proposed rental registry and allowed us to reach a broader
network of stakeholders.
Stakeholder listening sessions: To reach a broader audience of renters, housing providers, and
advocates across the state, we held five virtual listening sessions. Our listening sessions provided a
platform for housing providers, tenants, and advocates to learn more about rental registries, provide
input about the design and purpose of a statewide rental registry, and share concerns about potential or
perceived negative impacts of a rental registry program. In advance of each listening session, we
conducted outreach and sent flyers to potential participants through a range of partner organizations,
local governments, and other intermediaries. We facilitated two listening sessions with housing
providers and industry representatives, with 203 attendees in 21 counties, and three listening sessions
with renters and tenant advocates with 26 attendees. In each session, we provided a brief informational
presentation, conducted polling both to capture participant information and to gather input, and heard
comments from attendees.
Appendix B provides a detailed summary of engagement activities and stakeholder input.
State and local government staff might be the primary users of a
statewide rental registry
Public entities are interested in up-to-date housing data for policymaking and improved communication with
housing providers. Aside from state-level entities and tenant organizations, the biggest proponents and
primary users of a statewide rental registry are likely to be local (city and county) staff without an existing
registry. Such interviewees noted that having access to up-to-date information about their local rental housing
market would help them to make better-informed policy and investment decisions. Representatives of cities
with existing registries noted that the registry has led to better relationships with housing providers, as city
staff can contact them directly regarding any housing issues or programs. Interviewees of cities without
registries also voiced their interest in a registry as a tool to improve communication with housing providers.
Local governments with rent registries prefer to retain their existing registries but are open to sharing data
with the state. Most local registries implement policies to improve housing quality of public safety and include
requirements for housing inspections. Multiple interviewees said that unless a statewide registry had the same
requirements as their existing local ones, they would prefer to continue with their own requirements. Multiple
interviewees were reluctant to layer their existing registry with additional statewide requirements and thought
WASHINGTON RENTAL REGISTRY STUDY 23
it would lead to a regulatory burden for housing providers. City representatives were willing to share their data
with the state if it supported a statewide registry.
Renters’ most pressing challenges include rental affordability and
housing quality
A standalone statewide rental registry would not directly support rental affordability, which remains a priority
for tenants and tenant advocates. Rental affordability challenges throughout the state include high and rising
rents, low housing quality, and housing instability. Many existing local rental registries in Washington directly
address housing quality by mandating a housing inspection. A statewide rental registry could negatively
impact existing challenges if property owners pass fees on to their tenants or if owners remove their units
from the rental stock to avoid further regulation. It would be difficult for a rental registry to provide continuous
tracking and analysis of tenant-level information (such as income and loss of housing). This means that the
registry would provide limited visibility into housing affordability at the unit level.
Tenants and advocates find merit in a rental registry if it results in better housing quality and/or
transparency. Some local rental registries allow property owners to choose their own inspectors, and tenant
advocates expressed concern that these programs might not be effective at improving the quality and livability
of rental homes. One interviewee also mentioned the need to ensure housing quality statewide, particularly in
rural areas where inspections are less common. Some advocates were also hesitant about inspections, stating
that renters can be reluctant to allow unknown people into their home. Interviewees and some listening
session participants voiced interest in a statewide registry that improved real-time data on rental costs and
provided contact information of housing providers. Tenants felt that access to information about the
ownership of rental properties would give them more agency when looking for apartments to rent or raising
issues about their apartments.
Property owners and managers oppose a state rental registry
Housing providers believe that “no program is the best program.” Housing providers feel that their industry is
already highly regulated and expressed frustration with existing local registries, many of which require
inspections and annual fees. Providers oppose increased regulation and additional fees at the state level.
Commenters oppose a new statewide program, which many view as an overreach by the government.
Repeatedly in interviews and listening sessions, we heard from housing providers that the state should not
create a rental registry and that having one would create added expense or burden on them and tenants
without providing a benefit. Multiple providers thought that conducting a housing survey or using existing
public and private data would provide information on rents without adding more regulations on their
operations.
Housing providers suggested that a rent registry could increase housing costs and remove units from the
market, negatively impacting tenants. Multiple commenters said that further regulation would cause them or
other housing providers, particularly owners-managers with small rental properties, to sell their properties.
Providers said that increased regulation would reduce the availability of rental housing as some owners
choose to leave the market. Interviewees and listening session participants also said tenants would bear the
cost of any fees associated with the registry, leading to higher rental costs.
WASHINGTON RENTAL REGISTRY STUDY 24
Appendix A: Detailed program design considerations
Purpose of this document
This document summarizes the major considerations that will inform the design of a state rental registry,
including design options, tradeoffs, and relevant findings from background research.
Methodology
We conducted background research to develop an overview of design features of rental registries and
considerations for the design of a state rental registry program in Washington. This work included: producing
case studies of four existing rental registry programs; creating an overview of existing local rental registry
programs in Washington; conducting a scan of rental housing market conditions in Washington; and engaging
with stakeholders through interviews and listening sessions.
Rental registry goals
Potential policy goals
Rental registries can advance several potential policy goals or purposes. Rental registries collect information
about rental housing. This can include information about the number and location of rental homes; market
data including housing type and cost; and information about the quality of homes. In addition, a rental registry
can support regulation of one or all of these.
Potential goals for a rental registry include:
Inform policy decisions for state and local governments by providing up-to-date data on rental housing
Help state and local governments monitor compliance with state policies, such as monitoring progress
toward accommodating housing needs for all incomes, or tracking evictions
Ensure housing quality and strategic code enforcement by identifying and addressing health, safety, and
other hazards in housing, or by identifying owners of rental properties with persistent code violations,
and working with property owners to make needed repairs
Reduce or minimize regulatory burdens for housing providers (property owners and managers) working
in multiple cities by streamlining compliance requirements with multiple local registries
Improve and enable communication with housing providers to conduct outreach, provide resources,
build trust and improve relationships between the industry and government regulators
Existing state-level rental registries meet a range of goals, from tracking rent-stabilized properties (New York),
to addressing environmental hazards in older homes (Maryland), to identifying property owners to support
local services such as code compliance and first responders (Ohio). In Washington, local rental registry
programs focus on ensuring housing quality.
The goal or goals for a statewide rental registry in Washington will be critical to informing the program’s
design. The proviso does not specify a purpose for the proposed rental registry. Based on conversations with
Commerce, we understand that one of the state’s goals is to help state lawmakers and local governments
WASHINGTON RENTAL REGISTRY STUDY 25
understand their rental housing markets to make informed decisions, meet growth and affordability
requirements, and track housing affordability.
Study Question:
What are the equity concerns for this project? Where is the burden placed and what may be unintended
impacts from the implementation of the registry?
Equity considerations
The most essential equity consideration for a state rental registry is to ensure the program does not worsen
challenges of affordability and stability for renters in Washington. Renters throughout Washington make less
money and face higher housing cost burdens, which means they have fewer resources to withstand
unforeseen costs or loss of income. Increasing housing costs will make housing cost burden worse for many
renters. Renters are also disproportionately nonwhite, due to historic and ongoing exclusionary policies and
practices that limit access to homeownership. Any policy that impacts renters will disproportionately affect
low-income residents as well as nonwhite households.
A rental registry program could place added cost burdens on renters. Housing providers could pass
registration fees on to renters, either directly in the form of fees or indirectly in the form of increased rents,
though studies suggest this is not a common practice. Increasing cost or regulatory burden for property
owners could also lead to some of them to remove housing from the rental market, such as by operating the
home as a Short-Term Rental instead of permanent housing. Because of these risks, it will be essential to
minimize registration fees and the costs of compliance with a rental registry.
The fee structure should not create excessive charges for owners with only a few rental properties. Small
rental properties, such as single-family homes, are more likely than larger properties to have small, private and
self-managed property owners. These owners are more likely to rent to lower-income or more vulnerable
renters. Some exiting rental registries charge a larger registration fee for the first unit in a rental property, and a
smaller per-unit fee for each additional unit. This structure results in a high fee per unit for smaller properties,
and therefore creates higher cost impacts to these owners and their renters.
The rental registry program should accommodate registration through online and paper forms. A user-
friendly online portal that can collect registration information and fees will be critical to minimize compliance
costs for many property owners in the state. However, access to reliable high-speed internet varies across the
state. To ensure that differences in access do not create barriers to compliance, the state should allow
property owners to provide registration forms and payments by mail.
Applicability
Subject geography
The design of the program will consider the potential tradeoffs and implications of implementation across two
different geographies:
1. Statewide implementation
2. Implementation limited to the six largest counties (Clark, King, Pierce, Snohomish, Spokane, and
Thurston), which together account for approximately 74% of renter-occupied homes in
Washington
WASHINGTON RENTAL REGISTRY STUDY 26
A statewide implementation would give the state the best opportunity for a full understanding of rental housing
in different types of markets. However, the six largest counties account for almost three quarters of rental
housing in the state. It will be an important cost/benefit decision to consider the benefits of gathering this data
compared to additional costs associated with compiling and managing it.
Rental homes subject to registration
Study Question:
Analyze different types/groups of units that could be included and or excluded from the registry and
discuss the potential impacts of excluding those groups including data loss that might result from these
exclusions.
The inclusion or exclusion of different property types is likely to impact fees collected as well as the
complexity of administration, impacts to property owners, and strength of data collection. Most existing rental
registries in Washington apply to all residential rental property with limited exceptions.
Properties by size and type:
Renter-occupied single-family homes: Most city-level rental registries in Washington require all rental
homes, including single-family homes, to comply with registry requirements, though a few exempt these
properties from inspection requirements. Single-family homes account for over one-third of all rental
housing in the state, and they are the largest category of rental housing across each region. Single-family
homes are more likely than larger multifamily properties to have small, private owners.
• Excluding single-family homes from a rental registry would result in a significant loss of data. There
is not a compelling reason to exclude or exempt renter-occupied single-family homes from
compliance with a rental registry program.
Duplexes (or ADUs) in which one unit is owner-occupied: Most city-level rental registries in Washington,
which are focused on maintaining housing quality, require all rental homes, including single-family
homes, to comply with registry requirements, though a few exempt these properties from inspection
requirements. Owner-occupancy of small properties could indicate that the property has a small, private
owner. We do not know how many of these homes exist in Washington. Properties with 2 to 9 units
account for the second largest number of rental homes in each region after single-family homes.
• Excluding duplexes or properties with Accessory Dwelling Units in which one unit is owner-occupied
is likely to result in a significant loss of data. If the state is interested in collecting rental market
data, there is not a compelling reason to exclude or exempt owner-occupied duplexes from
compliance with a rental registry program, though the owner-occupied units in each duplex would
not be subject to the registry.
Mobile homes (owner-occupied and renter-occupied): Mobile homes, unlike non-manufactured rental
units, have divided ownership. Mobile homeowners pay for their own gas and electricity, while the
landowners pay for sewer and refuse collection costs. Mobile home park operating costs could include
more infrastructure expenses than apartment buildings, but much fewer maintenance costs. There are
approximately 165,000 occupied mobile homes statewide (127,000 owner-occupied and 38,000 renter-
occupied). This represents approximately 13.7% of homes that would be subject to a rental registry.
WASHINGTON RENTAL REGISTRY STUDY 27
• There is not a compelling reason to exclude or exempt mobile home parks from compliance with a
rental registry program. The state could provide exemptions to mobile home occupants who own
both the mobile home and the property on which it sits.
Subsidized affordable housing: Many existing rental registries require owners of subsidized affordable
housing to register their properties. In Washington, most registries waive inspection requirements for
homes with federal subsidies, such as Low-Income Housing Tax Credit (LIHTC)-financed properties,
because these properties are already subject to inspection through HUD requirements. Some also
provide fee waivers for nonprofit-owned affordable housing to reduce the financial burden.
• Pending confirmation of the legal restrictions, the state should require registration but waive fees
for government-owned and operated rental properties.
Institution and commercial properties including group homes, dormitories, and hotels: Most existing
rental registries exempt these non-rental housing property types from rental registry compliance.
• The state should exempt non-rental housing property types such as institutions and hotels because
their operations, furnishings, zoning, and other factors are distinct from permanent rental housing.
Properties by ownership:
Ownership type (e.g., individual, LLC, corporation) or number of units owned: To protect small, private
housing providers (“mom and pops”) a rental registry could allow exemptions for owners with fewer than
a certain number of rental units or individual owners (as opposed to a corporate owner). This can be
complicated for a number of reasons. First, many renters do not consider the legal structure of the
property’s ownership in selecting a rental home but would receive different types of protection or
regulation based on ownership. Second, through establishment of multiple LLCs it is easy for owners to
obscure the number of properties they own. Finally, identifying contact information to enable
communication with property owners, including small private owners, is likely to be a critical output of
any rental registry program.
• To gather useful data on rental markets and enable communications with property owners, the
state should not exempt properties based on ownership.
Government-owned properties: Our research indicates state law exempts government-owned, operated
or managed rental properties from paying registration fees. This includes housing authority properties.
• Pending confirmation of the legal restrictions, the state should require registration but waive fees
for government-owned and operated rental properties.
Tribal-owned properties: Some tribal governments own rental properties outside of tribal lands. We are
not aware of any legal barriers that would prevent the state from requiring registration of these
properties, however the state’s attorney general should confirm this.
• Pending confirmation of the legal restrictions, the state could consider making registration of tribal-
owned properties on non-tribal lands voluntary, by waiving any fees or fines associated with
compliance.
WASHINGTON RENTAL REGISTRY STUDY 28
Other cases:
Vacant properties not available for rent: Several existing rental registries in Washington allow
exceptions for properties that are vacant and not available for rent. The goal of these programs is to
ensure that rental housing meets life and safety standards for residents, so homes that are not available
for rent and would not have occupants are exempt from compliance. However, capturing information
about these properties would be helpful to understand market conditions and housing supply, or to
identify property owners of abandoned or chronically vacant properties in support of code enforcement.
Vacant properties not available for rent would be unable to provide information on monthly rents.
• If one of the state’s goals is to gather data on rental markets and housing supply, the state should
not exempt properties based on vacancy status.
Room rentals in owner-occupied homes: Most existing rental registries in Washington offer exemptions
for room rentals, or rentals for which the lease applies only to a portion of an owner-occupied home. It
would be difficult to track and enforce compliance of these properties, and it would be difficult to
compare monthly rents of these rentals with rents that apply to an entire home.
• Because of the complexity of enforcement and because rooms are not comparable with units for
data gathering purposes, the state should exempt room rentals in owner-occupied homes.
Short-term rentals:
Study question:
What are the potential impacts, including costs, of including or excluding short term or vacation
rentals in the registry?
At the state level, property owners who rent out homes, rooms, condos, time shares, cabins, camping
sites, or RV sites on a short-term basis (less than 30 days in a row) for overnight accommodations need
to register with the Department of Revenue and get a business license if they meet certain criteria.
Qualifying short-term rental businesses must apply for a business license, pay associated fees, and,
depending on the type of ownership entity, sometimes register with the Washington Secretary of State.
The Department of Revenue business license application requires information on the owner, business
location, estimated income, products or services sold, and number of employees. At the city level, the
way cities with registries manage short-term rentals varies significantly—some exempt them from their
registries, some include them, and some govern them under a separate ordinance. Including short-term
rentals in a registry at the state level would make it easier to understand what portion of rental housing
stock is not available to traditional renters to get a more accurate sense of the available rental housing
supply. However, since the state already governs short-term rentals via business licenses, requiring
registration of short-term rentals could result in overly bureaucratic processes and a lack of clarity about
government oversight. In addition, short-term rentals are not part of the supply of permanent rental
housing and do not charge monthly rents or calculate vacancy status in the same way that permanent
rental homes do.
• The state could require short-term rental properties to comply with a rental registry, but there are
two primary reasons not to: first, because the state already requires owners of these properties to
obtain a business license, and therefore already has information about the number and location of
WASHINGTON RENTAL REGISTRY STUDY 29
these properties; and second, because data about short-term rentals will not be comparable to data
about long-term housing.
Data capture
Study question
Conduct an analysis to determine the potential benefits of collecting additional data beyond the
requirements stipulated in the proviso. Consider the potential impact of collecting additional data on the
overall functionality and effectiveness of the registry. Propose modifications to the data fields that could
enhance the utility of the registry and the impacts of each of those specific proposed modifications.
Types of data
The proviso specifies the collection of the following data:
Physical address
Property owner identity
Monthly rent charged
Vacancy status
There are fundamental tradeoffs between the level of detail or granularity of data, its value in informing
market assessments, the cost and complexity of gathering and storing data, and the likelihood of getting
reliable compliance. The most basic tradeoff is between collecting data at the property level (simple) and at
the unit level (complex), however, there are other important nuances.
Value of market data: It can be difficult to get meaningful data on costs to renters without asking for
multiple data points. At the most basic, the number of bedrooms in each unit will impact the rent (as will
other property-level specifics such as the floorplan, placement in the building, etc.). Asking housing
providers to provide monthly rent without also asking for the number of bedrooms in each unit will make
it difficult to understand the actual cost and availability of rental housing. Rental units also differ in which
utilities or services monthly rent includes, and which the tenant pays directly. This can also make it
difficult to understand the true cost of rental housing. Some rental properties offer incentives (e.g., free
month of rent) or charge amenity or service fees in addition to monthly rents. To capture useful data to
analyze actual cost of housing at the market level, the registry would need to collect data on the number
of bedrooms and the total of all monthly charges to the tenant, adjusted for annual incentives or fees,
and identify any utilities not included in rent.
Program cost and complexity: Collecting and storing property-level information is less complex than
collecting and storing unit-level information. There are two primary components to the added complexity:
first, the database and data security infrastructure would need to be more complex to store more
records (there are approximately 1 million rental homes in Washington in about 450,000 rental
properties), to store data at both the unit and the property level, and to maintain security of more
sensitive industry data. Artesia can help estimate the increased complexity and cost of this requirement.
Second, the state would require added staff time to oversee compliance efforts and assist property
owners, enter data from paper registration forms (if applicable), and analyze data.
Compliance impacts: The longer and more complex the registration process, the more likely it is to
produce incomplete or inaccurate data. Property owners or managers might not have full and accurate
WASHINGTON RENTAL REGISTRY STUDY 30
data organized in a way that they can easily reference it, and they could provide guesses rather than
confirm details. A complex registration process could discourage compliance or lead to partial
compliance (property owners provide some but not all of the data requested). About 30% of rental
housing in Washington is in single-family homes (more when adjusting to include owner-occupied mobile
homes), and for those homes collecting unit-level and property-level data would be the same. However,
for a multifamily housing provider with multiple properties, a property level registration process could
require only a few entries, whereas unit-level could require them to enter information for hundreds or
thousands of rental units.
Of the data points in the proviso, physical address and property owner identity are property-level data points,
while vacancy and monthly rent would typically be unit-level. A registry could collect data on vacancy status at
either the unit level (for each unit, is it occupied or vacant?), or the property level (what number or what percent
of units are vacant?). Collecting full and accurate rent data at the property level would be difficult and costly.
As a potential alternative, the registry could ask for the number of units and “typical” monthly costs (inclusive
of all fees) by size (e.g., studio, 1 bedroom, 2 bedroom, etc.). This would produce less detailed and complete
market data, but it would simplify the registration program.
Below is a broad summary of potential data types a rental registry could collect, and relevant considerations
for their inclusion or exclusion:
Table A1: Data types a rental registry could collect and considerations
Type of data Potential data points Considerations
Physical address
Physical address is the most universal property identifier and
Other property identifier (e.g., parcel
therefore likely to serve as the basis for the inventory of rental
number)
properties. Other property identifiers (e.g., parcel numbers) will vary
Property type (e.g., Single-family, ADU,
in length by County but might be helpful to track for verification
2-to-4-unit property, 5+ unit property,
purposes when addresses are similar, or when sharing data with
mobile home)
local governments.
Property Total number of rental units in the
information property (excluding owner-occupied
Information about the property type and total number of rental units
units)
will provide helpful context and information about the rental market.
Number or percent of units that are
vacant
The year built could be a useful data point but not all registrants will
Assessment data (e.g., year built, total
have access to that data. The state could potentially work with
square footage, receipt of homeowner
County assessors to track year built or other assessment data.
exemption, assessed value)
In order to enable full communications with housing providers
Property owner name, mailing including property owners and third-party managers, the rental
address, email address, phone registry should collect names and contact information for property
number owners and managers.
Property manager name, mailing
Ownership and address, email address, phone If the state is interested in better understanding the nature and type
contact number (if different from owner) of property owners in Washington, it could also ask for information
information Ownership type (e.g., individual or about the ownership structure or total number of units owned.
trust, limited partnership, LLC,
corporation) or other data (e.g., Some code enforcement-focused rental registries require
number of units owned) registrants to identify a local contact when the owner does not live
Local contact/individual contact locally, or an individual contact for properties with a corporate, LLC,
or other legal entity for an owner.
Lease type (long-term or short-term,
Unit-level data will help give detailed information about the supply of
i.e., less than 1 month)
Unit information rental housing.
Occupancy status (occupied or
vacant)
WASHINGTON RENTAL REGISTRY STUDY 31
Type of data Potential data points Considerations
Unit size (number of bedrooms or The more complex the data the state tracks, the more onerous the
square footage) or other details such burden on property owners and the more complex the data
as number of bathrooms management and analysis will need to be. At the most basic, the
Monthly rent state could track lease type, vacancy status, number of bedrooms,
Utilities included in rent and monthly rent. The status of utilities and additional fees could
Additional fees (e.g., Amenity fee, help give a more complete view of housing costs.
HOA fee for mobile homes)
There are several ways to track subsidized affordable homes. At the
most basic, the state could track whether each unit receives a
subsidy in exchange for income restriction, and the affordability
level of the restriction based on Area Median Income (e.g., 30% AMI,
Income-restricted status
50% AMI, 60% AMI, 80% AMI). A more complex approach would be
Subsidy type (LIHTC, Project-Based
to also track the type of subsidy (e.g., Low-Income Housing Tax
Vouchers, other)
Unit affordability Credits (LIHTC), HUD 202 financing, Project-Based Vouchers, etc.).
Affordability level (based on Area
information
Median Income, e.g., 30% AMI, 60%
The use of tenant-based vouchers provides another data point
AMI)
related to affordability, though it is subsidy for the tenant rather than
Use of Tenant-Based Vouchers
the property owner.
Most federal subsidy programs already require detailed reporting to
track compliance of these properties.
Tenant data (which could include demographic information such as
age, household size, and race or ethnicity as well as income, length
Tenant data (demographics, income, of tenure in the home, and source of income such as vouchers)
Tenant length of tenure) could provide an additional dimension of rental market data.
information Source of Income (e.g., use of tenant- However, collecting this data would significantly increase the
based vouchers) complexity of the data collection process, creating a burden for
registrants to update data on their tenants’ income annually. It could
pose a privacy risk for tenants.
Data on property management policies and could provide additional
Property Tenant screening criteria (e.g., information on housing access and displacement rates. However,
management required income, credit score) requesting this data would increase the complexity of the data
policies Unit eviction history collection process and housing providers could be unwilling to
share the information.
Inspection requirement
Most existing local rental registries in Washington require inspections.
Overseeing an inspection program would be costly and would duplicate local efforts. A state registry should
not include an inspection requirement unless improving housing quality is an explicit goal of the program.
Program administration
Study question:
Should the Rental Registry Program be managed by the Department of Commerce or is it more efficient and
effective for another agency to manage the registry based on their existing capabilities?
Program administrator
A new state rental registry program will require a program administrator to manage operations, including:
WASHINGTON RENTAL REGISTRY STUDY 32
Providing outreach, information, and technical assistance to property owners and other stakeholders about
the program, both to increase compliance and to educate the public
Hosting and managing an online platform to collect, store, and disseminate data and collect fees (either
directly or with a third-party vendor)
Conducting data entry for paper submissions (if applicable)
Conducting quality control for registration data
Monitoring and reporting on compliance and other metrics of success
Analyzing and reporting on rental market data, or responding to requests for data
Providing other oversight as needed depending on the program’s goals
A state agency such as Commerce could serve as the administrator or could hire a third-party contractor to
administer the program. Ohio’s model requires no state-level administration, and instead puts the
administrative burden on participating County Auditors. However, this approach both creates new
administrative burdens for County staff and limits the value of the program at the state level.
Commerce works with a range of stakeholders statewide including local governments, businesses, and
community organizations. It oversees state-level housing programs including the Housing Trust Fund and
provides technical assistance and education.
Commerce is likely to be a suitable administrator.
Fee schedule
Study question:
Provide an analysis of the various registration fee structures with detailed projections of how different fee
levels would impact the rates of landlord participation. Identify and detail any potential tipping points for
dramatically decreased or increased participation.
Most rental registry programs charge a registration fee. The registration fee typically helps offset the costs to
administer the program. In some of the cases we reviewed, administrators found that registration fees were
not sufficient to cover program operating costs, and either raised registration fees or were considering raising
fees.
Fee structure:
Fee by size: Registration fees often vary according to the size of the property, either as a flat per-unit fee
or a tiered fee based on ranges of units. Many existing registries charge a larger amount for the first unit
in a property, and a smaller per-unit fee for each additional unit. This structure results in a
disproportionately high fee per unit for smaller properties, which are more likely than larger properties to
have small, private and self-managed property owners.
• A flat per-unit fee ensures that the scale of revenue tracks the scale of registrations, without
creating disproportionate burdens on small property owners and their tenants.
Fees by property condition: Minneapolis charges rental registration fees based on property size and
condition, to incentivize owners and managers to keep their properties in good condition, and to ensure
that property owners that create more compliance costs (i.e. require more frequent inspections and take
longer to address problems) pay a higher fee to cover those costs.
WASHINGTON RENTAL REGISTRY STUDY 33
• Because housing quality and inspections are not a focus of the state program, a fee structure tied
to property condition is not advisable.
Fee levels:
Scale to program size: Ohio’s statewide registry, which has no cost to the state, does not include a
registration fee at the state or the county level. Los Angeles County charges $90 per unit for properties
that are subject to rent stabilization (and require additional oversight) and only $30 per unit for properties
that are not rent-stabilized. Minneapolis charges a broad range of fees depending on property size and
condition, but even a single-family home in good condition would have registration fees above $100 per
year. However, Minneapolis’s program has compliance incentives that reduce costs. Rental registration
fees for existing city-level registries in Washington typically range from about $10 to $50 per unit per
year, excluding the cost of inspections.
Financial burden and compliance: Added cost for property owners, particularly those who already pay
local registration fees and inspection fees, could serve as a deterrent to compliance. Minneapolis’s
program, which has a compliance rate of over 90%, has compliance incentives that reduce costs.
• The state should explore the possibility of not charging a fee for registration. The state should also
explore compliance mechanisms that reduce costs, such as discounts for early registration.
Tenant impacts and equity implications: It is possible that property owners would pass any fees
associated with registration on to tenants, either directly as a rent surcharge or indirectly through
increased rent or decreased services. Renters in Washington are more likely to have lower incomes and
to be non-white than homeowners. High registration fees could have a disproportionate impact on
Washington’s most vulnerable residents.
• A state rental registry should minimize registration fees to the extent possible.
In addition, the state would either require property owners that already pay city registration fees to pay a
state registration fee as well, or exempt property owners who pay city registration fees, which could
cause imbalances to the impacts of a state program on property owners in different cities.
• To minimize unintended consequences, maximize compliance, and limit regulatory burdens for
property owners, the state should minimize the registration fees as much as possible, such as
charging a low, flat per-unit fee of $10 to $30. The state should also explore the possibility of
operating a program without a fee. This means that the program might not produce enough revenue
to cover its operating costs. The state will need to pay for most or all of the program’s
administrative costs to avoid passing them on to property owners and, potentially, renters.
Tipping points
Outreach and enforcement mechanisms will create the primary “tipping points” in participation. If the state
creates a voluntary program or a program with no fees and no penalties for non-compliance, compliance will
be low. The primary ways to increase participation will be first, to conduct extensive outreach and marketing to
property owners, and second, to make non-compliance burdensome and expensive.
Registration process
The registration process and timing should be as easy as possible to maximize compliance, while allowing
flexibility.
WASHINGTON RENTAL REGISTRY STUDY 34
Online portal for registration: The best practice for a registration process is to provide a secure online
portal where property owners or managers can submit information and pay fees.
Paper option: Property owners in some parts of the state could have barriers to using an online platform,
so the state could also consider providing a static form that owners can download or receive by mail, as
well as allowing payment of fees by check. Seattle estimates that 30% of its property owners opted to
provide a paper form and check instead of using the online system. Providing a mail-in option would add
to the administrative cost of the program to provide data entry but could help to increase compliance as
well as the accessibility of the program.
Re-registration schedule
Study question:
Determine whether re-registration for every new vacancy is required or if an annual requirement is sufficient
to gather impactful state data.
Most existing registries have a set date on which all registrations are due each year. This approach is
straightforward and predictable, both for owners and for program administrators. Some registries require
registration at other times, such as the sale of the property or a change in tenancy. This approach adds
complication and cost to the program but could be valuable for programs such as San Francisco’s where the
purpose is to track compliance with rent stabilization. Housing providers that operate multiple units would find
it burdensome to track turnover of every rental unit each time it occurs.
Collecting point-in-time data on a predictable schedule provides useful data for analysis and is and more
cost effective than requiring updates based on property changes.
There are over 1 million rental homes in Washington. Instead of requiring annual registration for every unit, a
rental registry could, for example, require registration every 3 years, so that approximately one-third of rental
units must provide updated registration information each year. There are precedents for this approach in
Seattle and in Minneapolis. This would reduce the timeliness of market data. However, using a multi-year cycle
for registration would significantly reduce the costs to operate the program as well as the impacts to property
owners.
The state should consider adopting a multi-year registration cycle, such as a 3-year cycle.
Compliance mechanisms
Study question:
Deliver a comprehensive analysis of the current participation rates in existing registries in jurisdictions in
Washington and in other states.
Based on comprehensive literature review and case studies, assess the expected level of landlord
participation in the registry over both the short and long term. Provide insights into potential challenges and
opportunities for sustaining or increasing participation rates over time.
WASHINGTON RENTAL REGISTRY STUDY 35
It is difficult to comprehensively analyze and report on rental registry compliance. This is partly because most
rental registries either do not report compliance or lack historical compliance data. Additionally, administrators
of these programs do not know the exact number of rental homes subject to registration requirements and can
only estimate compliance.
New rent registries have low compliance rates. Based on case study research, Los Angeles County and
San Francisco, which both implemented rental registry programs in 2020, have compliance rates below
5%. In Washington, the cities of Kent and Olympia established rental registries in recent years and
estimate compliance is currently below 10%. Challenges arising from the COVID-19 pandemic, including
limited stakeholder engagement, rent freezes, and other pandemic-era policies could partly explain these
low compliance rates.
Some longer-operating registries have higher compliance rates. For example, Minneapolis' long-
standing program, now in its 26th year, boasts over 90% compliance. Similarly, Seattle, which established
its registry in 2014, estimates a compliance rate of about 90%. Both cities employ outreach and
compliance measures similar to newer programs, such as mailers, online applications, late fees, and
early registry fee waivers. It is possible that their higher compliance rates are due in part to their longer
operations, as well as to other factors such as compliance mechanisms.
The level of compliance and participation in a statewide rental registry will depend on a number of factors
including the cost and complexity of the registration process, outreach measures, and incentives and penalties
for compliance. It is likely that the program will have low compliance (below 10%) for the first 3 years. This is
due to the challenges of rolling out a program in a large geographic area, and challenges in identifying,
contacting, and incentivizing property owners. Pairing effective incentives and consequences to increase
compliance with extensive ongoing outreach and enforcement campaigns will be critical to improving
participation in a statewide rental registry program.
There are three primary approaches to encourage compliance. Programs with high compliance use all three.
Study question:
Provide a comprehensive overview and analysis of strategies to encourage property registration. Provide
recommendations on the most effective approaches for implementing consequences or incentives to
increase compliance rates. Special focus should be given to addressing registration challenges among
hard-to-reach landlords and unconventional unit types, including owner-occupied multifamily properties,
accessory dwelling units, and mobile home rentals.
Approach 1: Reduce regulatory barriers to compliance:
Provide user-friendly registration options. An easy-to-use secure online portal can make it easy for
property owners to register and pay fees. In addition, providing an option for paper submissions is
important for property owners who prefer to mail their form and payment. Registration forms should be
as straightforward as possible and minimize the time required for data entry.
Provide extensive outreach, marketing, and technical assistance. An effective outreach and educational
campaign will be critical in the pre-launch and startup phases to raise awareness among property
owners and tenants. After startup, ongoing outreach and marketing are important to continue to
WASHINGTON RENTAL REGISTRY STUDY 36
encourage registration. To further reduce regulatory barriers, programs can also provide technical
assistance for property owners and tenants with questions about the registration process.
Engage with tenants as well as property owners. Some rental registries allow tenants to provide
information about their rentals, such as the property location and owner or manager information, to
support outreach efforts. Some rental registries that support broader policies such as housing quality
also allow tenants to report violations.
Approach 2: Provide financial incentives for compliance:
Waive initial registration fees. Some newer registry programs, such as Los Angeles County’s registry,
waive the registration fees for an initial compliance period (e.g., one year) to encourage early
participation.
Provide annual discounts for early registration. Minneapolis, which has over 90% compliance, provides a
discount of 50% of the registration fee for property owners that submit registrations before the annual
deadline. Olympia’s rental registry offers tax rebates for early compliance.
Provide other mechanisms for owners to reduce fees. Some registry programs, including Minneapolis,
enable property owners to lower their registration fees if they attend “good landlord” workshops or other
educational initiatives that advance program goals.
Approach 3: Make non-compliance expensive
A rental registry program without financial or regulatory consequences for non-compliance will be voluntary,
and compliance will be low. Setting and enforcing clear penalties for non-compliance will be the most critical
way to encourage participation.
Create financial penalties for late compliance. LA County imposes an annual 10% late fee on any unpaid
balance for already-registered property owners who fail to pay their units’ fees by the annual deadline.
Staff noted that the fee was too low to increase compliance significantly. San Francisco charges
property owners a monthly 5% late fee, collected through the Bureau of Delinquent Revenue. In
Minneapolis, rental license renewals 15 days after the yearly deadline are subject to an annual penalty
charge of 25% of the license fee up to $3,000, charged through the annual real estate tax payment.
Create financial penalties that dis-incentivize unwanted practices. Minneapolis’ progressive fee
structure includes higher fee amounts for properties that have code violations, as well as a progressive
supplemental Property Management fee that the city applies if they must conduct multiple property
inspections. This fee structure ensures that unresponsive property managers offset the cost of added
oversight.
Create regulatory penalties for non-compliance. Registries that support broader housing programs or
policies tie non-compliance penalties to these policies. In San Francisco and LA County, non-compliant
properties are not eligible to raise rents of rent-stabilized properties. If a non-compliant property owner
increases rents without a license in San Francisco, the tenant has the right to file a civil proceeding
against the property owner. Tenants and mobile homeowners in LA County can submit an online form if
their home unregistered or if their housing provider is raising rents above allowable limits. Minneapolis
requires owners to have an up-to-date rental license to rent a unit, enforced by reporting from tenants or
their advocates.
WASHINGTON RENTAL REGISTRY STUDY 37
• A multi-pronged approach that combines clear incentives and penalties, streamlined registration
processes, and robust outreach efforts will improve initial registration and ongoing program
compliance.
Addressing the registration challenges among hard-to-reach landlords and unconventional unit types
requires tailored outreach and support programs. For owner-occupied multifamily properties, accessory
dwelling units (ADUs), and mobile home rentals, personalized communication and technical assistance can
enhance participation. The City of Burien exempts these property types from certain inspection requirements
while offering technical assistance and financial incentives to encourage compliance. Olympia’s new rent
registry exempts ADUs and duplexes with an owner-occupied unit from inspections. Targeted mail campaigns,
online portals, and in-person assistance can also facilitate the registration process. Offering workshops and
training sessions, as seen in Minneapolis, can also educate property owners on the benefits and requirements
of registration, ensuring higher compliance rates across diverse property types.
Outreach and education
Study question:
Compile an analysis of the most effective strategies observed in various jurisdictions for outreach and
educational campaigns aimed at improving participation accompanied by cost estimates for these efforts.
An effective outreach and educational campaign is essential for improving participation in a statewide rental
registry program. Our case study review and interviews with program administrators highlight the need for
ongoing engagement with housing providers from the initial registry design and rollout through startup and
ongoing operations. The state should conduct outreach from pre-launch through startup and continue
throughout the program's operation. Implementing statewide engagement approaches like mass mailers and
technical assistance will require significant time and funding. Additionally, the state needs to couple outreach
with compliance mechanisms over an extended period to increase registration rates.
Table A2: Engagement approaches and considerations
Engagement approach Phase Advantages Disadvantages
Unlikely to reach disengaged
property owners
Boost initial program
awareness Virtual sessions might not
Informational sessions be accessible to owners
Most registries engaged housing providers and their advocate Virtual sessions are with internet access barriers
Pre-
associations in informational sessions prior to launching the low-cost and can have
launch,
rental registry. The sessions, which can be virtual, in-person, or a wide reach Hosting in-person sessions
startup
hybrid, allow housing providers to familiarize themselves with the across the state could be
program, ask questions, and plan for registration. The state can record costly
sessions webinars for
later viewing Housing providers can use
sessions to air grievances
about the program
Access to
Partnerships with associations
Pre- associations’ Unlikely to reach disengaged
Most registries engage rental housing associations and tenant
launch, extensive network of property owners
advocacy groups to co-host events and distribute materials,
startup, housing providers
increasing awareness to a large number and variety of housing
ongoing High cost if in person
providers.
Low cost if remote
WASHINGTON RENTAL REGISTRY STUDY 38
Engagement approach Phase Advantages Disadvantages
Meeting with neighborhood groups High cost if in person
Pre- Targets hard to reach
Organizing neighborhood meetings in urban, suburban, and rural
launch, property owners in
areas can reach property owners who might be less likely to Challenging to accomplish
startup specific geographies
respond to mail or online communications. across the state
Data collection will be time-
consuming and expensive
without a central state
Mass paper mailing
address repository
Direct mailer campaigns increase awareness of the program
Boost initial program
before registration begins. Commerce needs to assess how to
awareness Direct mail costs to reach all
collect contact information (e.g., address, owner’s name) for all
property owners or likely
residential properties across the state. The state can collaborate
Cover a high number rental properties across the
with county assessors, utility companies, or local governments to Pre-
of properties state could be very
secure these contact details. Outreach materials should include launch,
expensive
information about the program, as well as contact information for startup,
More likely to reach
questions and website links for further information. ongoing
small-scale housing Could result in a high
providers and other number of calls from
As a starting point, mass mailing can cover all residential property
difficult to reach housing providers and
or focus on “likely rental properties,” multiunit residential
owners single-family homeowners
properties plus any single-family residential properties for which
the tax billing or utility billing address is not the property address.
Requires staff capacity to
answer phone and email
inquiries
Boost program
Transaction-driven mailing Pre- awareness of new
Requires coordination with
Coordinate with property registries to receive up-to-date launch, property owners
local and/or state property
information on new property sales. Send rent registry information startup,
registries
to new property owners based on sales transaction records. ongoing Engage new property
owners
Boost initial program
awareness
Mass emailing Data collection will be time-
Direct email campaigns increase awareness of the program consuming and expensive
Cover a high number
before registration begins. Commerce would need to assess how
of properties
to collect contact information (e.g., email address, owner’s name) Could result in a high
Pre-
for property owners across the state. This would involve working number of calls from
launch, Lower cost than a
with operators of existing rental registries, local governments, housing providers and
startup, paper mail campaign
utility companies, and industry associations to support an online single-family homeowners
ongoing
outreach campaign and develop a distribution list. The state
More likely to reach
should include information about the program as well as contact Requires staff capacity to
small-scale housing
information for questions or links to information sessions on the answer phone and email
providers and other
outreach materials. inquiries
difficult to reach
owners
Could result in a high
Boost initial program number of calls from
Pre- awareness housing providers and
Advertising and social media
launch, single-family owners
Posts on state social media accounts, paid social media
startup, Cover a high number
advertisements, and advertisements in local media outlets
ongoing of properties at a low Requires staff capacity to
cost answer phone and email
inquiries
Online and phone
Technical assistance
system is accessible
Providing one-on-one technical assistance through a dedicated Startup, High implementation and
regardless of users’
helpline and online chat support to help property owners with the ongoing operating cost
location
registration process.
WASHINGTON RENTAL REGISTRY STUDY 39
Engagement approach Phase Advantages Disadvantages
Small scale owners
can receive focused
support
Dependent on a user-friendly
online website or mobile
Low cost application, as well as
Citizen reporting
Startup, outreach to tenants and
Allows renters and their advocates to pro-actively report
ongoing Engages renters and tenant advocates
properties they know or believe to be rental properties.
advocacy groups
Process to verify rental unit
can be lengthy and high cost
Metrics for success
Study question:
Develop a comprehensive plan outlining the metrics and data sources to be used for assessing compliance
and evaluating the effectiveness of the registry.
The policy goals of a rental registry program should define the metrics for its success. The state can measure
success both in terms of the program’s outputs (measurements related to the program’s operations) and
outcomes (measurements in changes to underlying societal or housing market trends).
Table A4: Evaluation themes, outputs and outcomes
Outcomes:
Outputs:
Program administrators and policymakers track
Evaluation theme Program administrators track directly through
through outreach with users, analyzing trends in
program budgets and registry data
market data, and other sources as needed
Number of properties and rental units
registered, total and by submarket (e.g., city,
county) Improved investment and policy decision-
Estimated compliance rate, total and by making by state and local governments to
submarket (e.g., city, county) address rental market challenges
Program impacts and Annual increases in number of registered Other metrics tied to program policy goals or
effectiveness properties or rental units compliance with a broader state policy (if
Number of individuals accessing portal data, applicable), such as reduced evictions,
reports, or other data sources increased rental affordability, reduced renter
Improved availability and visibility and of rental housing cost burden, etc.
market data to stakeholders including local
policymakers, renters, and housing providers
Total Full-Time Equivalent (FTE) staff positions
Number of technical assistance inquiries
Average time to resolve inquiries Increased ability to enforce or track a broader state
Operational and
Program revenues, total and per unit registered policy, if applicable
Financial Efficiency
Operating cost, total and per unit registered
Program operating losses (or revenues), total
and per unit registered
WASHINGTON RENTAL REGISTRY STUDY 40
Integration with existing registries
Study question:
If the statewide, or six largest jurisdictions registry, did not include information for those units already
registered in local programs, how much data loss would occur?
In collaboration with Commerce staff and Artesia Systems, evaluate the feasibility of working with local
government personnel to incorporate the necessary data elements into their current registries. Determine
the potential costs and timeframe required for all jurisdictions with registries to align their data fields with
the proposed statewide registry.
Provide an analysis of alternative methods that could be used to gather the required data for units in areas
that have current registries and assess how the effectiveness of those alternatives compares to a full
integration strategy.
There are 17 cities in Washington with existing rental registries, covering approximately 436,000 rental homes
in the state (about 40% of rental homes statewide, and 49% of rental homes in the six largest counties).
If a statewide registry or one limited to the six largest counties excluded rental properties already subject to
city-level registries it would result in a significant loss of data, either 40% or 49% of total rental housing
depending on the subject geography.
Existing city-level rental registry programs in Washington primarily focus on ensuring housing quality; most do
not collect unit-level data including rent or vacancy (only Olympia and Tacoma collect data on monthly rents;
Seattle collects data on vacancy indirectly by collecting tenant contact information). Most or all existing rental
registries in Washington collect and store data at the property level; converting the programs to collect and
store data at the unit level would increase program costs substantially and require significant changes to the
data infrastructure for each of the 17 existing registries. We do not know in precisely what format cities store
registry data at the property level (e.g., property address and owner information) or how easy it would be for
the state to access back-end data for integration with a statewide registry database. Most city programs
collect data via a digital portal and could provide data for integration into a statewide database with some
adjustments.
It is likely cost prohibitive to convert existing local registries to fully integrate into a state registry that meets
the requirements of the proviso. However, the state could work with local governments to gather property
address and owner information to support outreach. This would require imposing a second registration on
property owners subject to local registries or accepting a loss of data on property rents and vacancy status
for rental properties in cities with local registries.
There are several basic approaches to gathering the required data for rental units in areas that have existing
local rental registries:
Full integration of local registries into a state program: As stated above, modifying existing local rental
registries to collect unit-level data on monthly rents and vacancy would add significant complexity to the
cost, compliance and administrative needs, and IT infrastructure required to operate existing local
registries.
• This approach is likely not feasible.
WASHINGTON RENTAL REGISTRY STUDY 41
Partial integration of local registries into a state program with exemption: The state could work with
operators of local rental registries to integrate property address and owner contact information at the
property level into a state program, and exempt property owners in cities with local rental registries from
compliance with a state program. This would require the state to forego data on rents and vacancy for
the majority of integrated data.
• This approach would result in a loss of monthly rent and vacancy data for either 40% or 49% of total
rental housing depending on the subject geography.
Partial integration of local registries into a state program without exemption: The state could work with
operators of local rental registries to integrate property address and owner contact information at the
property level into a state program and use that information to support outreach efforts to property
owners to comply with a state rental registry.
• This approach would incur costs to pursue both the integration work and the outreach but could
improve initial compliance for property owners in cities with existing rental registries. It would
involve requiring a second registration for property owners in cities with rental registries.
No integration: The state could make no effort to integrate existing local registration data. It could ask
operators of existing local registries to support outreach efforts to property owners in their cities without
providing property information to the state.
• This approach would be less costly to the state and less costly to local governments than partial
integration, though it could result in lower compliance. It would involve requiring a second
registration for property owners in cities with rental registries.
For each of these approaches, to minimize costs and potential data loss, the state could focus data collection
and integration on three cities: Seattle, Spokane, and Tacoma, which together account for approximately 70%
of homes currently subject to rental registries.
Data security, availability, and IT requirements
Database Design and Information Infrastructure
The complexity of data collection and reporting requirements will impact the design of the database. Primary
drivers of database design, online portal, and IT infrastructure are likely to include:
The level at which the database collects and stores data: E.g., by property, by unit, or both.
The complexity of the online portal, including whether it needs to collect registration fees (and the scale
of these fees), and the number and type of users (e.g., creating a separate portal for tenants to access or
report data on their homes would add substantial complexity).
The process for exporting data from the database: E.g., developing a list of pre-formatted data reports
As the state evaluates a custom platform and third-party vendors to host the rental registry, it should
consider the cost and complexity of the database and its reporting features alongside program goals,
data capture, and other design choices.
WASHINGTON RENTAL REGISTRY STUDY 42
As part of the design of the database and online portal for the rental registry, Commerce and its partners will
also need to take steps to ensure the security of the database and online portal against cyberattacks.
Data access and reporting
Study question:
In collaboration with Commerce Staff and Artesia Systems, provide an analysis of how to address data
privacy concerns, especially regarding sensitive information such as property owner identity and monthly
rent charged. Based on these concerns, offer recommendations on which stakeholders should have access
to the data collected through the registry and to what extent of detail the data should be available.
To provide useful rental market information to a range of users including local governments, it will be critical to
ensure a level of data transparency while also safeguarding sensitive information, such as property owner
identity and monthly rents. To achieve this balance, the program should make different levels of data available
to different potential users or audiences.
Property owners and managers: Property owners and managers should have access to information
related to their property or properties via the online portal but should not be able to view information
related to other properties.
Tenants: Some rental registries include tenant portals, where tenants can access information related to
their rental homes or file complaints about violations related to policies (such as housing quality) the
rental registry supports. A tenant portal would add complexity to the IT requirements of the program. The
baseline rental registry design does not require a tenant portal.
Program administrators: Program administrators are likely to need access to the full database as well as
any data reports in order to track compliance and analyze market data. Commerce has systems to
regulate access to secure databases.
Other public sector users: If one of the state’s goals is to support state and local governments by
providing rental market data, it could provide this data in the form of full property data records, specific
data reports (which could remove identifying fields such as owner name and street address), or
aggregated data (such as a summary of rental units by zip code or another market area). The state
would need to balance the utility of various data formats against privacy concerns.
• Due to privacy concerns it is not advisable to share full property records with other public sector
users. Anonymized data reports or aggregated data could be valuable tools for state and local
governments.
General public: Some rental registries, such as Minneapolis, have open data portals that allow public
users to view, and download select data related to all properties. Some, like San Francisco, provide some
data to the public but require users to look up specific properties individually. The state could publish
some rental data on an online data portal for the public. It could also publish aggregated data and
market analysis, in the form of a public dashboard or market report, for public users to view market
trends.
WASHINGTON RENTAL REGISTRY STUDY 43
• An online dashboard of registration trends and market-level rental trends, which can update
automatically as new data becomes available, is likely to provide the most value to the public for
the lowest cost.
WASHINGTON RENTAL REGISTRY STUDY 44
Appendix B: Stakeholder engagement summary
Summary of relevant takeaways
HR&A conducted fourteen interviews with intermediary organizations, including rental housing associations
and other industry representatives, tenant advocacy groups, local government staff, and housing authorities,
as well as five listening sessions with tenants, housing providers (property owners and property managers),
and their advocates. Several themes emerged from the interviews and listening sessions which can directly
inform the design of a rental registry.
State and local government staff might be the primary users of a
statewide rental registry:
Public entities are interested in up-to-date housing data for policymaking and improved
communication with housing providers. Aside from state-level entities and tenant organizations, the
biggest proponents and primary users of a statewide rental registry are likely to be local (city and county)
staff without an existing registry. Such interviewees noted that having access to up-to-date information
about their local rental housing market would help them to make better-informed policy and investment
decisions. Representatives of cities with existing registries noted that the registry has led to better
relationships with housing providers, as city staff can contact them directly regarding any housing issues
or programs. Interviewees of cities without registries also voiced their interest in a registry as a tool to
improve communication with housing providers.
Local governments with rent registries prefer to retain their existing registries but are open to sharing
data with the state. Most local registries implement policies to improve housing quality of public safety
and include requirements for housing inspections. Multiple interviewees said that unless a statewide
registry had the same requirements as their existing local ones, they would prefer to continue with their
own requirements. Multiple interviewees were reluctant to layer their existing registry with additional
statewide requirements and thought it would lead to a regulatory burden for housing providers. City
representatives were willing to share their data with the state if it supported a statewide registry.
A state rental registry might not directly address renters’ most pressing
challenges:
As described in the proviso, a statewide rental registry would not directly support rental affordability,
which remains a priority for tenants and tenant advocates. Rental affordability challenges throughout
the state include high and rising rents, low housing quality, and housing instability. Many existing local
rental registries in Washington directly address housing quality by mandating a housing inspection. A
statewide rental registry could negatively impact existing challenges if property owners pass fees on to
their tenants or if owners remove their units from the rental stock to avoid further regulation. It would be
difficult for a rental registry to provide continuous tracking and analysis of tenant-level information (such
as income and loss of housing). This means that the registry would provide limited visibility into housing
affordability at the unit level.
Tenants and advocates find merit in a rental registry if it results in better housing quality or
transparency. Some local rental registries allow property owners to choose their own inspectors, and
tenant advocates expressed concern that these programs might not be effective at improving the quality
WASHINGTON RENTAL REGISTRY STUDY 45
and livability of rental homes. One interviewee also mentioned the need to ensure housing quality
statewide, particularly in rural areas where inspections are less common. Some advocates were also
hesitant about inspections, stating that renters can be reluctant to allow unknown people into their
home. Interviewees and some listening session participants voiced interest in a statewide registry that
improved real-time data on rental costs and provided contact information of housing providers. Tenants
felt that access to information about the ownership of rental properties would give them more agency
when looking for apartments to rent or raising issues about their apartments.
Property owners and managers oppose a state rental registry:
Housing providers believe that “no program is the best program.” Housing providers feel that their
industry is already highly regulated and expressed frustration with existing local registries, many of
which require inspections and annual fees. Providers oppose increased regulation and additional fees at
the state level. Commenters oppose a new statewide program, which many view as an overreach by the
government. Repeatedly in interviews and listening sessions, we heard from housing providers that the
state should not create a rental registry, and that having one would create added expense or burden on
them and tenants without providing a benefit. Multiple providers thought that conducting a housing
survey or using existing public and private data would provide information on rents without adding more
regulations on their operations.
Housing providers stated that a rent registry could increase housing costs and remove units from the
market, negatively impacting tenants. Multiple commenters said that further regulation would cause
them or other housing providers, particularly owners-managers with small rental properties, to sell their
properties. Providers stated that increased regulation would reduce the availability of rental housing as
some owners choose to leave the market. Interviewees and listening session participants also said
tenants would bear the cost of any fees associated with the registry, leading to higher rental costs.
A limited-scope program is likely to have broader support than a larger
and more complex program:
Despite housing quality concerns, requiring inspections could pose challenges for a statewide
program. Many existing local registry programs in Washington require property inspections. Property
owners reported that inspection procedures and findings can vary even within a particular city. Owners
of deed-restricted affordable rentals expressed concern about the costs and paperwork associated with
an additional inspection, as those units are already highly regulated by local and federal subsidy
providers. Requiring inspections for a statewide registry would be duplicative of or add complexity to
existing local registry requirements.
Some housing providers note that a statewide registry could be useful and more cost-effective if it
replaced local registries. There is a growing patchwork of local registries throughout Washington, many
of which are understaffed or under-resourced. Compliance with these registries adds cost and
complication to owners and managers, who must keep track of varying regulations, fees, and inspection
processes. Housing providers were amenable to a statewide program that could somehow replace local
registries, particularly those with properties across the state.
WASHINGTON RENTAL REGISTRY STUDY 46
Introduction
HR&A Advisors, working in partnership with the Washington State Department of Commerce (Commerce), is
leading efforts to study and design a proposed rental registry program for the Washington. One objective of
this project is to facilitate engagement to collect input from a range of stakeholders. The purpose of this
stakeholder engagement is to:
Understand how a rental registry might impact various stakeholders, including property owners, property
managers, tenants, and local governments
Understand the interests, concerns, and needs of these potentially impacted stakeholders
Assess perceptions of the proposed rental registry
Solicit input on the potential design of a rental registry program
Recognizing that a rental registry would impact stakeholders across the housing ecosystem, we conducted
strategic engagement with a variety of groups, including:
Housing providers (property owners and property managers) own and manage buildings and will be
directly impacted by a rental registry program as they would need to provide information for the registry
and be responsible for any fees and additional registry requirements.
Apartment associations and other industry organizations represent property owners and property
managers and lobby for policies that benefit housing providers. These associations are important
intermediaries to understand housing providers’ concerns.
Renters and tenant advocates can help to inform a rental registry’s design by providing insight into the
rental market challenges that tenants face and providing alternate perspectives to housing providers.
Local government staff understand local rental market trends and can provide input on the program
design and its potential impacts on local government capacity.
Housing authorities frequently have broad networks of property owners they work with through voucher
programs and can provide helpful context about the pressures facing both property owners and low-
income renters.
Summary of engagement activities and participants
Key informant interviews
We conducted 14 interviews with intermediary organizations, including:
Local governments (7)
Local housing authorities (2)
Tenant advocates (2)
Housing provider industry associations (3)
These interviews served two main purposes: they helped quickly survey stakeholders familiar with a broad
cross-section of perspectives on the proposed rental registry and allowed us to reach a broader network of
stakeholders. We designed interview questions to further understand the Washington rental housing
WASHINGTON RENTAL REGISTRY STUDY 47
landscape, identify challenges of existing rental registry programs and gather feedback on potential registry
components.
Stakeholder listening sessions
We conducted listening sessions to gather input from a broader audience of property owners, property
managers, and tenants, as well as their advocates. We reached out to potential attendees through intermediary
organizations and local government staff. Three listening sessions focused on gathering input from tenants
and tenant advocates, and two focused on gathering input from property owners and managers. Each session
lasted for 60-minutes; however, we remained after each session to hear all comments. In each session, we
provided a brief informational presentation, conducted polling both to capture participant information and to
gather input, and heard comments from attendees.
Renter and tenant advocate listening sessions
We convened three listening sessions for renters and advocates: one on June 18, 2024, one on August 6, 2024,
and the third on August 9, 2024. In total, 80 renters and tenant advocates registered to attend the sessions, but
only 26 participants attended. Despite low attendance, we had participants including renters and advocates
with experience in urban, rural, and suburban markets, a variety of housing types, and a range of familiarity
with rental registries. We did not reach renters from the eastern part of the state, although we did have input
from advocates that work statewide.
Question: What best describes you?
Renter: 1
Tenant Advocate: 6
Both: 7
No Response: 12
Question: Where do you live or provide advocacy?
Whatcom County: 2
Pierce County: 1
Snohomish County: 2
King County: 5
Spokane County: 1
Statewide advocacy: 1
No response: 15
Question: What type of building do you live in?
Single-family: 6
2-4 units/building: 1
5-19 units/building: 1
20-99 units/building: 2
100+ units/building: 4
Mobile home: 2
No response: 9
Question: What type of market do you live in or provide advocacy in?
Urban: 12
Suburban: 5
Rural: 2
WASHINGTON RENTAL REGISTRY STUDY 48
No response: 8
Question: On a scale of 1-5 (least to most), how familiar are you with rental registries?
1: 8
2: 0
3: 3
4: 5
5: 3
No response: 7
Housing provider listening sessions
We convened two listening sessions for housing providers: one on June 18, 2024, and one on June 21, 2024.
We had a total of 203 participants across these two sessions. Overall, we heard from property owners in
western and eastern parts of the state. The geographic distribution of participants matched the distribution of
rental housing throughout the state, though participation from housing providers with property in Spokane is
high compared to the percentage of rental housing in that county. The largest group of participants identified
themselves as owners of single-family rental homes, consistent with statewide trends.
Question: What best describes you?
Property owner: 86
Property manager: 52
Trade association representative: 7
No response: 86
Table B1: Question: What counties do you own or manage property in?
Response Participant count Percent of responses Percent of Renter-Occupied Homes (2022 ACS data)
King 64 32% 37%
Pierce 24 12% 11%
Snohomish 24 12% 9%
Spokane 42 21% 7%
Clark 5 3% 6%
Thurston 17 9% 4%
Whatcom 0 0% 3%
Yakima 2 1% 3%
Kitsap 10 5% 3%
Benton 0 0% 2%
Skagit 0 0% 1%
Cowlitz 0 0% 1%
Grant 1 1% 1%
Chelan 0 0% 1%
Kittitas 4 2% Less than 1%
Jefferson 2 1% Less than 1%
Grays Harbor 1 1% Less than 1%
WASHINGTON RENTAL REGISTRY STUDY 49
Response Participant count Percent of responses Percent of Renter-Occupied Homes (2022 ACS data)
Island 1 1% Less than 1%
Mason 1 1% Less than 1%
Pend Oreille 1 1% Less than 1%
Whitman 1 1% Less than 1%
No response 82 N/A N/A
Note: The table above excludes counties for which we had no poll respondents that also have less than 1% of the statewide renter-occupied homes.
Question: What residential property types do you own/manage?
Single-family: 69
2-4 units/building: 53
5-19 units/building: 31
20-99 units/building: 25
100+ units/building: 16
Mobile homes: 8
No response: 90
Question: How many residential units do you own or manage across Washington state?
1-25: 65
25-50: 8
50-100: 7
100-200: 9
200-500: 7
500-1,000: 6
1,000-5,000: 3
5,000-10,000: 2
10,000+: 6
No response: 94
Question: On a scale of 1-5 (least to most), how familiar are you with rental registries?
1 - Not at all familiar: 30
2 - Slightly familiar: 8
3 - Somewhat familiar: 19
4 - Moderately familiar: 14
5 - Extremely familiar: 34
No response: 98
Stakeholder Input
Below is a full summary of stakeholder input by stakeholder group.
Tenants and tenant advocates:
Renters and advocates had concerns about the effectiveness of existing rental registry programs.
Some existing local registries allow housing providers to choose their own inspectors, which raised
questions about the integrity of housing standards. One commenter who lives in Bellingham felt that the
city made too many concessions to property owners in the design of its program, including allowing
independent contractors. They hoped that a statewide program could add accountability.
WASHINGTON RENTAL REGISTRY STUDY 50
Renters and advocates want a housing registry that increases transparency and applies to all rental
units across the state to ensure equal protection for all tenants. Stakeholders voiced interest in a
transparent registry that captures and openly displays housing information and stressed the importance
of tracking changes in affordability year to year. Representatives of tenant organizations mentioned that
an open-source registry could support tenant organization efforts, assess renters’ rental burdens, and
even drive voter engagement. Tenants and advocates think that a registry will increase transparency by
allowing tenants to know who owns and manages their property or properties they are interested in
moving into. A few mentioned an interest in avoiding large corporate owners with whom they had already
had negative tenant experiences. A registry that displays housing providers’ contact information will also
let tenants contact their providers directly - one commenter who lives in Spokane expressed how difficult
it is for tenant protections to be effective when it is unclear on how to reach your landlord directly - a
registry could make this process easier and more transparent.
Renters and advocates voiced concerns that a state rental registry might have limited effectiveness or
create new costs for tenants. Listening session participants mentioned concerns that compliance and
enforcement of a rental registry program would be low, that fees would be too high for smaller property
owners, or that owners would evade payment. Advocates also acknowledged concerns that housing
providers would pass registry on to renters, exacerbating affordability challenges. One stakeholder
recommended that registry fees (and whether the property owner passed fees directly to the tenant)
should be transparent.
Commenters and interviewees preferred a statewide registry over a six-county strategy. Advocates
noted that housing quality challenges are more prevalent in rural areas which do not have housing
inspection policies. Advocates also said that surging rental prices are a concern across the state, not
only in more populous counties.
Renters and advocates are concerned about a statewide registry’s data privacy. Tenants and advocates
raised data privacy concerns in every listening session. Tenants questioned whether a registry should
capture inhabitants’ names or other personal information, and expressed concern that the state could
protect their privacy from data breaches. Listening session attendees were also concerned about
retribution from housing providers if tenants reported unregistered units.
Rising rents and housing quality are major concerns for renters and tenant advocacy groups across the
state. Other challenges included housing insecurity and difficulty finding or affording suitable rental
housing. Costs for utilities, garbage removal, and other monthly bills contribute to affordability
challenges even when rents appear low. Advocates indicated that homes in coastal areas often have
moisture and mold, while those in eastern areas are older and less likely to be subject to inspections.
Renters report difficult relationships with property owners. There is a lack of trust between tenants and
property owners. Multiple commenters mentioned rent gouging and concerns that housing providers
engage in predatory practices or allow unsafe property conditions. This concern also extends to
operators of mobile home parks. Several commenters expressed concern about tenant selection
practices including required income, credit score, and tenant rules. Renters and advocates stressed the
need for transparency and accountability in the rental housing market.
WASHINGTON RENTAL REGISTRY STUDY 51
Property owners and managers:
Most housing providers we spoke with believe that "no registry is the best registry." Approximately 160
housing providers and advocates attended HR&A’s listening sessions held on June 2024. Out of 91
commenters in the listening sessions, 88, or 96%, voiced skepticism, expressed doubt, or otherwise
opposed a statewide registry. 77% clearly stated that the state should not create a rental registry. About
48% of commenters expressed concern about the additional costs and administrative burden associated
with a rental registry and believed it would “only drive up rental rates.” Most housing providers strongly
oppose any effort to further regulate their industry – at least 39% of commenters saw a statewide
registry as a form of government overreach and interference in the private sector. About 33% of
respondents commented that the proposed regulations do not provide any clear benefits to housing
providers or tenants. They view a registry as unnecessary and ineffective. One commenter stated, "Still
unclear about what problem we are trying to solve. Why would we pay the state to gather our data?"
Multiple interviewees and commenters at the listening sessions stated that housing providers will pass
fees associated with a registry to tenants, which would drive up rental costs and contribute to the state’s
affordability crisis.
Housing providers have had negative experiences with existing registries. When asked about their
experience with existing registries, 47% of respondents expressed concerns about the additional costs
associated with existing registries. Others mentioned inspection and accountability issues. One
commenter stated, “Their inspector fails to submit his report and I have to hassle and have it done all
over again and they want to charge fees for their mistake.” Housing providers and industry
representatives that work across the state noted the challenge of complying with different regulations
across multiple localities. Several listening session participants noted that they were considering or
would consider selling property due to regulatory requirements.
Housing providers feel that their industry is already highly regulated and oppose additional regulation.
About 44% of commenters mentioned feeling overwhelmed by the existing regulations and dreading the
addition of more rules. One commenter stated, "Everything seems set up to discourage and complicate
the ability to provide housing, not to help." Owners and managers of deed-restricted affordable units
oppose a housing inspection requirement, because they are already subject to inspections through
federal and state subsidy providers. Smaller property owners feel that added regulations will
disproportionately affect them and could force them out of the market. One commenter stated that, "the
cost associated with fees just to be a landlord is pushing the mom & pop landlords out of the market."
They fear that a more complex regulatory environment might force them to hire a property manager or
sell their rental units, which they noted would impact tenants, either by driving up rental prices or
eliminating units from the market. Some stakeholders worried that a rental registry would be a precursor
to additional state regulations.
Skepticism about registries extends to data collection and sharing. Housing providers argue that
market data is available elsewhere, and that availability of registration data would be of little use to them
or to tenants. Multiple commenters viewed a statewide registry as a step towards surveillance and
control by the state, and about 14% of commenters expressed concerns about data security, one stating
the registry has “potential for a massive security breach, increased spam and potential scams.” Several
stakeholders suggested that the program should ensure anonymity or be voluntary to address privacy
concerns.
WASHINGTON RENTAL REGISTRY STUDY 52
If the state pursues a rental registry, providers believe it should be as simple as possible and should
create tangible value for property owners. Housing providers stated that a statewide registry would only
be valuable if it replaced the patchwork of existing local registries with one, streamlined, application. The
worst outcome, according to housing providers, would be for Commerce to add further regulations to
local registries, leading to complex and costly regulations. Industry representatives suggest that
incentives, such as a low cost registration fee, risk mitigation fund waivers for smaller buildings, or
waivers for affordable housing providers could increase the likelihood of a registry's success.
A few providers indicated that a registry could be useful if it connected housing providers, particularly
small housing providers, with resources to reduce costs. Technical assistance and support in
compliance with regulations, particularly for small housing providers, would help reduce costs. Financial
resources such as rental assistance or risk reduction could also be valuable to housing providers.
Local government and public entities:
Interviewed municipalities with existing registries saw limited value in a new statewide initiative. Local
government staff we interviewed questioned the purpose of a statewide registry and its benefits over
existing local initiatives. Municipalities that require building inspections with their registry were reluctant
to replace it with a statewide option that did not have an inspection component. They were also hesitant
of increased fees and regulations on housing providers already paying local registration fees. Staff
reiterated that housing providers tend to pass fees down to tenants and that these new requirements
could also cause further tension between municipalities, housing providers, and tenants. Interviewed
municipalities were open to sharing their existing registry data with the state to support a statewide
data-gathering effort but noted that they do not capture unit-specific rental information.
Interviewees acknowledged challenges with local registries and suggested improvements for a
statewide registry. Existing city-level registries do not track market data, and many undercount units due
to low compliance. Municipalities with local registries often do not share data with other public entities,
limiting their value for local and state policymaking and research. Staff in cities and counties without
registries expressed interest in a statewide program if they could access data. Interviewees
recommended making the registration free or adding clear programmatic incentives to garner more
support from housing providers and prevent costs from trickling down to renters.
Local governments would benefit from a statewide rental registry that captures real-time data but
expressed uncertainty about the policy goals behind a statewide solution. Current data from the Census
and local collections have delays and gaps, making it difficult to compare trends across municipalities or
counties. Some local governments and housing authorities would welcome a registry that provides data
on unit sizes, rent variations, and long-term trends. Two interviewees noted that the registry could
support county housing needs assessments and comprehensive plan updates. Others are skeptical that
the state can capture useful market data through a rental registry. Interviewed staff from two
municipalities noted that housing providers already track their portfolios and provide this data to third-
party real estate information companies such as CoStar. They doubted that a statewide registry would
capture better information. They proposed that a statewide housing survey could provide information
about the rental market without adding more paperwork and fees for housing providers.
Interviewees think that rental registries can improve communication between municipalities and
housing providers. Interviewed staff from cities with registries highlighted that communication with
WASHINGTON RENTAL REGISTRY STUDY 53
providers has improved because of the registry. They mentioned that collecting providers’ contact
information and regularly interacting with them has led to more open communication, leading providers
to reach out directly for housing concerns or programs. Interviewees from cities without a registry also
mentioned that a registry would help improve their communication with providers.
Attachment: listening session presentation
Listening session presentation available on Box (PDF)
WASHINGTON RENTAL REGISTRY STUDY 54
Appendix C: Rental registry case studies
Summary of relevant takeaways
It is likely that a statewide rental registry in Washington would not exactly follow any of the models in the four
cases we studied. However, each offers lessons on the design of a suitable program.
On the whole, the case studies point to two potential models for a statewide rental registry in Washington:
1. Registry as a policy enforcement tool: Three of the four cases we studied (Los Angeles County,
Minneapolis, and San Francisco) are relatively large, complex registry programs. This is because their
primary purpose is to support compliance for other housing programs. In the case of Minneapolis, the
rental registry supports an inspection program to ensure that rental housing meets habitability standards.
In Los Angeles County and San Francisco, the rental registries are designed to track compliance with rent
stabilization programs.
2. Registry as data gathering tool: Ohio’s property registry has data gathering as a primary goal. In particular,
the goal is for county governments to be able to identify property owners in the case of property damage,
emergency, or code violations. The state does not incur any costs to oversee this program because the
administration occurs at the County level. However, the program does not generate funding to pay for
County administrative costs, and the state does not aggregate or report any data. If Washington wants to
pursue a data gathering registry it should design a program that has the minimum costs and administrative
needs to produce useful data.
Clear compliance mechanisms are important to program design, but it is also likely that rental registry
compliance will be low in the first few years:
Minneapolis has clear mechanisms to incentivize compliance. These include opportunities both to
reduce fees by registering early or participating in a good landlord program, and penalties for
noncompliance (25% penalty). Minneapolis has over 90% compliance with its rental registry. By contrast,
Los Angeles County and San Francisco charge only a 5% to 10% penalty, and do not offer incentives for
compliance. Those rental registries also prevent non-compliant property owners from raising rents on
rent-stabilized properties.
Los Angeles and San Francisco have seen low compliance in their first years of operations. Both
programs started in the last few years and have had low (around 5%) compliance to date. This may be
due in part to ongoing complications from the COVID-19 pandemic and related impacts to the housing
market (such as temporary rent freezes). Los Angeles County waived rental fees for its first year as a
way to incentivize early compliance.
Summary by case study
Ohio’s Residential Rental Property Registry program provides helpful insight for Washington both into how a
state can design a limited rental registry and the challenges to doing so effectively. Due to the difficulties that
Ohio’s approach creates for Counties and the challenges to aggregate data for a disaggregated program, this
model is not likely to be successful for Washington.
LA County’s Rent Registry program showcases the initial challenges of implementing a registry, creating
specific requirements for mobile homeowners, and the merits of an online portal for tenants and housing
providers. The program includes specific regulations and fees for mobile homes. The primary goal of the Rent
WASHINGTON RENTAL REGISTRY STUDY 55
Registry is to support the implementation and monitoring of the County’s rent stabilization and just cause
eviction ordinances for rental units and mobile homes. Because of this focus, LA County’s model may be less
relevant to Washington.
The Minneapolis Rental License Program demonstrates how incentives and technical assistance can improve
compliance and help meet program goals. The city’s open data portal promotes transparency, while its
inspection requirements ensure safety and quality. The program has had consistently high compliance. The
primary goal of the Minneapolis Rental License Program is to ensure that the city’s rental housing stock is
code compliant and livable. A statewide rental registry in Washington is unlikely to include an inspection
requirement, so those aspects of Minneapolis’s program are not relevant. However, Minneapolis structures its
fees to encourage property maintenance and the prompt resolution of any issues and provides opportunities
for owners to reduce their fees through early compliance, demonstrating how fees and compliance
mechanisms can produce high compliance. In addition, Minneapolis shows how a rental registry can promote
transparency through an open data portal.
San Francisco’s Housing Inventory has had low compliance in its first years of operations, highlighting the
importance of adequate outreach and compliance strategies. The goal of the program is to enhance the Rent
Board’s ability to oversee the city’s rent stabilization policy. Because of this focus, and because the primary
compliance mechanism relates to allowable rental increases, San Francisco’s model is less relevant to
Washington. However, Washington should consider using a range of outreach approaches to encourage early
compliance.
Introduction
We developed case studies of four rental registry programs to understand a range of policy goals and designs
for rental registry programs, as well as potential mechanisms for compliance and lessons for Washington as it
considers creating a statewide rental registry. We chose these case studies for their ability to illustrate a range
of purposes, structures, and geographies, with a focus on West Coast models:
Ohio Residential Rental Property Registry, State of Ohio
Los Angeles County Rent Registry, Los Angeles County, CA
Minneapolis Rental License Program, City of Minneapolis, MN
San Francisco Rent Board Housing Inventory, City of San Francisco, CA
The original intention was to develop case studies for four state-level rental registries. However, we
determined that of the limited number of existing state rental registries, only Ohio offered relevant insight for
Washington. There are a few other state-level rental registries, including in New York, Maryland, and Rhode
Island, but these rental registries apply to only specific properties and have a narrow focus (tracking rent
stabilization or environmental hazards in older housing) that were not relevant for Washington.
WASHINGTON RENTAL REGISTRY STUDY 56
Case studies
Case study | Ohio's Residential Rental Property Registry
State of Ohio
Ohio’s Residential Rental Property Registry program provides helpful insight for Washington both into how a
state can design a limited rental registry and the challenges to doing so effectively.
In 2006, the State of Ohio passed legislation establishing a residential rental property registration for counties
with populations over 200,000 residents. The stated goal of the program was to support first responders in
identifying the ownership of properties when they are damaged, such as in the case of natural disaster or fire,
however Counties mostly use registry data for code enforcement (Interview with Program Staff). Property
owners must register rental properties with their county auditor, but the registries typically collect minimal data
(Ohio Department of Taxation). While the law only requires counties with more than 200,000 residents to
establish a registry, other cities or counties can establish a rental registry. The state does not administer the
program; County Auditors within each county oversee administration. The program carries no cost for the
state but also produces no state-level data. Counties have limited enforcement mechanisms and no revenue to
support administration, which creates challenges to effective implementation (Greater Ohio Policy Center).
Key facts
Year created 2006
All residential rental property owners in counties with more than 200,000 residents per the most
recent decennial census (Currently 15 counties: Franklin, Cuyahoga, Hamilton, Summit,
Coverage
Montgomery, Lucas, Butler, Stark, Lorain, Warren, Lake, Delaware, Mahoning, Clermont, Trumbull).
The program treats mobile homes as residential rental property. (Approximately 1,120,000 units)
Local determination (state requires registration within sixty days of a change in the ownership
Re-registration
information)
Fee None
Property Owner Name, Address and Phone Number
Property Street Address and Permanent Parcel Number
Data captured
Other data (local determination)
Rent data is not required by the state. No counties collect rent data.
Property inspection Local determination
Varies by county. Some counties do not publish data. Others provide a comprehensive list of
Online portal and data availability
registered properties. Montgomery County organizes data by tax district.
Compliance Varies by county, generally unknown. State does not collect data or track compliance.
Short-term rental considerations Yes, the program treats STRs as rental properties (Ohio Department of Commerce)
Background
History and context
Ohio created the Residential Rental Property Registry in 2006 to help first responders identify the true
ownership of residential properties in case of damage. The state initially required every county to develop a
rental registry. However, after pushback from smaller counties, the state amended the law in 2007 to apply
only to counties with populations over 200,000 residents (Greater Ohio Policy Center).
WASHINGTON RENTAL REGISTRY STUDY 57
Legal authority
H.B. 294 of the 126th General Assembly created the Residential Rental Registry. H.B. 294 required all counties
to create a registry. As a result of backlash, H.B. 119 of the 127th General Assembly amended the law to only
require counties with over 200,000 residents to create a registry.
Initial implementation
There is limited documentation about what if any stakeholder engagement occurred prior to approval of H.B.
294.
Because of the decentralized nature of the program, outreach practices to property owners vary by county
according to local priorities and capacity. Some counties send notifications via mail to alert property owners
that they are not listed in the rental registry. Others might conduct minimal to no outreach depending on the
priorities of elected officials (Interview with Program Staff).
Startup costs also varied by County, but the state incurred minimal costs for the initial implementation.
Program operations, administration and costs
Program administration occurs exclusively at the local level. The state does not provide oversight into the
program beyond ensuring that counties that meet the population threshold have a rental property registry.
There are no reporting requirements from the counties to the state, and the state does not publish a record of
existing registries or registration data (Greater Ohio Policy Center). The costs to the state are therefore
minimal.
Counties have broad ability to set local program requirements, such as whether to administer the non-
compliance fee, requirements regarding inspections, and additional information to collect (Interview with
Program Staff). Program costs therefore vary by county. The state does not provide any funding to the
counties to administer the program. State law authorizes a non-compliance penalty fee which could help fund
program administration at the county level, but most counties do not enforce this fee, so funding often
originates from each county’s general fund. According to program staff, one county, which is currently focused
on maintaining the minimum requirements, has four staff members in the department overseeing the program,
among other responsibilities in the county. We were not able to identify a specify number of full-time
employees (FTE) necessary to administer the program. However, the cited county has a population of over
500,000.
Program features
The program establishes the minimum standard of information for county auditors to collect, and the penalty
for non-compliance (Ohio Department of Taxation). County governments make their own determinations about
program administration and specific features.
Compliance mechanisms
Non-compliant property owners can be subject to a $50 to $150 fine per property and a minor misdemeanor
charge. County Auditors decide whether to enforce compliance, but according to program staff, many do not.
Only Franklin County appears to assess fines. Program staff for a different county recalled sending mail
notifications of the registration requirement to property owners, but that did not result in assessing fines.
Rather, the county decided to discontinue mail notifications due to backlash.
WASHINGTON RENTAL REGISTRY STUDY 58
Data availability
The state does not maintain an online portal as all registration occurs through local governments and county
auditors. Several localities use an online portal to facilitate the registration process. Counties differ in how they
provide data on registered properties, ranging from a comprehensive database of all registered properties to
listings of all filed registrations.
Impacts and lessons learned
Program impacts and effectiveness
Program effectiveness is limited due to the lack of enforcement mechanisms available to the counties, and the
decision of many counties not to impose fines or misdemeanor charges on noncompliant property owners.
One county program staff member estimated that their registry included 20%-25% of all properties in the
county.
Currently, while first responders still use the registries, the program is often more targeted towards identifying
absentee landlords. Several counties use registries as part of their code enforcement strategies, however the
lack of statewide data collection or sharing makes it difficult to track “bad actors” with rental properties in
multiple counties (rental property owners with persistent code violations or blighted or unsafe conditions).
Implementation and participation challenges
The state law created an unfunded mandate for the counties to create and administer rental registry programs
(Greater Ohio Policy Center). It appears that the primary ways in which most counties have addressed this
challenge is by creating rental registries with limited scope and enforcement. Counties experience challenges
in administering the program, both from a design standpoint and an enforcement perspective. The state does
not provide any assistance when a new county needs to set up its registry. Further, the state has not specified
counties’ enforcement rights. As one county official stated, “we are not the police.”
Counties are often working to engage local property owners to increase participation, to varying degrees of
success. State law requires county auditors to include a statement on property tax bills about the registration
requirement, and to provide notice at the sale of a residential rental property. Counties identify non-compliant
property owners through approaches including complaints from tenants, by notifying new property owners of
the registry program, and by researching whether registered property owners own other properties in the
County. However, because many county auditors do not enforce compliance, outreach does not often lead to
new registrations. It is unclear if registrations have increased or decreased over time.
Equity Considerations
The state law does not provide any direction to the counties on how to incorporate racial equity
considerations. Stakeholders indicated that counties focus on increasing overall compliance to the extent they
are able, and do not pursue more equity-oriented efforts.
Lessons Learned
Ohio’s Residential Rental Property Registry program provides helpful insight for Washington both into how a
state can design a limited rental registry and the challenges to doing so effectively.
State law can establish registries at the local government levels but should consider the administrative
impacts to local governments. All the largest counties in Ohio manage rental registries. The program
also set a precedent for other localities to develop their own registries. However, the program creates an
administrative burden for Counties without providing revenue to pay for administrative costs, leading to
high variability in enforcement and impacts.
WASHINGTON RENTAL REGISTRY STUDY 59
Program design should reflect program goals and provide the necessary structures to produce impacts.
Ohio’s program lacks a clear purpose. In addition, the state does not provide oversight or data gathering,
which limits the program’s effectiveness at both the County and state level. Without developing the
infrastructure for a state-level registry, it can be challenging to aggregate the county-level data into a
comprehensive database. The state could theoretically collect the minimum required data from each
county related to property location and ownership, but there is variation between counties not just in the
type of information collected but also in the way that counties collect and store information. Any effort
by the state to consolidate information would require lengthy efforts by staff to re-organize county data
into a statewide database, and data availability would be inconsistent.
Due to the difficulties that Ohio’s approach creates for counties and the challenges to aggregate data for a
disaggregated program, this model is not likely to be successful for Washington.
Case study | Los Angeles County rent registry
Los Angeles County, CA
LA County’s Rent Registry program showcases the initial challenges of implementing a registry, the
importance of adequate outreach and the need to provide incentives for registration.
Los Angeles County established the Rent Registry program in 2020 to track rental rates in unincorporated
areas of LA County. The program was created to assist the implementation and monitoring of the County’s
rent stabilization and just cause eviction policies. LA County’s Registry has a simple, flat-fee structure, which
includes a set fee for mobile homes. The online portal allows property owners to submit necessary rental
housing information to comply with the County’s rent stabilization ordinances. This includes details on tenancy
changes, rental rates, and amenities, as well as the payment of annual registration fees for program
administration and enforcement. Tenants can also log into the online portal to review information about their
rental unit or dispute a rent increase.
Key facts
Year created 2020
Coverage All rental homes in unincorporated areas of the County (Approximately 107,500 units)
Re-registration Annual
Fee Annual fee based on unit type (rent stabilized and/or just cause eviction)
Owner information
Property manager information
Unit number
Number of bedrooms
Occupant name
Data captured Occupant type (tenant, family member, other)
Occupant characteristics (senior, children, disability, low-income)
Amenities in unit
Rent amount
Date of occupancy
Date of last rent increase
Property inspection No
Online portal and data availability Yes, open to property owners and tenants. Unit-level data available.
WASHINGTON RENTAL REGISTRY STUDY 60
Low (4%). Low compliance during initial years of implementation could be due in part to roll-
Compliance
out complications and rent freezes during the COVID-19 pandemic.
Short-term rental considerations No
Background
History and context
The County launched the online Rent Registry in late 2021 to supporting implementation and monitoring of
their rent stabilization program. The Registry provides the County with a tool to regulate rent increases and
safeguard tenants and mobile homeowners from excessive rents and evictions
In 2018, the County implemented an interim Rent Stabilization Ordinance in unincorporated areas to stem rent
hikes and mitigate evictions, which were rising in the area. From 2018 to 2020, when the interim ordinance was
in place, property owners sought an average rent increase of 28%, or $313 per month per unit (LA County Rent
Stabilization Ordinance, 2021). Renters, attorneys and activists urged the County Board to extend the
ordinance, saying it would help keep residents in their homes. This successful tenant advocacy prompted the
County to pass new, permanent ordinances. Landlord groups opposed the rent stabilization ordinance, saying
it would force them to raise rents where they otherwise wouldn’t. They also argued that the measure would
disproportionately impact small apartment owners who may be unable to cover building and operating
expenses if they’re unable to adequately raise rents.
In parallel, the County also enacted a mobile home rent stabilization ordinance. The ordinance was spurred by
the number of mobile homes in the county and their owners’ demographics. There are approximately 6,000
mobile homeowners in the unincorporated County. About 79% of mobile homeowners are over 45 years old,
more likely to rely on public subsidies, and often have disabilities (LA County Mobile Home Rent Stabilization
Ordinance, 2021). These vulnerabilities leave mobile homeowners with little leverage in negotiating space
rents with park owners. High moving costs, potential damage, installation requirements, lack of alternative
spaces, and significant investments in their homes further disadvantage them. By enacting a rent stabilization
ordinance focused on mobile homes and supporting it with a rent registry, the County aims to keep this
vulnerable population housed.
Legal authority
The County created the Registry through two rent stabilization ordinances: the Rent Stabilization and Tenant
Protections Ordinance (RSTPO) and the Mobilehome Rent Stabilization and Mobilehome Owners Protections
Ordinance (MRSMOPO).
Initial implementation
According to an interview with Los Angeles County Department of Consumer and Business Affairs staff,
COVID-19 pandemic delayed the program’s rollout, which started soon after the ordinances’ approval in early
2020. Limits to in-person meetings and pauses in the County services limited stakeholder engagement prior to
program launch. The County engaged property owners and advocacy groups through social media and mailing
lists. To support property owners who missed tenant payments during the pandemic, the County waived fees
for the first year of operations. The County sends annual mailers to all property owners in unincorporated
areas to remind them to register their property.
WASHINGTON RENTAL REGISTRY STUDY 61
Program operations, administration and costs
The Department of Consumer and Business Affairs (DCBA) hosts the County's Rent Registry program. The
DCBA received $1.79 million from Consumer Protection Settlement funds to create the Rent Stabilization Unit,
which included the cost of 12 full-time staff as well as services and supplies. At implementation, DCBA
estimated an annual budget of $5.6 million to implement the program, accounting for 29 full-time staff,
operation expenses, and relocation support. The County expects these costs to be covered by registration and
application fees as the program matures. 3Di Systems, a third-party vendor, supplies the software for the
online registry portal.
Table C1: LA County's Registry fee schedule
Property type Fee/unit Description
Multifamily properties built before 1995 which are subject to rent stabilization as well as “Just
Fully covered rental units $90
Cause” eviction protections
Rental properties that are not subject to rent stabilization, but are subject to “Just Cause”
Partially covered units $30
eviction protections (single-family rentals and
Mobile homes $90 Mobile home parks and “pad” rentals
Source: LA County’s Rent Registry
Compliance mechanisms
The County imposes a 10% late fee on already-registered property owners who fail to pay their units’ fees by
the annual deadline. The County has no way of tracking unregistered property owners, and therefore cannot
impose late fees on them. Property owners who do not register their units face restrictions on increasing their
tenants’ rents. Tenants and mobile homeowners can submit an online form to the County if their home is
unregistered or if their housing provider is raising rents higher than what is allowed by law.
Online portal
LA County launched the online portal in 2021. The portal allows property owners to register their rental units
online and pay registration fees. Tenants can also use the portal to look up reported rents for their unit.
Impacts and lessons learned
Program impacts and effectiveness
The County estimates that 4% of all rental units have been registered since registration became mandatory
and the portal began operating in 2020.
Implementation and participation challenges
To date, the program has had limited success with rental registrations. The County estimates that 4% of all
rental units are registered in the three years of the Registry’s operations. Restrictions to in-person meetings
and pauses in the County services limited stakeholder engagement prior to program launch, which likely
deterred initial program participation. To improve program success, the County conducts annual outreach
through mailers to property owners. The County is also exploring further compliance mechanisms because the
10% late fee has not been effective at improving registration rates.
The program’s revenues do not currently cover its operating costs. The County is currently reviewing a new fee
structure which would increase fees to help pay for the program’s costs and add nuance of fee amounts based
on housing and owner type. The County is also pursuing other strategies to improve its operations by
expanding its contract with 3Di Systems to subcontract parts of the program’s operations, including
WASHINGTON RENTAL REGISTRY STUDY 62
monitoring compliance and supporting online portal users. The Department of Consumer and Business Affairs’
staff would oversee designing further program upgrades.
Equity considerations
The County is reviewing an alternative fee structure for small property owners who could be unable to pay
registry fees and increasing support for those who face challenges with online applications. The County is
separately working to address rental unit livability and property improvements through the Rental Housing
Habitability Ordinance and the Rent Escrow Account Program (REAP).
Lessons learned
LA County’s Rent Registry program showcases the initial challenges of implementing a registry, the
importance of adequate outreach and the need to provide incentives for registration.
Successfully registering rental units takes time and continuous effort. The County chose to waive
registration fees the first year of operations to encourage housing providers to register. Despite this
initial effort and continuous outreach to property owners through physical flyers. To date, only 4% of
eligible units are registered, although registration rates have increased with each annual cycle.
The fee structure is affordable to housing providers and has specific fees for mobile homes but fails to
finance the registry’s annual costs. Unlike other registries, LA County charges a flat fee to housing
providers based on the unit’s rent stabilization provisions and whether the unit is a rental apartment or a
mobile home. However, the fee is too low to cover all program costs and fails to make special
considerations for small housing providers.
An online rent registry portal can be used by housing providers and tenants. The online portal allows both
housing providers and tenants to review information about their rental unit. Tenants can also use the online
portal to report their unit’s registered status and any unauthorized rent increases.
Case study | Minneapolis Rental License Program
Minneapolis, MN
The Minneapolis Rental License Program demonstrates how incentives and technical assistance can improve
compliance and help meet program goals.
The Minneapolis Rental License Program supports the city’s goal of promoting health and safety of homes for
renters. The program combines a registry with a property inspection program and has a fee structure based on
property condition that incentivizes proper repair and upkeep. The city provides workshops to help property
owners and managers meet regulatory requirements, address code violations, and lower fees. In addition, the
program has open data dashboards that allow users to track active rental licenses, housing violations, and
property conditions, with fees assigned based on property quality. The city takes a renter-centered approach by
pairing its Rental License Program with a Renters Rights Office, which provides support to tenants living in
unfit rental homes. The city’s open data portal promotes transparency, while its inspection requirements
ensure safety and quality. Minneapolis has had consistently high compliance rates.
WASHINGTON RENTAL REGISTRY STUDY 63
Key facts
Year created 1998
Coverage All rental homes (Approximately 112,000 units in 25,000 properties)
Re-registration Annual
Fee Annual fee based on property condition tier and building size
Rental property address
Property owner information
Building location
Data captured
Total building units and total rental units
Number of bedrooms per unit
The program does not collect data on monthly rents
Property inspection Yes, frequency varies
Yes, open source data portal allows visitors to view or download all data at the unit level as
Online portal and data availability
well as summary data.
Compliance High (92%). Historical trends not available.
Short-term rental considerations Yes, additional requirements
Background
History and context
The city established its Rental License Program in 1998 to support tenant health and safety through
standardized monitoring and quality improvement. Most Minneapolis residents rent their homes and lack the
authority to undertake repairs. The majority of rental homes in Minneapolis were built prior to 1970. Older
housing is more likely to need maintenance and repairs. The program aims to address these issues by
enforcing housing standards and ensuring property owners maintain their properties.
Legal authority
Minneapolis has a home rule charter which gives it broad authority. The Minneapolis Code of Ordinances, Title
12. Chapter 244. Article XVI. Rental Dwelling Licenses codifies the program. The article includes applicability
and exceptions of the ordinance, the application process, additional requirements for short-term rental
dwellings, minimum inspection standards, license fees, and procedures for property owners and tenants.
Initial implementation
Due to the age of the program, current city staff lack insight into the program’s initial implementation and
stakeholder engagement.
Program operations, administration and costs
The city’s Regulatory Services Department oversees the Rental License Program. The Department has over
120 Full-Time Equivalent (FTE) staff and includes program administrators, clerks, and inspectors who work on
the housing inspections and registry program in addition to other related tasks. The 2024 budget for housing
inspections was just under $7.0 million.
Property owners can apply for a rental license, pay annual license bills, and provide unit updates online through
the Minneapolis’ Rental Licenses website. Property owners can book appointments online or visit a Service
WASHINGTON RENTAL REGISTRY STUDY 64
Center to receive additional assistance submitting or updating a rental license. Property owners and tenants
can also call the city’s 311 number to receive assistance on specific questions regarding a unit’s rental license
and inspections.
The Rental License Program has four main components: the registry, an inspection program, training for
property owners, and an online portal. Each of these works to advance the city’s goal of ensuring that rental
homes meet health and safety standards.
Registry fees
The registry fee is comprised of two separate components: a license fee and a supplemental fee. The license
fee includes a base building fee and an additional per-unit fee. The city uses a tiered fee structure under which
the fee increases based on the number of rental units and the property conditions tier, based on two years of
data on property conditions including inspections and violations.
Table C3: Minneapolis rental license fee, based on property condition tier
Building fee, 1-3 unit Fee per unit, 1-3 unit Building fee, 4+ unit Fee per unit, 4+ unit
Property condition tier
buildings buildings buildings buildings
Tier 1 (default tier) $85 $35 $145 $10
Tier 2 $90 $65 $170 $25
Tier 3 $105 $165 $200 $85
Source: City of Minneapolis
The supplemental fee is based on a combination of the property conditions tier and the property management
score. The Property Management Score reflects how long it takes a property owner to comply with rental
licensing standards. This allows the city to focus inspections on the buildings that need them most. Property
Management Score elements include the number of re-inspections conducted to address property condition
violations, the number of administrative citations to gain compliance, late payment on rental licenses, any
special assessments incurred for grass or trash removal, and actions taken to revoke a rental license.
If the Fee Level is higher than the Property Conditions Tier, it means that the city spent additional resources
making sure that the issues found during inspection were addressed and fixed.
Table C4: Property Conditions Tiers, Minneapolis Rental License Program
Property conditions tier Inspection frequency Description
Tier 1 (default tier) 8 years Property is well-maintained and meets minimum housing code.
Property is well-maintained but has a few violations that could have an urgent
Tier 2 5 years
impact on renter safety and habitability.
Property is poorly maintained. There are several violations, and it is likely that
Tier 3 1 year
more than one has an urgent impact on renter health and safety.
Source: City of Minneapolis
Rental property owner workshops
The city hosts workshops (also available online as “on-demand” trainings) for rental property owners and
managers. The training covers an overview of the rental license program, fees, and renewal requirements; the
inspection process; common code violations; and property owner responsibilities to renters.
WASHINGTON RENTAL REGISTRY STUDY 65
Compliance mechanisms
In addition to using a fee structure that incentivizes keeping properties in good conditions, the city uses a
combination of incentives and penalties to encourage property owners to comply with registration. City staff
interviewed noted that compliance is primarily driven by calls to 311 from tenants or advocacy groups
reporting unregistered units.
Incentives:
The city reduces the annual license fee by 50% for applications submitted between September 1 and the
end of February each year (license fees are due March 1).
Owners and managers of single-family homes who attend a city-hosted workshop receive a $250 discount
on their annual fees for a period of five years.
Penalties:
Rental license renewals received 15 days after the annual deadline are subject to a penalty charge of 25%
of the license fee up to $3,000.
Property owners can’t rent a unit unless they have an up-to-date license for the building.
Online portal
The City of Minneapolis has several open data tools available on their website for the Rental License Program.
The dashboards are publicly available, and the public has free access to view and download data. Users,
including housing providers, renters, advocacy groups and policymakers can check information about a
specific unit or building, as well as identify city-wide trends. Available dashboards include:
Regulatory Services Violations Dashboard: An interactive, citywide list of locations of Housing Maintenance
Code and Fire Code violations.
Active Rental Licenses Dashboard: A list of all rental licenses in the city, which includes the rental property
address, the property's tier score, and contact information for each property.
Rental Tiering Dashboard: A report on property condition scores, tier assignments, and fee levels.
Treatment of Short-Term Rental Properties (STR)
The city licenses STRs under a separate program. STR licenses follow the same fee structure and inspection
cycle as regular rental licenses. STRs have additional requirements including insurance requirements, neighbor
notification, and ownership limits.
Impacts and lessons learned
Program impacts and effectiveness
The Rental License Program currently has over 92% of rental units registered and in compliance. Of the
112,150 units in the rental registry, over 103,000 (92%) are Property Condition Tier 1, and only about 3,300 (3%)
are Property Condition Tier 3. Compliance and property condition data from previous years is unavailable.
Implementation and participation challenges
The Program was initially implemented in 1998, more than 25 years ago. City staff who presently work on the
program are unfamiliar with initial implementation challenges.
Equity considerations
The city takes a person-centered and renter-first approach to code enforcement and inspection to reduce the
impacts of housing instability on Minneapolis’s most vulnerable residents. Renters are a majority of the city’s
residents and also disproportionately residents of color. The Inspection Services Division pays particular
attention to the impacts of its programs in BIPOC communities.
WASHINGTON RENTAL REGISTRY STUDY 66
Lessons learned
Minneapolis’s approach to its rental registry promotes transparency, safety and quality in rental housing and
centers the needs of tenants while providing guidance for housing providers to reduce the costs of
compliance. A statewide rental registry in Washington is unlikely to focus primarily on housing quality and
inspections as Minneapolis’s program does. However, Minneapolis’s emphasis on data collection and
strategic enforcement, strong incentive and penalty structures, and adequate implementation for capacity can
be applicable to Washington.
Incentives, fee structures, strategic enforcement, and technical assistance can increase compliance. The
program has achieved a high compliance rate. Approximately 92% of rental units have a license and are
compliant with inspection requirements. This achievement is partly due to the program’s tenure (over 25
years) and the city’s capacity for implementation. City staff have also stressed the importance of
prioritizing data collection and management in order to be strategic in their interventions and to monitor
progress toward compliance. Incentives for compliance with quality standards, such as reduced
inspection frequency and reduced fees, have also contributed to the program’s success.
Adequate fees can support program operations. The city’s comprehensive fee structure rewards housing
providers that responsibly manage and maintain their units. However, fees escalate for owners of properties
with multiple, recurring violations. These fees help support the program’s costs.
Case study | San Francisco's Rent Board Housing Inventory
San Francisco, CA
San Francisco’s Housing Inventory has had implementation challenges in its first years of operations,
highlighting the importance of adequate outreach and compliance strategies.
In 2020, the San Francisco Board of Supervisors amended the City’s Rent Ordinance to establish a Housing
Inventory. The purpose of this inventory was to enhance the Rent Board’s ability to oversee the city’s rent
stabilization policy by maintaining an accurate inventory of the city’s residential rental housing. Through the
program, property owners pay an annual fee and maintain accurate information on their properties (updated
annually) to qualify for the annual allowable rent increases (Rent Board). The program is still new, and
compliance rates are low to date. The Housing Inventory demonstrates how a rental registry can operate
alongside a rent stabilization program to track detailed property information.
Key facts
Year created 2020
All property owners are required to report certain information about their residential
Coverage
properties. Approximately 406,000 units.
Re-registration Annual
$59 per dwelling unit, $29.50 per guest room (e.g., SROs). 50% of the fee can be passed on to
Fee
the tenant under the city’s rent stabilization policy.
Owner-occupied units:
Name
Confirmation that unit is owner-occupied.
Data captured
Non-owner-occupied units
Name and business contact information of property owner or property manager
WASHINGTON RENTAL REGISTRY STUDY 67
Business registration number
Square footage of unit (in 250 square foot increments)
Number of bedrooms
Number of bathrooms
Date current occupancy began
Rent paid by tenant (in $250 increments)
Utilities included in rent
Vacant units:
Name and business contact information of property owner or property manager
Business registration number
Square footage of unit (in 250 square foot increments)
Number of bedrooms
Number of bathrooms
Date current vacancy began
Start and end dates of any other vacancies or occupancies that have occurred during the
past 12 months
Property inspection No
Yes. Public users can search properties by address or parcel number to view the registration
fee amount, how much has been paid, which units have been registered, and which units
Online portal and data availability received a rent increase license. The portal only provides data on the searched property.
Users can not view or export the full database in a single query. Tenants and Property owners
can submit information through the online portal.
Low (5%). The city’s primary compliance mechanism is withholding rent increase licenses for
Compliance non-compliant property owners. COVID-era rent freezes and other pandemic-era
complications could have limited early compliance.
Short-term rental considerations No
Background
History and context
San Francisco passed a Rent Ordinance in 1979 to limit rent increases on units built before June 13, 1979. The
Ordinance established the San Francisco Rent Board to administer the Ordinance. For many decades, the city
managed tenant-landlord relationships without a formal inventory for tracking units governed by the Rent
Ordinance.
In 2020, the city passed an amendment to the Rent Ordinance that established the Housing Inventory. The
Inventory requires all properties subject to the Rent Ordinance to be registered with the San Francisco Rent
Board. Additionally, the amendment requires property owners to obtain a license to increase rents, including
increases within the allowable range under the Rent Ordinance. These changes went into effect Jan. 18, 2021.
According to a report from the Budget and Legislative Analyst’s Office, the purpose of the program was to
provide information for the Rent Board in order to investigate housing services provided to tenants, analyze
rents and vacancies, monitor compliance with the rent ordinance, generate reports, and provide assistance to
landlords, tenants, and other city departments.
Legal authority
The San Francisco Board of Supervisors passed Residential Rent Stabilization and Arbitration Ordinance
(Chapter 37 of the San Francisco Administrative Code) in 1979. In 2020, the Board of Supervisors passed
Ordinance 265-20, an amendment to the Rent Ordinance which created the Housing Inventory.
WASHINGTON RENTAL REGISTRY STUDY 68
Initial implementation
It is unknown how the city conducted stakeholder engagement in advance of creating the Housing Inventory.
The city created the Housing Inventory during the height of the COVID-19 pandemic which might have
complicated engagement. The city held a public hearing to approve the Ordinance.
The Housing Inventory is new, and implementation is underway. The rent board already had a history of
oversight of residential rental properties in San Francisco. During the initial rollout, the Rent Board sent two
notifications via mail and one press release reminding all residential property owners of the registration
requirement. Property owners of owner-occupied units only have to report their mailing address and that the
unit is owner-occupied.
Program operations, administration and costs
A 2020 report from the city’s Budget and Legislative Analyst’s Office estimated year one costs for the program
of between $1.3 and $3.3 million and ongoing annual costs between $1.2 and $2.8 million to maintain the
inventory. The primary cost is for staffing of between seven and 14 Full-Time Equivalent (FTE) staff positions.
It is not likely that the program revenues are currently sufficient to cover its costs, due to low compliance.
The Rent Board administers the Housing Inventory. The city established a special revenue fund to fund the
Rent Board. Charges for services, including registration fees, provide the Board’s operating funds. The city
does not seem to have a targeted outreach strategy to identify and incentivize non-compliant property owners
In addition to maintaining the Housing Inventory, the Rent Board conducts hearings and mediations of rent
disputes, investigates wrongful conviction claims, provides counseling on the Rent Board, and provide
Alternative Dispute Resolution (ADR) meditation to tenants, roommates, landlords, and property owners. San
Francisco’s 311 Customer Service team also supports operation of the Housing Inventory, helping users
navigate challenges with the online portal.
Program features
The design of the Housing Inventory supports the operations of the city’s rent stabilization program.
Registry fees
The city uses a flat per-unit annual registration fee (Rent Board). The registration cost differs for dwelling units
and guest units (e.g., SROs or residential hotel rooms). The property owner can pass through up to 50% of the
registry fee to tenants.
Table C5: San Francisco's Rent Board Housing Inventory registration fees
Property type Total fee/unit
Dwelling unit $59
Guest unit (single-room occupancy or residential hotel room) $29.50
Prior to the creation of the Housing Inventory, property owners paid a fee through their property tax bill. Now,
property owners pay the same fee (plus a surcharge which covers the cost of operating the Housing Inventory)
directly to the Rent Board through the online portal.
Compliance mechanisms
Property owners that fail to pay the registry fee are subject to a 5% late fee for every month beyond March 1st.
Any unpaid fees on or after June 1st incur penalties through the Bureau of Delinquent Revenue. Non-compliant
properties cannot receive a rent increase license under the city’s rent stabilization law. If a non-compliant
WASHINGTON RENTAL REGISTRY STUDY 69
property owner increases rents without a license, the tenant has the right to file a civil proceeding against the
property owner. It is not clear if the Rent Board has assessed penalties at this point.
While the city provided a funding mechanism to administer the inventory, there remain few actions the Rent
Board can proactively take to ensure compliance. Compliance depends on tenants and non-profits filing civil
proceedings against non-compliant landlords. Meanwhile, the Rent Board continues annually notifying property
owners of the registration requirement.
Online portal
The city maintains a registry for property owners and for tenants. The property owner portal allows owners to
submit their registration, file for a rent increase license, pay the registry fee, and upkeep information on their
business and properties. The tenant portal enables tenants to provide their information and to identify whether
a property has received a rent increase license.
Impacts and lessons learned
Program impacts and effectiveness
The registration requirement officially launched on January 18, 2021. As of February 2023, the Rent Board
reported 12,000 registered properties, less than 5% the overall inventory of rental units subject to the Rental
Ordinance.
The Rent Board also measures the program’s effectiveness in terms of compliance with rent stabilization
requirements. However, data is not available about the impact of the housing inventory on rent stabilization
compliance.
Implementation and participation challenges
San Francisco’s Rent Board Housing Inventory benefited from existing organizational capacity designed to
support rent stabilization efforts. The Rent Board has been in existence for over four decades, which provided
a natural governance structure to implement the Housing Inventory.
The city began its rollout of the program by mailing notices to all property owners of the registry program.
Additionally, the city used press releases to increase awareness of the requirement.
So far, the city has experienced limited success with rental registrations in the first few years of operations.
COVID-era rent freezes might have contributed to low registration compliance. To improve registration
compliance, the Rent Board sends mail notifications to all residential property owners, regardless of
registration status or tenure. However, written notifications alone might not sufficiently increase registrations,
and the city does not currently have a more focused compliance strategy.
Equity considerations
The Rent Board offers exemptions for units regulated by a government agency, such as Housing Choice
Vouchers, units that are an accommodation in a hospital, monastery, extended care facility, licensed home for
the elderly, or dormitories, and units manage by nonprofit cooperative.
The city has also taken intentional steps to avoid burdening mission-driven property managers and subsidized
properties. The city allows exemptions for non-profit organizations, subsidized units, and homes for the elderly
to avoid negatively impacting properties with lower profit margins.
WASHINGTON RENTAL REGISTRY STUDY 70
Lessons learned
The San Francisco Rent Board’s Housing Inventory demonstrates how a rental registry can work alongside a
rent stabilization program to track detailed property information:
Limited data transparency is possible. The city tracks detailed unit-level data including changes in rents
and has a secure online portal where anyone view limited unit-level data such as registration fees and
status of the rent increase license. Public users cannot access information on unit rent or size.
Early compliance is challenging, and mailed notices have not had high success rates. The city has relied
primarily on written notices to property owners to encourage compliance. The Housing Inventory has
only been in operation a few years, and compliance is still low. The city’s primary compliance
mechanism is withholding rent increase licenses, but this has not been effective at incentivizing
registration.
Washington does not have rent stabilization laws, so a statewide rental registry would not use rent increases
to encourage compliance. Washington should use multiple means of outreach and explore relevant
compliance mechanisms. Washington can consider how best to balance
WASHINGTON RENTAL REGISTRY STUDY 71
Appendix D: Overview of existing rental registries
Summary of relevant takeaways
We found several trends in existing rental registries that are likely to make integration with a proposed
statewide rental registry difficult:
Excluding rental properties subject to local rental registries from a state rental registry program would
result in a significant loss of data. Existing rental registries already cover approximately 40% of rental
homes in the state, or 49% of homes in the six largest counties.
If the state were able to access and integrate all existing registry data, it would be missing rent and
occupancy data. Most existing rental registry programs focus on ensuring that rental housing meets
basic safety, habitability, and other quality standards. Very few collect information about rent or
occupancy. This will pose a challenge to integrating existing rental registry data into a state registry.
Existing rental registry data could be valuable as a starting point for outreach for a state registry. Most
existing rental registry programs in Washington collect owner contact information. The state could use
this data to conduct focused outreach to those property owners to encourage compliance with a state
program.
To leverage existing registry data, a statewide program will require the capacity to work with data that
is collected and stored differently. Each city has its own online web portal or other system for recording
registry information and accepting fee payments. Cities have various practices regarding the storage of
this data, and very little data is available publicly, either at the property level or through reporting. The
lack of transparency makes it difficult to understand the compliance rates and scale of existing
programs. It could also make it difficult to collect and aggregate data from existing rental registries into
a statewide registry.
A state program should not increase registration fees and regulatory requirements more than is
necessary to meet its goals. Compliance with existing registries can be costly and burdensome,
particularly for owners with properties in multiple cities. Most existing rental registry programs require
inspections, with slightly different requirements for business licenses, subject and exempt rental
properties, qualified inspectors, and inspection criteria. Property owners in most locations must pay a
registration fee as well as a fee for inspection. Some must also pay a business license fee. For housing
providers that own or manage properties in multiple cities with registries, varying standards, processes,
and portals could make compliance difficult. The state should avoid adding additional barriers for
property owners as much as possible.
Introduction
Purpose
Many of Washington’s largest cities already have residential rental registry programs. We compiled a summary
of these programs in order to understand how these local registries might interact with or inform the design of
a statewide rental registry program. Our review includes a summary of major program elements, fees, and data
collection practices.
WASHINGTON RENTAL REGISTRY STUDY 72
Existing rental registries in Washington
We identified 17 cities in Washington with existing rental registries. We did not identify any county-level rental
registries in Washington.
Table D1: Rental registry programs in Washington
Year Total Renter-occupied
City County Program name
begun population homes
Aberdeen Grays Harbor Rental Registration and Inspection Program 2019 17,013 2,860
Auburn King Rental Housing License Program 2019 87,256 12,381
Rental Registration and Safety Inspection Program
Bellingham Whatcom 2015 91,482 23,131
(RR&SIP)
Landlord License Program, Landlord Notification
Bremerton Kitsap 2014 43,505 9,480
Program
Burien King Rental Housing Inspection Program 2021 52,066 8,623
Kent King Rental Housing Inspection Program 2021 136,588 20,433
Lacey Thurston Residential Rental Registration Program 1999 53,526 9,375
Lakewood Pierce Rental Housing Safety Program 2015 63,612 14,878
Mountlake Terrace Snohomish Rental Housing License & Safety Inspection Program 2012 21,286 3,735
Olympia Thurston Rental Registry and Inspection Program 2024 55,605 12,709
Pasco Franklin Rental License Program 1997 77,108 7,277
Crime Free Rental Housing & Inspection Program
Prosser Benton 2012 6,062 1,008
(CFRHIP)
Renton King Rental Registration Program 2019 106,785 18,022
Seattle King Rental Registration and Inspection Ordinance (RRIO) 2014 737,015 206,391
Spokane Spokane Long-Term Rental Registry 2023 228,989 40,699
Tacoma Pierce Rental Business License 2019 219,346 40,263
Tukwila King Rental Housing Program 2011 21,798 4,663
Source: 2022 ACS 5-Year Estimates
Purpose and structure of existing registries
Existing rental registries in Washington all have similar purpose and structure. The primary stated purpose of
all of these registries is ensuring that rental housing meets basic safety standards. Some programs state
secondary purposes such as data collection, support for property owners and tenants, support for first
responders, and housing preservation.
WASHINGTON RENTAL REGISTRY STUDY 73
Inspections
Inspections are a central part of most of the existing rental registries in Washington. Of the 17 rental registry
programs, 11 require inspections on a recurring schedule (typically every 3 to 5 years), 3 programs allow
property owners to self-certify the condition of the property without an inspection, and 3 programs have no
inspection requirements at all. Some cities provide inspections at no cost to the property owner. Others allow
property owners to hire either a city inspector or a qualified or pre-approved private inspector.
Table D2: Inspection requirements for rental registry programs
City Policy focus Inspection requirement
Aberdeen Housing quality Yes
Auburn Housing quality No
Bellingham Housing quality Yes
Bremerton Housing quality Self-certification
Burien Housing quality Yes
Kent Housing quality Yes
Lacey Public safety No
Lakewood Housing quality Yes
Mountlake Terrace Housing quality Yes
Olympia Housing quality Yes
Pasco Housing quality Yes
Prosser Public safety Yes
Renton Housing quality Self-certification
Seattle Housing quality Yes
Spokane Housing quality No
Tacoma Housing quality Self-certification
Tukwila Housing quality Yes
Exemptions
Most registries cover all rental properties, including single-family homes, accessory dwelling units (ADUs), and
smaller rental properties. Some programs offer exceptions from inspection requirements for ADUs or duplexes
where one unit is owner-occupied, though these typically still have to register. Other exceptions include
government-owned property or subsidized properties that have federal inspection requirements. Registries
vary in their treatment of Short-Term Rentals. Some are subject to the same inspection and registration
requirements as longer-term rentals. Some have additional compliance standards, while some are exempt
from registration. In several cities STRs are governed under different legislation, as described in the Existing
Rental Registries – Additional Details table.
WASHINGTON RENTAL REGISTRY STUDY 74
Fees
We found that fees and fee structures vary, though most rental registries charge either a simple per-unit
registration fee or a fee for the first unit plus a smaller per-unit fee for each additional unit. Some programs
also require owners to pay a business license fee, and to pay for inspections either to the city, a private
inspector, or both. On average, most programs charge annual fees between about $10 and $50 per unit.
Programs with different approaches include:
Seattle, which charges a base registration fee of $115.50, plus $21 per unit for each additional unit. This
does not include fees for city inspections. It also requires re-registration every two years instead of annual
re-registration which is more common.
Renton, which does not charge a fee for registration.
Prosser, which charges a $10 fee for initial registration and a $5 annual renewal.
Tacoma, which bases fees on estimated rental revenue.
Fees are intended to offset or cover the costs of program administration; however, we do not have access to
detailed information about program costs and revenues. We did find that Seattle increased its registration fees
slightly in recent years because the program revenue was not sufficient to cover the program costs.
Data collected
We found that most rental registries have an online portal for property owners to submit required information
and documents to comply with the rental registry. Because of the emphasis on inspection compliance and
property condition, data collection focuses on property address and owner information. Most registries also
record the number of units in the building because this typically determines the registration fees. Some
registries request property manager contact information or a local agent. Only two registries collect
information on monthly rents or vacancy status, as required in the state’s proviso: Tacoma and Olympia. These
cities take two different approaches:
Olympia requires property owners to submit their complete rent roll, with fields for property address, unit
number, unit floor area, number of bedrooms, number of bathrooms, and rent for each individual unit.
The rent field is not required, however.
Tacoma requires property owners to provide information on rents at the property level. For single units,
Tacoma requires monthly rent for the unit. For multi-unit properties, Tacoma requires property owners to
quantify the number of units by type (i.e., studio, 1-bedroom, and 2-bedroom) and rent range (i.e., $1,501-
$1,750; $1,751-$2,000). Tacoma’s fees are based on gross rental income.
A few also collect information about utilities, tenancy, and other data points, including accessibility features
and use of Housing Choice Vouchers.
Table D3: Rental registry data collection
Property Number of Manager Rent and
City Owner info Unit size Tenant info Other
address units info utilities
Aberdeen Yes Yes Yes No No Yes No No
Auburn Yes Yes Yes Yes No No No No
Bellingham Yes Yes Yes No No No No No
WASHINGTON RENTAL REGISTRY STUDY 75
Property Number of Manager Rent and
City Owner info Unit size Tenant info Other
address units info utilities
Bremerton Yes Yes Yes No No No No No
Burien Yes Yes Yes No No No No No
Kent Yes Yes Yes No No No No No
Lacey Yes Yes Yes Yes No Yes No Yes
Lakewood Yes Yes Yes Yes No No No No
Mountlake Terrace Yes Yes Yes Yes No No No No
Olympia Yes Yes Yes No Yes No Yes Yes
Pasco Yes Yes Yes Yes No No No No
Prosser Yes Yes Yes No No No No No
Renton Yes Yes Yes Yes No No No No
Seattle Yes Yes Yes Yes No No Yes No
Spokane Yes Yes Yes Yes No No No No
Tacoma Yes Yes Yes Yes Yes No No No
Tukwila Yes Yes Yes No No No No No
Compliance rates
Compliance rates of existing registries
We were unable to get reliable data on compliance rates of existing rental registries. Most cities do not report
compliance rates or other registration figures publicly. Almost no data is available through open data portals
or other public reporting systems. We found limited registration data for a few existing registries, including
Seattle and Bellingham. Estimating compliance is also difficult for program administrators because it is
difficult to determine the exact number of rental properties or units subject to registration requirements. In
some cities, incomplete data could leave some properties in partial compliance.
Scale of existing registries and integration of data
Scale of existing registries
The best estimate we have of the scale of homes subject to existing rental registries is through the U.S.
Census Bureau’s American Community Survey, which reports the number of renter-occupied homes. This does
not include vacant rental homes. Based on available estimates, approximately 40% of rental homes statewide
may be currently subject to rental registries at the city level. Together, Seattle, Spokane, and Tacoma make up
70% of the rental units currently subject to local registries.
WASHINGTON RENTAL REGISTRY STUDY 76
Table D4: Estimated scale of existing rental registries, six largest counties
Cities in county with existing rental Renter-occupied homes in Total renter- Approximate % subject
County
registries cities with rental registries occupied homes to rental registry
Clark None identified 0 62,839 0.0%
Auburn, Burien, Kent, Renton,
King 270,513 401,313 67.4%
Seattle, Tukwila
Pierce Lakewood, Tacoma 55,141 121,139 45.5%
Snohomish Mountlake Terrace 3,735 96,712 3.9%
Spokane Spokane 40,699 77,399 52.6%
Thurston Lacey, Olympia 22,084 37,865 58.3%
Aberdeen, Bellingham, Bremerton,
All other counties 43,756 281,753 15.5%
Pasco, Prosser
Statewide total 435,928 1,079,020 40.4%
Source: 2022 ACS 5-Year Estimates
Data storage and format
Most existing rental registries use an online portal for property owners or managers to pay fees, submit
inspections, and update registration information. Some also allow tenants to access data related to their
homes through these portals. However, each city has its own online portal system, which is sometimes tied to
other city functions. We are conducting additional outreach to operators of larger registries to understand in
what format registry data is stored and how easy it would be for the state to access back-end data for
integration with a statewide registry database.
Estimated data loss
If the state were able to access and integrate registry data for all existing registries (so as to not require
duplicate registration by owners in those cities), it would have some ownership and property information, but it
would only have monthly rent data for homes in Olympia and Tacoma. We do not know current compliance
rates for these existing registries. If the state were not able to access and integrate registry data for any
existing registries, it would result in a loss of data for up to 436,000 homes or 40% of the total for statewide
implementation, or 392,000 homes or 49% of the total for implementation limited to the six largest counties.
To minimize potential data loss, the state could focus data collection and integration on three cities: Seattle,
Spokane, and Tacoma, which together account for approximately 67% of homes currently subject to rental
registries statewide and 73% of homes currently subject to rent registries in the six largest counties. Seattle
and Spokane do not collect rent data, so this strategy would only capture Tacoma’s rent data.
Table D5: Existing rental registries – program overview
Year Policy
City Program name Overview
begun focus
The City of Aberdeen's rental registration and inspection program requires
Residential Rental
Housing registration and inspection to protect tenants from living in poorly
Aberdeen Registration and 2019
quality maintained homes. The program covers all rental homes, with exceptions
Inspection Program
only for housing owned by government entities and for commercial lodging.
WASHINGTON RENTAL REGISTRY STUDY 77
Year Policy
City Program name Overview
begun focus
Registrations must be renewed annually. In addition to registration the
property owner must obtain a business license and have an inspection every
3 years. The city's inspection fee is $75 and covers one follow-up inspection.
The city estimates that 1,000 units are registered through the program.
Auburn requires a city rental license for all rental homes to ensure proper
management and maintenance of rental properties and to keep up to date
Rental Housing Housing
Auburn 2019 contact information for property owners and managers to respond to
License Program quality
complaints. Nonprofit-owned properties do not pay a fee for registration.
Most homes do not require an inspection.
The purpose of the City of Bellingham's RR&SIP is to ensure that rental
housing meets basic safety standards. The program covers all residential
Rental Registration
rental properties. The city publishes a list of registered properties, which
and Safety Housing
Bellingham 2015 includes approximately 20,600 rental units in 5,300 properties. Properties
Inspection Program quality
that must register but are exempt from inspection requirements include
(RR&SIP)
owner-occupied properties with two units and government-owned properties
or subsidized properties subject to inspection under HUD requirements.
Bremerton requires property owners to obtain a landlord business license
Landlord License
and to provide the city's police department with a listing of all rental
Program, Landlord Housing
Bremerton 2014 properties inside city limits. Property owners must sign a declaration of
Notification quality
compliance related to adherence to certain building codes and can receive
Program
property inspection checklists to do a self-inspection.
Burien's program aims to protect tenants' health and safety and encourage
proper maintenance of rental housing. The city requires an annual housing
business license for each residential property and a health and safety
Rental Housing Housing
Burien 2021 inspection every three years for rental properties with two or more units.
Inspection Program quality
Single-family homes, mobile homes, ADUs, condominiums, and properties
that received a certificate of occupancy within the past 4 years are exempt.
Government owned properties are also exempt.
Kent's program arose from tenant concerns about health and safety and
requires inspection of rental properties with two or more units. Single-family
homes, owner-occupied mobile homes, government-owned rental properties,
Rental Housing Housing and properties that received a certificate of occupancy within the last 4 years
Kent 2021
Inspection Program quality are exempt. Notably, Kent allows tenants to register their apartment building
to help build the city's database of rental housing and to support outreach to
property owners. The city has cited low (less than 10%) registration rate and
delays due to COVID.
Lacey's residential rental registration program requires rental properties with
5 or more units to register annually with the city. The city does not require
inspections and charges a minimal fee of $5 per unit per year for
Residential Rental
Public registration. The program appears to be tied to public safety and crime
Lacey Registration 1999
safety prevention, as a portion of registration fees go to crime prevention programs
Program
and registration forms ask for security officer contact information.
Registration fees are waived for property owners who participate in a crime
free housing program.
Lakewood's rental housing safety program focuses on ensuring that rental
housing meets specific life and fire safety standards through annual
Rental Housing Housing
Lakewood 2015 registration and inspections every 5 years. It allows exemptions for owner-
Safety Program quality
occupied units, government-owned and subsidized homes, units in
condominiums, mobile homes, and homes that are less than 10 years old.
Rental Housing Mountlake Terrace's program requires property owners to obtain a business
Mountlake Housing
License & Safety 2012 license which they must renew annually. The program requires inspections
Terrace quality
Inspection Program for all residential rental properties to ensure that housing meets safety
WASHINGTON RENTAL REGISTRY STUDY 78
Year Policy
City Program name Overview
begun focus
standards. City and county inspectors conduct inspections at no cost to the
owner.
Olympia is in the process of implementing a rental housing registration
program similar to those in other cities. The goals of the program include
ensuring health and safety for tenants, housing preservation, data collection,
and support for housing providers. Property owners are required to register
annually, obtain a business license from the state, and undergo inspection
every 5 years. ADUs and duplexes in which one unit is owner-occupied must
Rental Registry and Housing comply with the registry but are exempt from inspections. The same is true
Olympia 2024
Inspection Program quality for homes that are less than 10 years old and affordable housing that is
subject to inspections under HUD requirements. Olympia's ordinance
prohibits passing registration fees, inspection fees, or other compliance
costs on to tenants. Notably, Olympia's program is tied to funding for
housing providers with low-income tenants that allows them to make repairs
in order to ensure that the program does not contribute to displacement.
Registration began on March 1, 2024.
The City of Pasco established the first rental registry program in Washington,
with the stated goals of assisting first responders and ensuring that rental
Rental License Housing housing meets minimum code standards. The program is operated by the
Pasco 1997
Program quality Sheriff's office and code enforcement department. Property owners must
obtain a business license and submit a certificate of inspection every 2
years.
The stated purpose of Prosser's CFRHIP is to create better, safer, crime-free
rental housing. The city describes a two-sided approach involving both the
Crime Free Rental
police department and the building department, focused on information,
Housing & Public
Prosser 2012 training, assistance, and inspections to improve rental property conditions.
Inspection Program safety
All rental property owners must obtain a rental license and an inspection.
(CFRHIP)
Participation in the Crime Free Rental program is voluntary unless a property
has two or more violations.
Renton's rental registration program is a limited-scope program focused on
ensuring housing quality. Renton requires registration for all rental
properties, though only owners of apartment complexes with 5 or more units
require a business license. The program has exemptions for room rentals in
Rental Registration Housing
Renton 2019 owner-occupied housing, short-term rentals, state-licensed facilities, and
Program quality
government-owned housing. Registration must be renewed annually, and
housing providers must self-certify the condition of the property annually
through a declaration of compliance with various codes and housing safety
requirements.
Seattle's program is designed to ensure that rental housing meets basic
maintenance and safety requirements, and to educate property owners,
managers, and renters. Registration is required every 2 years for all rental
housing. The city suspended inspection operations during the COVID-19
pandemic and registrations fell during this time, though it is unknown if this
is due to lower compliance or loss of housing. At the end of 2022, the city
Rental Registration had approximately 26,500 registered properties representing 161,000 rental
Housing
Seattle and Inspection 2014 units. About 7.3% of properties completed and passed inspections,
quality
Ordinance (RRIO) somewhat short of the city's 10% target. The city estimates that
approximately 90% of rental properties are registered. Registration and
inspection fees provide the bulk of operating revenue for the program,
however in 2022 that revenue was only about $1.8 million compared to total
program operating costs of $2.3 million. Outreach activities include the city's
website, direct mail to likely rental property owners, brochures, and
partnerships with property owner associations.
Long-Term Rental Housing Spokane's registry program is focused on maintaining safe living conditions,
Spokane 2023
Registry quality preserving housing stock, and tracking rental units. Property owners must
WASHINGTON RENTAL REGISTRY STUDY 79
Year Policy
City Program name Overview
begun focus
obtain business licenses. Tenants can submit complaints via the city's 311
system.
Tacoma requires a business license for all rental housing to support first
Rental Business Housing
Tacoma 2019 responders and address blighted property conditions. Property owners must
License quality
self-certify that properties meet basic habitability and code standards.
Tukwila requires a license and inspection for all rental units to ensure that
rental homes are safe and suitable for occupancy. The requirement applies
Rental Housing Housing to short-term rental properties, though the city does not allow short-term
Tukwila 2011
Program quality rentals in multi-family dwellings or Accessory Dwelling Units. Owners must
renew their licenses annually. The city maintains a user-friendly website and
holds virtual office hours for anyone to meet with staff.
Table D6: Existing rental registries – additional details
Registry Business Short-term Online Public
City Fees Inspections Enforcement
information license rentals portal data
Yes, required
Property
every 3 years.
address, owner
Property
information,
$50 plus $2 per owners can use Unclear, likely Yes
Aberdeen number of Yes Late fee No
additional unit a city inspector required (SmartGov)
units, number
or a qualified
of bedrooms,
private
square footage
inspector.
$30 to $500 per
Property
year (nonprofit
address, owner
owners pay no
information,
fee. $30 per unit
number of
for single-
units, manager
family; $75 per No (PDF
information, Unclear, likely
Auburn building per No Yes Unknown application No
local contact. required
year for 2-4 )
Additional
units, $150 per
information
year for 5 to 24
required for
units, $500 per
single-family
year for 25 or
residences.
more units)
Yes, required
every 3 to 3.5
$8 to $10 per years. Property
unit per year owners can use
Financial
Property (properties with a city inspector
Governed by penalties
address, owner up to 20 units or a private Yes Property
Bellingham No separate based on
information, on a single inspector (use (eTRAKit) list (PDF)
requirements length of non-
number of units parcel pay the of a private
compliance
higher rate per inspector
unit) requires an
additional $45
fee to the city)
Property $75 per year
Self- Civil penalty,
Bremerton address, owner business Yes Unknown No No
certification revocation of
or manager license fee
WASHINGTON RENTAL REGISTRY STUDY 80
Registry Business Short-term Online Public
City Fees Inspections Enforcement
information license rentals portal data
contact business
information, license
number of units
$303.75 to
Late fee
$911.24 per
incurred
year per Yes, required
every day the
property based every 3 years
Unknown unit operates
on number of (at least 20% of
(assume without a
units ($303.75 total units in the
minimum certificate of
for properties property).
property inspection.
Burien with up to 10 Property owner Yes Unknown No No
address, owner Property will
units. $759.36 must hire a
information, be deemed
for properties private
number of uninhabitable
with 11 to 50 inspector from
units) after 30 days
units. $911.24 a pre-approved
of
for properties list.
noncomplian
with 51 or more
ce.
units)
Yes, required
every 3 years
Property No fee for for 20% of the
Inability to
address, registration, total units in the
renew
number of $15 for property.
Kent Yes Unknown multifamily No No
units, owner submission of Property
business
name and inspection owners must
license
information report hire a qualified
private
inspector.
Property
address, owner
information,
Registration
number of units
fee is waived
with gross floor
$5 per unit per for owners
area, number
year with a who
and size of
Lacey maximum fee No No Unknown voluntary No No
bedrooms; use
of $500 per participate in
of tenant-
complex. a crime free
screening
housing
agency,
program.
manager and
security contact
information
Yes, required
Property every 5 years.
$12 per unit per Penalties of
information, Property
year (additional $150 per day,
owner owners can use Yes
Lakewood fee for re- No Unknown $500 per day No
information, a city inspector (Tolemi)
inspection of after first ten
manager or a qualified
failed unit) days
information private
inspector.
Yes, required
Property
every 3 years.
Address, owner $40 plus $1.50 No (PDF
Mountlake City or county
information, per additional Yes Unknown Unknown application No
Terrace inspectors
property unit )
conduct
manager
inspections.
WASHINGTON RENTAL REGISTRY STUDY 81
Registry Business Short-term Online Public
City Fees Inspections Enforcement
information license rentals portal data
information,
number of units
Property The city is
address, working
business toward
license number, voluntary
property owner compliance
name and through
contact education
information, and outreach.
property name, Penalties
rental property may include
Yes, required
type, total denial or
$35 per unit per every 5 years.
number of suspension
year (plus Property
rental units and Exempt of business
business owners select a Yes
Olympia buildings, Yes (permit licenses, No
license fees private (SmartGov)
presence of fee required) penalty fees,
and third-party inspector from
waivers or or the loss of
inspection fees) a pre-approved
tenants with occupancy
list.
Housing Choice certificate. If
Vouchers and the rental unit
other tenancy does not
and pass
accessibility inspection,
information, the property
rent per unit, owner is
inclusion of prohibited
utilities in rent, from raising
local contact rents.
Property
address, Yes, required
number of every 2 years.
units, owner's City inspectors
name and $50 plus $10 conduct
Yes
contact per additional inspections at
Pasco Yes Prohibited Unknown (Citizen No
information, unit (one-time no cost to
Connect)
ownership type, cost) owner, or owner
manager's may choose a
name and qualified private
contact inspector.
information
Yes, required
Property $10 per unit to every 5 years.
No (PDF
address, owner register, $5 per Property
Prosser Yes Unknown Unknown application No
information, unit annual owners select a
)
number of units renewal qualified private
inspector.
Property
Self-
address, owner
certification.
contact
Inspection not
Renton information, No fee No Exempt Misdemeanor No No
required except
manager
in cases of
contact info,
violations.
number of units
WASHINGTON RENTAL REGISTRY STUDY 82
Registry Business Short-term Online Public
City Fees Inspections Enforcement
information license rentals portal data
Property
address, owner
Yes, required
contact
every 5 to 10
information, $115.50 base
years. Property
tenant contact fee + $21 per Some are Late
owners can use Yes Annual
Seattle information, additional unit No subject to registration
a city inspector (Accela) report
manager (re-registration RRIO fee of $31.50
or a qualified
contact every 2 years)
private
information,
inspector.
number of units
and type
Inspections for
Property code
address, compliance
$127 annual
ownership and only if there is Governed by
business Yes
Spokane management cause. No fee Yes separate Unknown No
license fee plus (Accela)
information, for inspections requirements
$15 per unit
business unless there are
license number repeat
offences.
Property
address,
dwelling type,
owner
$37 to $2,000
information,
based on Self- Yes
Tacoma property Yes Unknown Unknown No
anticipated certification (FileLocal)
management
gross income
information,
ownership type,
monthly rent,
number of units
$84-$340 based
on number of
units ($84 for
Yes, required
properties with
Unknown before renting
up to 4 units,
(assume and then every
$218 for
minimum 4 years. Included,
properties with Late fees of
property Property limitations on
Tukwila 5 to 20 units, Yes $10 per Yes No
address, owner owners can use STR
$273 for month
information, a city inspector allowance
properties with
number of or choose a
21 to 50 units,
units) qualified private
$340 for
inspector.
properties with
51 or more
units)
WASHINGTON RENTAL REGISTRY STUDY 83
Appendix E: Rental housing market scan
Summary of relevant takeaways
The housing scan reveals several important considerations which might guide the design of the proposed
rental registry program.
There are tradeoffs between implementation cost, administrative burden, and coverage associated with both
a statewide rental registry and a registry with implementation limited to the six largest counties. The state
has approximately 1,076,000 renter-occupied homes, and the six largest counties together have approximately
797,000. Because the six largest counties account for 74% of total renter-occupied homes in the state, there
might not be an order-of-magnitude difference in the marginal costs to implement the more geographically
focused implementation, and the difference in data collection will be proportional to the difference in the
amount of rental housing. That said, the administrative burden associated with coordinating 40 counties
versus 6 counties could result in significant cost and time differences. The other potential downside to a more
focused approach is the exclusion of more rural counties that may benefit most from certain aspects of a rent
registry, like housing quality standards.
Cost of housing appears to be the primary difference in the housing market between regions. Though there
are many differences between the regions in the state, trends in housing type and age are similar across the
state. Smaller rental buildings and homes built in the 1970s through 1990s are the most common in each
region. The greatest difference between regions is in the distribution of rents. Western regions have higher
rents on average, while there are more homes with lower rents in Eastern regions. While each region has also
seen a loss of affordable housing, the Central Puget Sound region has experienced the most substantial losses
in both percent decline and number of affordable housing units lost. The design of the registry should consider
what market data and trends the state is most interested in understanding, both within and across each region
or county.
Residents of color are disproportionately likely to be renters. Renters also generally have lower incomes. This
means that rising rents, loss of naturally occurring affordable housing, and programs that impact the supply,
quality and cost of rental housing have a disproportionate impact on low-income residents and BIPOC
residents. While renters in the state tend to be younger, there is also a significant population of renters over 65.
The design of the registry should consider how it might support vulnerable renters’ needs and improve
equitable outcomes for Washington’s residents.
Purpose
The following overview describes HR&A’s analysis of trends in both the supply of rental housing and the
demographics of renters throughout Washington. This analysis provides important context for the design and
development of a rental registry. With a better understanding of the amount, type and location of rental
housing, and the characteristics of renters, the state can ensure that the rental registry addresses the specific
challenges associated with rental properties in Washington. In addition, the housing market scan will help to
inform cost estimates and planning for implementation under either a statewide program or a program limited
to the six largest counties.
Methodology
To conduct this analysis, we first categorized counties into regions based on important distinctions across the
state, particularly distinctions that exist between the western, central, and eastern parts of the state. We
WASHINGTON RENTAL REGISTRY STUDY 84
aggregated county-level data to show trends across regions. The analysis relies on data from 2017-2022
American Community Survey 5-Year Estimates (from the U.S. Census Bureau), American Community Survey
Public Use Microdata Sample (PUMS), and Zillow Observed Rent Index.1
US Census 2017-2022 American Community Survey 5 Year Estimates: The American Community
Survey (ACS) produces a wide range of demographic, socioeconomic, and housing data at many
geographic levels. This analysis uses county level data aggregated by region. This analysis uses the
2022 5-Year ACS data (the most current reporting year), which represents the average of data collected
between 2017 and 2022. With more years of data, the 5-year estimates provide a more detailed and
reliable picture at more geographic levels than ACS 1-year estimates. This analysis primarily uses data
on race, income, and renter-occupied units. Data is not available for room rentals, partial unit rentals, or
vacation rentals.
US Census American Community Survey Public Use Microdata Sample: The ACS Public Use Microdata
Sample (PUMS) is a set of individual records with detailed information about the characteristics of a
subset of individual people and housing units reached in the survey. This data does not include
personalized information and is aggregated to an area of at least 100,000 people. This data allows for
more complex research techniques and is reported in 1- and 5-year estimates like other ACS data.
Zillow Observed Rent Index: The Zillow Observed Rent Index (ZORI) measures the typical observed
market rate rent across a given region. ZORI is a repeat-rent index that is weighted to the rental housing
stock to ensure it is representative across the entire market, not just those homes currently listed for-
rent. The index calculates the mean of listed rents that fall into the 35th to 65th percentile range for all
homes and apartments in a given region, which is weighted to reflect the total rental housing stock.
Definitions
This analysis primarily pertains to Washington’s rental housing stock and the renters who live in it. ACS data
uses the term “Renter-Occupied Units” to denote housing units where renters (i.e., not owners) currently reside
(i.e., units are not vacant). Renter-Occupied Homes do not include mobile homes, which are treated differently.
Owner-Occupied Units, Vacant Units, and Mobile Home Units are other classifications for unit occupancy. This
analysis refers to renter-occupied units, rental homes, and rental homes interchangeably.
Table E1: Definition of regions
Region County
Peninsula/Coastal Clallam, Grays Harbor, Jefferson, Pacific
Northwest San Juan, Skagit, Whatcom
Central Puget Sound King, Snohomish, Island, Kitsap, Pierce
South Puget Sound Lewis, Mason, Thurston
Southwest Clark, Cowlitz, Skamania, Wahkiakum
North Central Chelan, Douglas, Grant, Okanogan
South Central Benton, Franklin, Kittitas, Klickitat, Walla Walla, Yakima
1 The housing scan does not include data from CoStar commercial listing service, because this data typically does not capture single-family homes or
smaller rental properties, which make up a significant amount of the rental housing in the state.
WASHINGTON RENTAL REGISTRY STUDY 85
Region County
Northeast Ferry, Lincoln, Pend Oreille, Spokane, Stevens
Southeast Adams, Asotin, Columbia, Garfield, Whitman
Figure E1: Map of regions
Housing supply trends
The number, distribution, type, and other characteristics of renter-occupied housing in Washington will impact
the costs of the program and might provide additional context to guide design. As of 2022, there were over
1.08 million renter-occupied homes in Washington (ACS 2022 5 Year Estimates). Renter-occupied homes
account for approximately 36% of homes statewide.
Geographic distribution
Determining where renter-occupied homes are located will help inform the design and implementation of the
rental registry program. Renter-occupied homes are highly concentrated in the Central Puget Sound region,
which accounts for 61% of all rental homes in the state. Central and Eastern regions have just 214,000 renter-
occupied homes, or about 20% of the statewide total. The six largest counties by population (King, Pierce,
Snohomish, Spokane, Clark, and Thurston) have a total of approximately 797,000 renter-occupied homes, or
74% of the statewide total. This indicates that the difference in data collected between a statewide program
WASHINGTON RENTAL REGISTRY STUDY 86
and one with implementation limited to only the six largest counties would only be approximately 26% of the
statewide total.
Table E2: 2022 Renter-occupied homes by region
Region Number of renter-occupied homes Percent of total
Peninsula/Coastal 22,580 2%
Northwest 50,540 5%
Central Puget Sound 659,270 61%
South Puget Sound 51,410 5%
Southwest 78,070 7%
North Central 32,590 3%
South Central 82,040 8%
Northeast 83,940 8%
Southeast 15,270 1%
Total 1,075,710 100%
Source: 2022 ACS 5-Year Estimates
Table E3: Renter-occupied homes in the six largest counties, 2022
Region Number of renter-occupied homes Percent of total
King County 401,313 37%
Pierce County 121,139 11%
Snohomish County 96,712 9%
Spokane County 77,399 7%
Clark County 62,839 6%
Thurston County 37,865 4%
All other counties 281,753 26%
Total 1,075,710 100%
Source: 2022 ACS 5-Year Estimates
Renter-occupied homes by type and age
The types of renter-occupied homes that exist in Washington can impact rental registry administration. Single-
family homes make up the largest share of renter-occupied homes within each region. Fifty-eight percent of
renter-occupied homes are in buildings with fewer than 10 units statewide, with single-family homes
accounting for 34% and units in buildings with 2-9 units accounting for 24%. There are approximately 184,700
mobile homes in Washington (including both renter- and owner-occupied homes). About 55,000 of these have
renter occupants. Owner-occupied mobile homes share some qualities with rentals, because the owners often
rent the land on which the mobile home is located. According to the Urban Institute article “Owners and
Renters of 6.2 Million Units in Small Buildings Are Particularly Vulnerable during the Pandemic,” smaller
properties are more likely to have small, private property owners, so this may indicate a high percentage of
WASHINGTON RENTAL REGISTRY STUDY 87
these “mom and pop” housing providers across the state. This suggests that small scale, mom and pop
property owners may be most burdened by the costs and hurdles associated with a rental registry.
Table E4: Renter-occupied homes by building type, 2022
Building typology Number of renter-occupied homes Percent of total
Single-family homes 367,750 34%
2-9 Units 260,930 24%
10-49 Units 224,890 21%
50+ Units 167,130 16%
Mobile homes 55,010 5%
Source: 2022 ACS 5-Year Estimates
Figure E2. Renter-occupied homes by building type, 2022
Southeast
Northeast
South Central
North Central
Southwest
South Puget Sound
Central Puget Sound
Northwest
Peninsula/Coastal
0 50,000 100,000 150,000 200,000 250,000
Mobile Homes 50+ 10-49 Units 2-9 Units Single Family Units
Source: 2022 ACS 5-Year Estimates
WASHINGTON RENTAL REGISTRY STUDY 88
If a rental registry program includes inspecting and enforcing housing quality standards, housing quality may
improve but older housing stock that has not been well maintained may be costly to bring into compliance.
Across regions, housing built in the 1970s is most common, and the distribution of homes by age is similar
across regions. Statewide, the median year built of renter-occupied homes is 1984, the same as owner-
occupied homes. By comparison, the national median year built for renter-occupied homes is 1978. Central
Puget Sound housing trends slightly newer than other regions, with more proportionally more homes built
during the 1980s and later.
Rental cost trends
Though each region has rental homes with a range of rents, rents are higher on average in Western regions.
Statewide, average rents range from about $1,450 to about $2,100, which means they are affordable to
households with incomes up to about $60,000 to $85,000 (assuming households pay no more than 30% of
their income on rent). Rents in Western Washington submarkets are most commonly between $1,500 and
$3,000, whereas Central and Eastern submarket rents are most commonly between $800 and $1,250. Rents
are highest in the Central Puget Sound region and lowest in the Southeast region.
Both income and rent determine affordability. Renter incomes tend to be lower in regions with lower rents, and
higher in regions with higher rents. This means that even though rents are lower in Central and Eastern regions,
rental homes may not actually be more affordable to the people that live there than in other regions.
Rising rents are one of the primary challenges to housing affordability and stability for renters. In recent years,
rents have increased across the state—by 45% since 2015, from an average of $1,124 to an average of $1,634
per home in 2022 (a compound annual growth rate of 5.5%). This trend holds across all regions with data,
though at different scales. Rents in the Northwest have increased most, rising 93% since 2015. The Northeast
follows closely, where rents have increased 85% since 2015. Rents in the Southwest have increased least in
that time at 32%. Rents in other regions have increased between 41% and 68% since 2015.
Figure E3: Change in rent from 2015 to 2022
South Puget Sound, Central Puget Sound,
$1,900 $1,950 $1,900
Northwest, $1,864
$1,700 Southwest, $1,535
North Central, $1,485
$1,500
South Central, $1,458
$1,300 Northeast, $1,456
$1,100
$900
$700
$500
2015 2016 2017 2018 2019 2020 2021 2022
Source: Zillow ZORI; Note labels show 2022 values by region
WASHINGTON RENTAL REGISTRY STUDY 89
The number of affordable units with rent less than $1,000, whether subsidized or not, has decreased
significantly across all regions since 2016. These units may be more affordable due to their age, size, location,
or, commonly, public subsidy. The National Housing Preservation Database lists 134,480 units in properties
with active public subsidies statewide compared to 198,040 total units with rent less than $1,000. It should be
noted that not all units that receive public subsidy have rents below $1,000, meaning some of these units are
affordable without public subsidy.
Table E5 shows the prevalence and change of these rental homes by region. There are 56% fewer rental homes
with rents less than $1,000 now than in 2016. The number of these units has decreased in every region,
decreasing most in the Central Puget Sound region (by 68% since 2016) and least in the Southeast region (by
25% since 2016). While the Central Puget Sound region has the most units with rents below $1,000, its units
with rents below $1,000 make up the smallest proportion of total renter-occupied homes in any region. These
units make up the highest proportion of rental homes in the Southeast, Peninsula/Coastal, and North Central
regions. The Southeast and the Peninsula/Coastal regions have the lowest renter median incomes, meaning
that these affordable rental homes are especially critical in these regions.
Table E5: Rental homes with rent less than $1,000 by region, 2022
Change in number of rental homes
Number of rental homes with rent Percent of total renter-occupied
Region with rent less than $1,000 from
less than $1,000 (2022) homes
2016 to 2022
Peninsula/Coastal 9,860 44% -39%
Northwest 10,790 21% -58%
Central Puget Sound 65,270 10% -68%
South Puget Sound 11,320 22% -53%
Southwest 13,370 17% -65%
North Central 13,900 43% -35%
South Central 32,090 39% -39%
Northeast 32,980 39% -40%
Southeast 8,460 55% -25%
Source: 2022 ACS 5-Year Estimates, PUMS Data
WASHINGTON RENTAL REGISTRY STUDY 90
Figure E4: Rental homes with rent less than $1,000
Southeast
Northeast
South Central
North Central
Southwest
South Puget Sound
Central Puget Sound
Northwest
Peninsula/Coastal
0 50,000 100,000 150,000 200,000 250,000
2016 2022
Source: 2022 ACS 5-Year Estimates, 2016 ACS 5-Year Estimates, PUMS Data
Renter demographic trends
Rentership rates and renter profile
There are significant disparities in rentership by race and income, underscoring the extent to which programs
for renters are critical to addressing racial equity in housing. Across all regions, Washington residents are
more likely to own their homes than to rent. However, the majority of Black and Hispanic or Latino residents
are renters, and across the state BIPOC households are more likely to be renters than white households. Asian
households are about as likely to rent their homes as white households except in the Southeast, where they are
twice as likely to rent their homes.
Across regions, renters’ incomes are significantly lower than the median. Renter median household incomes
range from 57% of the overall median household income in the Southeast region to 71% of overall median
household income in the North Central region. Except for the Peninsula/Coastal region, renter incomes tend to
be lower in the Central and Eastern regions. This trend mirrors trends in rent, which suggests that lower
incomes combined with lower rents could result in similar levels of affordability.
WASHINGTON RENTAL REGISTRY STUDY 91
Figure E5: Median household income by region
Southeast
Northeast
South Central
North Central
Southwest
South Puget Sound
Central Puget Sound
Northwest
Peninsula/Coastal
$0 $20,000 $40,000 $60,000 $80,000 $100,000 $120,000 $140,000 $160,000
Owners Renters All
Source: 2022 ACS 5-Year Estimates
Renter households tend to be younger than owner households. Statewide, 60% of renter householders are
under 45 years old and 40% are under 35 years old. In every region except for the Peninsula/Coastal region,
over 50% of renter householders are under 45. Renters in the Southeast region trend youngest, with 70% of
renter householders under 45 years old and 56% under 35. That said, there is a significant population of senior
renter householders over 65 years old—over 162,000 statewide, accounting for 15% of renter homes. The
Peninsula/Coastal region has the highest proportion of renter householders over 65 years old (24%).
WASHINGTON RENTAL REGISTRY STUDY 92
Renter housing cost burden
Renters are more likely than homeowners to pay more than 30% of their income for housing, which undermines
their housing stability. A household that pays over 30% of income toward housing costs is housing cost
burdened according to the U.S. Department of Housing and Urban Development (HUD). HUD classifies a
household that pays over 50% of its income toward housing costs as severely housing cost burdened. When
households pay too much income on rent, they have fewer resources to pay for other necessary costs. This
means they are more likely to struggle if they face loss of employment or unanticipated expenses. Housing
cost burden can therefore put renters at risk of housing instability and loss of housing. In Washington, 43% of
renters are housing cost burdened, and renters are more than twice as likely as homeowners to be severely
housing cost burdened.
Figure E3: Statewide cost burden
100%
8%
90%
20%
14%
80%
70%
23%
60%
50%
40%
77%
30%
56%
20%
10%
0%
Owners Renters
Not Housing Cost Burdened Housing Cost Burdened Severely Housing Cost Burdened Cost Burden Data not available
Source: 2020 HUD CHAS Data
WASHINGTON RENTAL REGISTRY STUDY 93
Appendix F: Program implementation timeline
Summary of relevant findings
Operational and administrative needs for the rental registry will vary across multiple phases of
implementation. While the estimated timeframe to implement a rent will depend on the program’s geographic
focus, we do not anticipate major timeline differences between a statewide implementation and
implementation limited to the six most populous counties.
Table F1: Primary implementation activities by phase
Program design Pre-launch Launch Stabilization
(Year 0) (Years 1 to 2) (Years 3 to 4) (Year 5 and ongoing)
Develop major data and
Continue extensive
management systems Provide ongoing data
outreach and marketing
Finalize program design Integrate county assessor management, analysis, and
Manage program launch,
Take legislative measures data and existing registries reporting
with technical assistance,
to create and fund the Develop informational and Provide ongoing outreach
data quality assurance, and
program marketing materials through direct mail and
initial reporting
Prepare to hire a program Conduct extensive other avenues
Begin robust compliance
coordinator outreach and marketing Continue robust
efforts
Hire staff and prepare for compliance activities
Grow operational capacity
launch
Introduction
Purpose
We are working with the Washington State Department of Commerce (Commerce) to study and design a
proposed rental registry program for the Washington. This memorandum outlines the anticipated costs to
launch and operate a state rental registry as well as the potential for registration fees to offset the cost of the
program.
Implementation timing estimates
The estimated timeframe to implement a rental registry will depend on the program’s geographic focus. Based
on our research, we anticipate that many of the steps needed to implement the program are independent of
the registry’s geographic focus (six-county versus statewide). Pre-launch tasks such as identifying and rolling
out software and creating an outreach plan will take the same amount of time regardless of the program’s
geographic focus, while others like hiring staff, working with county Assessors to integrate local data and
conducting outreach will take longer if the state chooses a statewide program. HR&A estimates that a six-
county program will lower the pre-launch and launch timelines by 3 to 6 months.
Program design (Year 0)
The state needs to take several pre-implementation steps:
1. Refine and finalize key elements of the program design and budget
2. Take legislative action to establish the registry and allocate funding
WASHINGTON RENTAL REGISTRY STUDY 94
3. Create software or select an existing software product that meets the requirements for the
registry
4. Create a job description, launch a search, hire and onboard a program coordinator to lead
implementation
Key actors: Commerce, state Legislature
Timing: Within one year, subject to the requirements and timing of the legislative process
Pre-launch (Years 1 to 2)
Table F2: Management and oversight
Geographic
Implementation step Key actors Timing
considerations
Hire and onboard staff for program implementation and ongoing
operations. Staff includes two FTEs for program management,
Program Months 0 Time may be reduced by
coordination and oversight, 6 to 18 FTEs for marketing, outreach and
Coordinator, to 6 and 3 months for a six-county
technical assistance, and 3 to 16 FTEs for IT and research
Commerce ongoing program
management, depending on implementation geography, phase, and
county coordination.
The overall length of the
Oversee pre-launch process, ensuring that implementation meets Program Months 0 pre-launch process will
project milestones. Coordinator to 24 be based on its
geographic focus
Program
Coordinator, users of Months 7
Plan for uses of rental registry data.
data e.g. local to 12
government partners
Program
Work with Commerce to grow capacity external to the program as Months 13
Coordinator,
needed. to 24
Commerce
Table F3: Outreach, marketing and compliance
Geographic
Implementation step Key actors Timing
considerations
Engagement
Develop informational materials for direct mailing, online Months 3
coordinator and
advertising, listening sessions, and other engagement methods. to 12
support staff
Build relationships with partner organizations including tenant
advocacy organizations, housing industry associations, local Engagement Time may be reduced by
Months 3
government partners. A six-county approach is likely to require a coordinator and 3 to 5 months for a six-
to 12
two-thirds to half the time for engagement than a statewide support staff county program
program.
Engagement
coordinator, support Months 6
Finalize outreach and marketing approach.
staff, partner to 9
organizations
Begin marketing campaign, circulating informational materials Time may be reduced by
Engagement Months 9
through online and print media, partner organizations. A six-county 8 to 4 months for a six-
coordinator, support to 24
approach is likely to require two-thirds to half the time for county program
WASHINGTON RENTAL REGISTRY STUDY 95
Geographic
Implementation step Key actors Timing
considerations
engagement than a statewide program due to the smaller geography staff, partner
covered. organizations
Host virtual and in-person informational sessions around the state. Engagement Time may be reduced by
Months
Information sessions for a statewide program will require more time coordinator and 6 to 4 months for a six-
13 to 24
due to the larger geography. support staff county program
Begin direct mailing to likely rental property owners. The length of Engagement
Months
time for this step may be dependent on the program’s geographic coordinator and
18 to 24
focus and local mailing times. support staff
Table F6: Research and information technology
Geographic
Implementation Step Key actors Timing
considerations
Database and
Months
Roll out software, data hosting, and other IT requirements. portal specialist,
3 to 12
data analyst
Work with county assessors to integrate assessor data into database. Time
Database and Time may be reduced by
considerations for this step will vary based on the program’s geographic Months
portal specialist, 3 to 6 months for a six-
focus. Data sharing and integration for a six-county approach will likely 6 to 24
data analyst county program
take two-thirds to half the time of a statewide effort.
Work with cities with existing registries and/or rental business licenses to
integrate data into database. Time considerations for this step will vary Database and Time may be reduced by
Months
based on the program’s geographic focus. Data sharing and integration for portal specialist, 3 to 6 months for a six-
6 to 24
a six-county approach will likely take two-thirds to half the time of a data analyst county program
statewide effort.
Database and
Months
Test and refine reporting and data management functions. portal specialist,
13 to 24
data analyst
Launch (Years 3 to 4)
Table F7: Management and oversight
Implementation step Key actors Timing
Track early program impacts and effectiveness, adjust approaches as Program coordinator and support Years 3 to 4 and
needed. staff ongoing
Program coordinator and support Years 3 to 4 and
Develop reporting processes and begin reporting.
staff ongoing
Years 3 to 4 and
Review and approve public materials. Program coordinator
ongoing
WASHINGTON RENTAL REGISTRY STUDY 96
Table F8: Outreach, marketing and compliance
Implementation step Key actors Timing
Conduct large outreach campaigns to inform housing providers about the rental Engagement coordinator
Years 1 to 4
registry program. and support staff
Engagement coordinator Year 1 and
Conduct direct mailing and online advertising to likely rental property owners.
and support staff ongoing
Engagement coordinator
Provide technical assistance by phone and email to help housing providers register, Year 3 to 4
and technical assistance
allow tenants to report rental properties, and respond to other inquiries. and ongoing
staff
Work with data analysts to continuously update outreach list with noncompliant Engagement coordinator Year 3 to 4
properties. Continue regular outreach efforts to those properties. and support staff and ongoing
Pursue thorough compliance efforts in markets throughout the state, including Engagement coordinator
Year 4 and
identifying likely noncompliant property owners, incurring and collecting penalties, and technical assistance
ongoing
and pursuing legal action as necessary. staff
Table F9: Research and information technology
Implementation step Key actors Timing
Manage the program’s database, conduct regular data analysis and reporting as Database and portal Year 3 to 4
required, regularly check for quality control. specialist, data analyst and ongoing
Work with county assessors to integrate assessor data annually or according to Database and portal
Years 3 to 4
assessment schedules. The length of time required to obtain, clean, and upload data specialist, data analyst,
and ongoing
will vary based on the geographic focus of program. County partners
Database and portal
Analyze and review data regularly to identify unregistered units, incomplete Year 3 to 4
specialist, data analyst,
registrations, or unpaid fees and flag for review by permit specialists. and ongoing
permit specialist
Review flagged permit applications to determine information required to reach Year 3 to 4
Permit Specialist
compliance. and ongoing
Year 4 and
Produce data reports Data analyst
ongoing
Stabilization (Year 5 and ongoing)
Ongoing operations at stabilization will continue similar to operations during the launch period, with more
emphasis on ongoing quality control and data management. Outreach and enforcement activities will continue,
with a focus on identifying major gaps in compliance and conducting outreach and enforcement as needed to
fill those gaps. Research and IT efforts will also continue throughout the program’s operations, with more time
dedicated to application and renewal review.
WASHINGTON RENTAL REGISTRY STUDY 97
Appendix G. Rental registry financial requirements
Summary of relevant takeaways
This analysis offers high-level cost estimates for a statewide rental registry with annual re-registration
requirements based on projected staff and material needs of such a program. We divided program
implementation into three phases: pre-launch, launch, and post-launch to stabilization. We assume that this
rental registry will reach its maximum compliance rate of 75% after 10 years. Though Seattle’s registry
achieves over 90% compliance, we chose to assume a lower compliance rate due to the complexities of a
statewide registry, the significant increase in the number of units, and the much broader geographic scope.
Clear regulatory incentives and extensive outreach and enforcement efforts will be critical to achieve this
compliance. We present cost estimates as a range to account for different program design and resource
sharing decisions which might impact costs, and we test alternative options, like three-year re-registration
cycles and implementation limited to only the six largest counties, to explore strategies to reduce costs. We
show all costs in 2024 dollars.
A statewide program such as the one the proviso describes will require significant cost to implement and
operate effectively and with high compliance. We estimate that the program will cost approximately $2.5 to
$4.7 million per year for a four-year pre-launch and launch phase, and $3.9 to $6.4 million per year during post-
launch to stabilization. Major categories of program cost include:
Management and oversight of the program
Research and information technology (IT) requirements, including data storage, data management and
analysis, data input for paper registry applications, and reporting
Outreach, marketing, and compliance to educate renters and property owners about the program, provide
technical support, and pursue enforcement of non-compliant properties
Program overhead, or the external costs to Commerce and other state agencies such as human resources,
payroll, and administrative costs.
Notably, these costs exclude potential legal costs incurred from collaboration with the state Attorney
General’s office for efforts to pursue enforcement through lawsuits.
Assuming the high cost range, the rental registry could achieve self-sufficiency at stabilization if it can
achieve sufficient compliance based on the per-unit registration fee. Compliance drives both program costs
and revenues. Higher compliance means more property owners pay registration fees, but it also means that
there are more applications that require more staff to review. While higher fees generate more revenue, they
also impact costs. Our model assumes a 2.5% payment processing fee, which means that higher fees incur
higher payment processing costs. Because of these variables, there is not a single point for fee or compliance
at which this program will become self-sufficient. Instead, different fees require different levels of compliance
to achieve self-sufficiency, as shown in the following matrix.
WASHINGTON RENTAL REGISTRY STUDY 98
Table G1: Estimated annual deficit or surplus
Per unit fee Compliance rate
10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
$5 -$4.2M -$4.0M -$3.8M -$3.6M -$3.4M -$3.2M -$3.0M -$2.7M -$2.5M -$2.3M
$10 -$3.8M -$3.2M -$2.6M -$2.0M -$1.4M -$801K -$201K $399K $1.0M $1.6M
$15 -$3.4M -$2.4M -$1.4M -$428K $565K $1.6M $2.6M $3.5M $4.5M $5.5M
$20 -$3.0M -$1.6M -$242K $1.1M $2.5M $3.9M $5.3M $6.7M $8.1M $9.5M
$25 -$2.6M -$842K $938K $2.7M $4.5M $6.3M $8.1M $9.8M $11.6M $13.4M
$30 -$2.2M -$55K $2.1M $4.3M $6.5M $8.6M $10.8M $13.0M $15.2M $17.3M
This matrix reflects the assumptions below. Any changes to these assumptions change the breakeven point
at which this program becomes self-sufficient.
Assumptions:
This analysis reflects staffing at stabilization, not during the “launch” or “pre-launch” periods. It excludes
one-time software costs and other startup costs.
The program allows a 50% discount for early registration; we assume that 50% of units qualify for this early
registration discount each year.
The analysis assumes enforcement costs are fixed – i.e. enforcement costs do not increase if compliance
is lower than expected.
The analysis assumes annual payment processing fee of 2.5% multiplied by the number of units renewing
and the per unit fee, including discounts.
The analysis assumes that some other operating costs – such as data analysis – scale with compliance.
The program is statewide.
The program requires annual reregistration and uses high cost estimates.
With these assumptions, the program could produce enough revenue to cover most of its costs with a
minimal per-unit registration fee. With a $10 fee, the registry will be self-sufficient if it achieves 80%
compliance. With a $15 fee, the registry will be self-sufficient at 50% compliance. Our cost analysis assumes
75% compliance at stabilization, meaning a $15 fee will make the registry self-sufficient under these
assumptions. This fee is greater than the actual stabilized per-unit cost of about $8 at 75% compliance
because of the assumptions regarding discounts for early registration, which reduce per-unit revenue to $7.50
for those units that take advantage. If this registry were to apply only to the six largest counties, this breakeven
point remains comparable, requiring about 80% compliance with a $10 per unit fee and 50% compliance with a
$15 per unit fee. This is because the reduction in units associated with the six county scenario reduces costs
and revenue proportionally. The additional efficiencies gained in the six county scenario that do not scale with
compliance are not enough to shift the breakeven point.
Importantly, actual compliance rates and uptake of incentives for early registration make actual program
revenue uncertain. The state must develop clear regulatory incentives and pursue extensive outreach and
enforcement to achieve the revenues we project, though outreach and enforcement beyond our projections will
WASHINGTON RENTAL REGISTRY STUDY 99
further increase costs. The state should keep fees consistent most years to ensure predictability, but can
increase costs every few years to account for increased program operating expenses due to enforcement
requirement, inflation, or other factors
Limiting implementation to the six largest counties creates notable operating efficiencies but will exclude
many rural rental homes. The six largest counties (Clark, King, Pierce, Snohomish, Spokane, and Thurston)
together account for approximately 74% of renter-occupied homes in the state. A registry limited to these
counties would therefore cover almost three quarters of rental homes, while providing a significant reduction
in the geography required for outreach and marketing, and the number of counties the state would need to
coordinate with to incorporate assessor data and potentially to pursue enforcement measures. Together, the
reduced application volume, geographic focus, and bureaucratic efficiencies result in a 20% to 25% reduction
in cost. However, this option would exclude many parts of the state, including much of central and western
Washington and many rural areas.
Table G2: Summary of program cost by scenario
Annual cost range Annual re-registration cycle
Pre-launch (Years 1 to 2) Statewide: $2.5 - $4.4 million; Six counties: $2.0 - $3.4 million
Launch (Years 3 to 4) Statewide: $3.0 - $4.7 million; Six counties: $2.4 - $3.7 million
Post-launch to stabilization (Year 5 and ongoing) Statewide: $3.9 - $6.4 million; Six counties: $3.1 - $4.8 million
Other design changes could reduce program costs but would reduce the amount or timeliness of data
available through the rental registry. To reduce costs, the state could require re-registration every three years
instead of annually. This would reduce the annual volume of applications and require fewer staff to oversee
the program, but rental market data would be less timely. The state could also reduce the outreach and
compliance functions of the program to limit costs, but this would likely result in much lower compliance rates
which will make the program less effective and could reduce the program’s financial sustainability.
Our cost estimates reflect a range of potential program design decisions, compliance rates, and outreach
methods which will have impacts on program cost. One of the primary differences between the higher and
lower cost estimates is the potential to use existing county and city outreach and data functions to reduce
costs to the state. If the state can easily integrate county assessor’s data into its database, and partner with
cities with existing rental registries both to incorporate data where possible and to use existing city outreach
methods, this could reduce staff and marketing costs to the state. The high end of the cost estimates
assumes that the state’s program uses no city or county resources to operate its registry.
Introduction
Purpose
The following outlines the anticipated costs to launch and operate a state rental registry as well as the
potential for registration fees to offset the cost of the program.
Methods
Existing programs are much smaller than a state program would be, so none are exactly comparable in scale
to the proposed statewide program. Scaling the cost per unit of these programs to the state level does not
WASHINGTON RENTAL REGISTRY STUDY 100
account for possible operating efficiencies of a larger program. Based on cost data from city-level rental
registries in Washington per-unit costs are between $16 and $25 for localities with fewer than 200,000 rental
units. Applying these per unit costs to all renter occupied units in the state leads to annual costs between $17
and $27 million, however we estimate that a statewide program would have some operating efficiencies that
would keep costs lower. We used our understanding of the operating functions of other registries to outline the
types of roles required to implement this registry and to estimate how certain roles do or do not scale to
impact staffing levels, using staffing benchmarks from existing rental registry programs. We detail
assumptions on operating functions, staff positions, and their scaling in the Operating Functions, Key Staff,
and Staff Scaling table. We used salaries from comparable positions in the Department of Commerce to
calculate staff costs, adding allowances for benefits and overhead.
For non-staff costs, we priced the costs of printing and mailing materials using the retail costs of stamps,
envelopes, and printed pages. We used estimates from Artesia Systems for the cost of establishing a
database and online portal, licensing software, hosting data, and processing payments.
We show all costs in 2024 dollars.
Table G3: Operating functions, key staff and staff scaling
Function Position Scaling
Program Coordinator Fixed
Management and oversight
Program Coordinator Support Fixed
Engagement Coordinator Fixed
Outreach, marketing and compliance Engagement Support Scales by number of counties subject to rental registry
Public Technical Assistance Scales by phase of implementation
Permit Specialist Scales by number of applications
Database and Portal Specialist Fixed
Research and information technologies (IT)
Scales by phase of implementation and number of
Data Analyst
counties subject to rental registry
HR and Payroll Scales by staffing costs
Overhead related to staffing Legal Scales by staffing costs
Other Interagency Support Scales by staffing costs
Cost estimates
Phases of implementation
Operational and administrative needs for the rental registry, and the respective costs, will vary across various
phases of the program rollout.
WASHINGTON RENTAL REGISTRY STUDY 101
Table G4: Implementation activities by phase
Pre-launch Launch Post-launch to stabilization
(Years 1 to 2) (Years 3 to 4) (Year 5 and ongoing)
Develop major data and Provide ongoing data
Continue extensive outreach and
management systems management, analysis, and
marketing
Develop informational reporting
Manage program launch, with technical
Primary and marketing materials Provide ongoing outreach
assistance, data quality assurance, and
activities Conduct extensive through direct mail and other
initial reporting
outreach and marketing avenues
Begin robust compliance efforts
Hire staff and prepare for Continue robust compliance
Grow operational capacity
launch activities
Estimated
$2.5 to $4.4 million $3.0 to $4.7 million $3.9 to $6.4 million
annual cost
Operational needs and associated costs
There are four primary categories of cost associated with the operations of the rental registry program.
Management and oversight
The program will require management and oversight functions, including management of personnel,
monitoring all activities, and reporting on compliance and other metrics of success:
Personnel requirements: Two full-time equivalent (FTE) positions during pre-launch, launch, and post-launch to
stabilization, including a program coordinator and a program coordinator support staff person.
Estimated cost: About $309,000 per year during pre-launch, launch, and post-launch to stabilization.
Outreach, marketing and compliance
The rental registry will not achieve compliance without significant investment in outreach, marketing, and
compliance efforts. Primary activities will include:
Conducting a large, outreach campaign in markets throughout the state, with informational materials,
meetings, direct mailings, and marketing (such as online advertising) to inform housing providers about
the rental registry program during pre-launch and launch
Conducting ongoing outreach and marketing annually to likely rental property owners, including direct
mailing and online advertising,
Providing technical assistance by phone and email to help housing providers register, allow tenants to
report rental properties, and respond to other inquiries
Pursuing thorough compliance efforts in markets throughout the state, including identifying likely
noncompliant property owners, incurring and collecting penalties, and pursuing legal action as necessary
Personnel requirements: 6 to 18 full-time equivalent (FTE) positions during pre-launch and launch and 6 to 16
FTE positions during post-launch to stabilization, including engagement and enforcement coordinators,
engagement and enforcement support staff, and public facing technical assistance staff. The low end of this
WASHINGTON RENTAL REGISTRY STUDY 102
range reflects the possibility that this registry can leverage existing engagement infrastructure in cities with
existing rent registries, and that if not it will require a significant investment in outreach staff to achieve
meaningful compliance.
Estimated cost: $1.3 million to $2.3 million per year during pre-launch and launch; $1.1 million to $2.1 million
per year during post-launch to stabilization
Research and Information Technology (IT)
Operating the rental registry program will require a number of activities related to data, research, and IT to
create and host a database and ensure its accuracy. Primary activities will include:
Creating or purchasing software to perform major online portal and database functions
Data hosting
Database management, data analysis, reporting, and quality control
Data integration (e.g. regular integration of county assessors’ property records) and data entry (for paper
registration forms)
Data review and flagging incomplete registrations for review by a permit specialist
Review of flagged permit applications to determine compliance
Personnel requirements: 3 to 8 full-time equivalent (FTE) positions during pre-launch and launch and 14 to 16
during post-launch to stabilization, including database and online portal specialists, data analysts, and permit
specialists. The number of employees required changes by phase and compliance – for instance, the number
of data analysts required increases as they receive, process, and integrate assessor data from counties, enter
data from mail-in registrations, and flag incomplete data for permit specialists. The number of permit
specialists increases as compliance increases because more applications and renewals require review.
The low end of this range represents lower workloads during pre-launch and launch, as well as potential
collaboration with county assessors if they can prepare data for integration with the state’s system instead of
the state taking on that function. The state could also choose to outsource many of these responsibilities,
which would reduce the FTE requirements associated with the Research and Information Technology (IT)
function of a rental registry even further but would require a vendor purchase at a similar price scale.
Estimated cost: $419,000 to $1.1 million per year during pre-launch and launch; $1.4 million to $2.1 million per
year during post-launch to stabilization.
Overhead
Operating a rental registry program will create overhead expenses. Commerce will incur costs related to hiring
and management, office space, supplies, and technology for new staff, and added demands for other services
such as legal services, reporting, payroll, etc.
Estimated cost: $428,000 to $1.1 million per year during pre-launch and launch; $1.1 million to $1.9 million per
year during post-launch to stabilization
WASHINGTON RENTAL REGISTRY STUDY 103
Table G5: Program operating costs, statewide implementation
Year 1 Year 2 Year 4
Year 3 (launch) Year 5* Year 6* Year 7* Year 8* Year 9* Year 10*
(pre-launch) (pre-launch) (launch)
Est. compliance rate 0% 0% 5% 20% 50% 55% 60% 65% 70% 75%
Management and oversight $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150
Outreach, marketing and $1.1 - $1.3 - $1.3 - $1.3 - $1.3 - $1.3 -
$1.3 - $2.2M $1.3 - $2.2M $1.5 - $2.3M $1.4 - $2.2M
compliance $1.9M $2.1M $2.1M $2.1M $2.1M $2.1M
$885,489 - $419,255 - $612,641 - $822,631 - $1.4 - $1.4 - $1.5 - $1.6 - $1.6- $1.7 -
Research and IT
$1.1M $666,035 $859,421 $1.1M $1.7M $1.8M $1.9M $1.9M $2.0M $2.1M
$428,220 - $428,220 - $590,801 - $781,815 - $1.1 - $1.2 - $1.3 - $1.3 - $1.4 - $1.5 -
Overhead
$780,480 $780,480 $943,061 $1.1M $1.5M $1.6M $1.7M $1.7M $1.8M $1.9M
$3.9 - $4.3 - $4.4 - $4.5 - $4.7 - $4.8 -
Total costs $3.0 - $4.4M $2.5 - $3.9M $3.0 - $4.4M $3.3 - $4.7M
$5.5M $5.8M $6.0M $6.1M $6.2M $6.4M
*Year six to ten are in the post launch phase. The program is estimated to reach stabilization at year ten.
Table G6: Program operating costs, six largest counties implementation
Year 1 Year 2 Year 3 Year 4
Year 5* Year 6* Year 7* Year 8* Year 9* Year 10*
(pre-launch) (pre-launch) (launch) (launch)
Est. compliance rate 0% 0% 5% 20% 50% 55% 60% 65% 70% 75%
Management and
$309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150
oversight
Outreach, marketing $987,815 - $987,815 - $846,719 - $964,299 - $964,299 - $964,299 - $964,299 - $964,299 -
$1.1 - $1.8M $1.1 - $1.7M
and compliance $1.6M $1.6M $1.5M $1.6M $1.6M $1.6M $1.6M $1.6M
$762,099- $295,865- $471,133- $626,768 -
Research and IT $1.1 - $1.2M $1.1 - $1.2M $1.2 - $1.3M $1.2 - $1.3M $1.3 - $1.4M $1.3 - $1.4M
$885,489 $419,255 $594,523 $750,158
$360,090 - $360,090 - $506,190 - $647,761 - $914,252 - $961,443 -
Overhead $1.0 - $1.3M $1.1 - $1.3M $1.1 - $1.4M $1.2 - $1.4M
$617,220 $617,220 $763,320 $904,891 $1.2M $1.2M
$3.1 - $3.3 - $3.4 - $3.5 - $3.6 - $3.7 -
Total costs $2.4 - $3.4M $2.0 - $3.0M $2.4 - $3.5M $2.7 - $3.7M
$4.2M $4.4M $4.5M $4.6M $4.7M $4.8M
*Year six to ten are in the post launch phase. The program is estimated to reach stabilization at year ten.
WASHINGTON RENTAL REGISTRY STUDY 104
Approaches to cost reduction
There are three main approaches that Washington can pursue to reduce the costs of a rental registry:
1. Limiting implementation to the six largest counties creates notable operating efficiencies but will exclude
many rural rental homes. The six largest counties (Clark, King, Pierce, Snohomish, Spokane, and Thurston)
together account for approximately 74% of renter-occupied homes in the state. A registry limited to these
counties would therefore cover almost three quarters of rental homes, while providing a significant
reduction in the geography required for outreach and marketing, and the number of counties the state
would need to coordinate with to incorporate assessor data and potentially to pursue enforcement
measures. Together, the reduced application volume, geographic focus, and bureaucratic efficiencies
result in an approximate 20% to 25% reduction in cost. However, this option would exclude many parts of
the state, including much of central and western Washington and many rural areas, and would overlap
significantly with existing registries, which cover 49% of units in the six largest counties.
2. To reduce program costs, the state could require re-registration every three years instead of annually,
though this approach reduces the timeliness of data. Requiring annual re-registration means that at
stabilization, every property owner will need to re-submit unit data each year. This leads to a high volume of
applications each year, and will require ongoing data management, quality control, data entry for paper
applications, and enforcement actions. By only requiring re-registration every three years the state reduces
annual applications to one-third of the volume. This approach requires fewer program staff and results in
an approximate 25% reduction in cost. However, with this approach some unit data, such as rents and
vacancy, could be one or two years out of date. In addition, this approach could reduce revenue if its fees
do not reflect a three-year renewal period. A registry taking this approach would need to adjust its fee
structure to ensure the same revenues in order to achieve cost savings.
3. Reduce outreach and compliance functions. Depending on the implementation phase, outreach, marketing,
and compliance activities account for between 34% and 51% of total program cost. With limited outreach
and compliance, Commerce can significantly reduce the cost of rental registries. However, this approach
will result in much lower compliance, which will make the rental registry significantly less effective and
could reduce the program’s financial sustainability.
Program revenue potential
Most rental registries charge a registration fee. To limit the potential for unintended consequences and
burdens to both property owners and renters, the state should minimize fees. At stabilization, the rental
registry could achieve self-sufficiency if it can achieve sufficient compliance based on the per-unit registration
fee. Compliance drives both program costs and revenues. Higher compliance means more property owners
pay registration fees, but it also means that there are more applications that require more staff to review. While
higher fees generate more revenue, they also impact costs. Our model assumes a 2.5% payment processing
fee, which means that higher fees incur higher payment processing costs. Because of these variables, there is
not a single point for fee or compliance at which this program will become self-sufficient. Instead, different
fees require different levels of compliance to achieve self-sufficiency, as shown in the following matrix.
WASHINGTON RENTAL REGISTRY STUDY 105
Table G7: Estimated annual deficit or surplus of statewide program
Per unit fee Compliance rate
10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
$5 -$4.2M -$4.0M -$3.8M -$3.6M -$3.4M -$3.2M -$3.0M -$2.7M -$2.5M -$2.3M
$10 -$3.8M -$3.2M -$2.6M -$2.0M -$1.4M -$801K -$201K $399K $1.0M $1.6M
$15 -$3.4M -$2.4M -$1.4M -$428K $565K $1.6M $2.6M $3.5M $4.5M $5.5M
$20 -$3.0M -$1.6M -$242K $1.1M $2.5M $3.9M $5.3M $6.7M $8.1M $9.5M
$25 -$2.6M -$842K $938K $2.7M $4.5M $6.3M $8.1M $9.8M $11.6M $13.4M
$30 -$2.2M -$55K $2.1M $4.3M $6.5M $8.6M $10.8M $13.0M $15.2M $17.3M
This matrix reflects the assumptions below. Any changes to these assumptions change the breakeven point
at which this program becomes self-sufficient.
Assumptions
This analysis reflects staffing at stabilization, not during the “launch” or “pre-launch” periods. It excludes
one-time software costs and other startup costs.
The program allows a 50% discount for early registration; we assume that 50% of units qualify for this early
registration discount each year.
The analysis assumes enforcement costs are fixed – i.e. enforcement costs do not increase if compliance
is lower than expected.
The analysis assumes annual payment processing fee of 2.5% multiplied by the number of units renewing
and the per unit fee, including discounts.
The analysis assumes that some other operating costs – such as data analysis – scale with compliance.
The program is statewide.
The program requires annual reregistration.
With these assumptions, the program could produce enough revenue to cover most of its costs with a
minimal per-unit registration fee. With a $10 fee, the registry will be self-sufficient if it achieves 80%
compliance. With a $15 fee, the registry will be self-sufficient at 50% compliance. Our cost analysis assumes
75% compliance at stabilization, meaning a $15 fee will make the registry self-sufficient under these
assumptions. This fee is greater than the actual stabilized per-unit cost of about $8 at 75% compliance
because of the assumptions regarding discounts for early registration, which reduce per-unit revenue to $7.50
for those units that take advantage. If this registry were to apply only to the six largest counties, this breakeven
point remains comparable, requiring about 80% compliance with a $10 per unit fee and 50% compliance with a
$15 per unit fee. This is because the reduction in units associated with the six county scenario reduces costs
and revenue proportionally. The additional efficiencies gained in the six county scenario that do not scale with
compliance are not enough to shift the breakeven point.
Importantly, actual compliance rates and uptake of incentives for early registration make actual program
revenue uncertain. The state must develop clear regulatory incentives and pursue extensive outreach and
enforcement to achieve the revenues we project, though outreach and enforcement beyond our projections will
WASHINGTON RENTAL REGISTRY STUDY 106
further increase costs. The state should keep fees consistent most years to ensure predictability and can
increase costs every few years to account for increased program operating expenses due to enforcement
requirement, inflation, or other factors.
Detailed assumptions
We used the staffing assumptions shown in the following tables to determine staffing costs. The range of FTE represents
decisions the state could make to reduce staffing needs, namely using existing county and city outreach and data
functions to reduce the need for more staff at the state. We assume benefits increase staff costs by 35% of salary, and
that the state incurs an additional cost of 45% of salary costs related to overhead, like payroll and HR, legal, building rent,
and other overhead expenses. We show salaries and all other costs in 2024 dollars.
Table G8: Staffing assumptions - statewide implementation
Staff positions Salary Pre-launch FTE six largest counties Launch FTE Post-launch to stabilization FTE
Program Coordinator $128,200 1 1 1
Program Coordinator Support $100,800 1 1 1
Permit Specialist $96,400 0 0.00001/Unit 0.00001/Unit
Database and Portal Specialist $111,800 1 1 1
Data Analyst $91,400 2-4 3-5 4-7
Engagement Coordinator $89,800 2 2 2
Engagement Support $60,000 2 - 12 2 - 12 2 - 12
Public Technical Assistance $64,200 2 4 2
Table G9: Staffing assumptions - statewide implementation
Staff positions Salary Pre-launch FTE six largest counties Launch FTE Post-launch to stabilization FTE
Program Coordinator $128,200 1 1 1
Program Coordinator Support $100,800 1 1 1
Permit Specialist $96,400 0 0.00001/Unit 0.00001/Unit
Database and Portal Specialist $111,800 1 1 1
Data Analyst $91,400 1-2 2-3 3-4
Engagement Coordinator $89,800 2 2 2
Engagement Support $60,000 1-9 1-9 1-9
Public Technical Assistance $64,200 2 4 2
We base non-staff costs on retail costs of basic materials for physical outreach mailers (i.e., the cost of stamps,
envelopes, and printed pages) and estimates from Commerce on the costs of building a database, licensing software, and
storing data. We list these assumptions in the following tables. We also assume a payment processing fee of 1.5%.
WASHINGTON RENTAL REGISTRY STUDY 107
Table G10: Non-staff outreach and data costs
Outreach material expenses Cost Database expenses Cost
Cost per stamp $0.73 One-time database and portal costs $466,234
Cost per envelope $0.02 Annual licensing $1,545
Cost per page printed $0.05 Data storage $20,000
Average mailers per property per year 2
WASHINGTON RENTAL REGISTRY STUDY 108
Detailed budgets
High cost estimates
Table G11: Statewide implementation with annual reregistration
Year 1 Year 2 (pre- Year 3 Year 4
Year 5* Year 6* Year 7* Year 8* Year 9* Year 10*
(pre-launch) launch) (launch) (launch)
Est. compliance rate 0% 0% 5% 20% 50% 55% 60% 65% 70% 75%
Management and oversight $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150
Outreach, marketing and
$2,153,521 $2,153,521 $2,290,188 $2,216,731 $1,933,036 $2,115,723 $2,115,611 $2,115,498 $2,115,386 $2,115,273
compliance
Research and IT $1,132,269 $666,035 $859,421 $1,069,411 $1,736,169 $1,806,166 $1,876,162 $1,946,159 $2,016,155 $2,086,152
Overhead $780,480 $780,480 $943,061 $1,134,075 $1,540,583 $1,604,254 $1,667,925 $1,731,597 $1,795,268 $1,858,939
Total costs $4,375,420 $3,909,186 $4,401,821 $4,729,367 $5,518,938 $5,835,293 $5,968,849 $6,102,404 $6,235,959 $6,369,514
*Year six to ten are in the post launch phase. The program is estimated to reach stabilization at year ten.
Table G12: Six largest counties implementation with annual reregistration
Year 1 Year 2 (pre- Year 3 Year 4
Year 5* Year 6* Year 7* Year 8* Year 9* Year 10*
(pre-launch) launch) (launch) (launch)
Est. compliance rate 0% 0% 5% 20% 50% 55% 60% 65% 70% 75%
Management and oversight $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150
Outreach, marketing and
$1,635,815 $1,635,815 $1,785,639 $1,738,607 $1,494,719 $1,612,299 $1,612,299 $1,612,299 $1,612,299 $1,612,299
compliance
Research and IT $885,489 $419,255 $594,523 $750,158 $1,184,817 $1,236,695 $1,288,573 $1,340,451 $1,392,329 $1,444,207
Overhead $617,220 $617,220 $763,320 $904,891 $1,171,382 $1,218,573 $1,265,763 $1,312,953 $1,360,143 $1,407,334
Total costs $3,447,674 $2,981,440 $3,452,632 $3,702,806 $4,160,068 $4,376,716 $4,475,785 $4,574,853 $4,673,922 $4,772,990
*Year six to ten are in the post launch phase. The program is estimated to reach stabilization at year ten.
WASHINGTON RENTAL REGISTRY STUDY 109
Table G13: Statewide implementation with three-year reregistration
Year 1 (pre- Year 2 (pre- Year 3 Year 4
Year 5* Year 6* Year 7* Year 8* Year 9* Year 10*
launch) launch) (launch) (launch)
Est. compliance rate 0% 0% 5% 20% 50% 55% 60% 65% 70% 75%
Management and oversight $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150
Outreach, marketing and
$2,153,521 $2,153,521 $2,290,188 $2,180,171 $1,786,796 $1,786,684 $1,823,131 $1,896,139 $1,713,226 $1,749,674
compliance
Research and IT $1,132,269 $666,035 $859,421 $999,414 $1,456,184 $1,176,198 $1,316,191 $1,526,180 $1,246,194 $1,386,187
Overhead $780,480 $780,480 $943,061 $1,070,404 $1,285,898 $1,031,213 $1,158,555 $1,349,569 $1,094,884 $1,222,226
Total costs $4,375,420 $3,909,186 $4,401,821 $4,559,139 $4,838,028 $4,303,244 $4,607,027 $5,081,038 $4,363,455 $4,667,237
*Year six to ten are in the post launch phase. The program is estimated to reach stabilization at year ten.
Table G14: Six largest counties implementation with three-year reregistration
Year 1 (pre- Year 2 (pre- Year 3 Year 4
Year 5* Year 6* Year 7* Year 8* Year 9* Year 10*
launch) launch) (launch) (launch)
Est. compliance rate 0% 0% 5% 20% 50% 55% 60% 65% 70% 75%
Management and oversight $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150
Outreach, marketing and
$1,635,815 $1,635,815 $1,785,639 $1,715,091 $1,400,655 $1,400,655 $1,424,171 $1,471,203 $1,353,623 $1,377,139
compliance
Research and IT $885,489 $419,255 $594,523 $698,279 $977,304 $769,791 $873,548 $1,029,182 $821,669 $925,426
Overhead $617,220 $617,220 $763,320 $857,701 $982,621 $793,860 $888,241 $1,029,812 $841,051 $935,431
Total costs $3,447,674 $2,981,440 $3,452,632 $3,580,221 $3,669,730 $3,273,456 $3,495,109 $3,839,347 $3,325,493 $3,547,146
*Year six to ten are in the post launch phase. The program is estimated to reach stabilization at year ten.
WASHINGTON RENTAL REGISTRY STUDY 110
Low cost estimates
Table G15: Statewide implementation with annual reregistration
Year 1 (pre- Year 2 (pre- Year 3 Year 4
Year 5* Year 6* Year 7* Year 8* Year 9* Year 10*
launch) launch) (launch) (launch)
Est. compliance rate 0% 0% 5% 20% 50% 55% 60% 65% 70% 75%
Management and oversight $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150
Outreach, marketing and
$1,343,521 $1,343,521 $1,480,188 $1,406,731 $1,123,036 $1,305,723 $1,305,611 $1,305,498 $1,305,386 $1,305,273
compliance
Research and IT $885,489 $419,255 $612,641 $822,631 $1,365,999 $1,435,996 $1,505,992 $1,575,989 $1,645,985 $1,715,982
Overhead $428,220 $428,220 $590,801 $781,815 $1,147,193 $1,210,864 $1,274,535 $1,338,207 $1,401,878 $1,465,549
Total costs $2,966,380 $2,500,146 $2,992,781 $3,320,327 $3,945,378 $4,261,733 $4,395,289 $4,528,844 $4,662,399 $4,795,954
*Year six to ten are in the post launch phase. The program is estimated to reach stabilization at year ten.
Table G16: Six largest counties implementation with annual reregistration
Year 1 (pre- Year 2 (pre- Year 3 Year 4
Year 5* Year 6* Year 7* Year 8* Year 9* Year 10*
launch) launch) (launch) (launch)
Est. compliance rate 0% 0% 5% 20% 50% 55% 60% 65% 70% 75%
Management and oversight $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150
Outreach, marketing and
$987,815 $987,815 $1,137,639 $1,090,607 $846,719 $964,299 $964,299 $964,299 $964,299 $964,299
compliance
Research and IT $762,099 $295,865 $471,133 $626,768 $1,061,427 $1,113,305 $1,165,183 $1,217,061 $1,268,939 $1,320,817
Overhead $360,090 $360,090 $506,190 $647,761 $914,252 $961,443 $1,008,633 $1,055,823 $1,103,013 $1,150,204
Total costs $2,419,154 $1,952,920 $2,424,112 $2,674,286 $3,131,548 $3,348,196 $3,447,265 $3,546,333 $3,645,402 $3,744,470
*Year six to ten are in the post launch phase. The program is estimated to reach stabilization at year ten.
WASHINGTON RENTAL REGISTRY STUDY 111
Table G17: Statewide implementation with three-year reregistration
Year 1 (pre- Year 2 (pre- Year 3 Year 4
Year 5* Year 6* Year 7* Year 8* Year 9* Year 10*
launch) launch) (launch) (launch)
Est. compliance rate 0% 0% 5% 20% 50% 55% 60% 65% 70% 75%
Management and oversight $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150
Outreach, marketing and
$1,343,521 $1,343,521 $1,480,188 $1,370,171 $976,796 $976,684 $1,013,131 $1,086,139 $903,226 $939,674
compliance
Research and IT $885,489 $419,255 $612,641 $752,634 $1,086,014 $806,028 $946,021 $1,156,010 $876,024 $1,016,017
Overhead $428,220 $428,220 $590,801 $718,144 $892,508 $637,823 $765,165 $956,179 $701,494 $828,836
Total costs $2,966,380 $2,500,146 $2,992,781 $3,150,099 $3,264,468 $2,729,684 $3,033,467 $3,507,478 $2,789,895 $3,093,677
*Year six to ten are in the post launch phase. The program is estimated to reach stabilization at year ten.
Table G18: Six largest counties implementation with three-year reregistration
Year 1 (pre- Year 2 (pre- Year 3 Year 4
Year 5* Year 6* Year 7* Year 8* Year 9* Year 10*
launch) launch) (launch) (launch)
Est. compliance rate 0% 0% 5% 20% 50% 55% 60% 65% 70% 75%
Management and oversight $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150 $309,150
Outreach, marketing and
$987,815 $987,815 $1,137,639 $1,067,091 $752,655 $752,655 $776,171 $823,203 $705,623 $729,139
compliance
Research and IT $762,099 $295,865 $471,133 $574,889 $853,914 $646,401 $750,158 $905,792 $698,279 $802,036
Overhead $360,090 $360,090 $506,190 $600,571 $725,491 $536,730 $631,111 $772,682 $583,921 $678,301
Total costs $2,419,154 $1,952,920 $2,424,112 $2,551,701 $2,641,210 $2,244,936 $2,466,589 $2,810,827 $2,296,973 $2,518,626
*Year six to ten are in the post launch phase. The program is estimated to reach stabilization at year ten.
WASHINGTON RENTAL REGISTRY STUDY 112
Appendix H: Artesia report on technical requirements
and considerations
Executive summary
Overview
Commerce partnered with Artesia Systems to assess the technical requirements for developing a statewide
rental registry portal that complies with legislative mandates. Artesia's analysis focused on key functional
elements, including system design, and implementation. The technical evaluation detailed in this appendix laid
the groundwork for understanding the system's complexity, which in turn informed the financial requirements
detailed in Appendix G: Rental Registry Financial Requirements. This appendix outlines the methodology used
to generate accurate cost estimates for both building the portal in-house and procuring an external vendor
solution. It also provides a timeline for the portal's technical deployment. The timeline estimates helped
determine the length of the pre-launch phase.
Please note: The costs of an internal system and the ongoing operation costs identified in this appendix have
been incorporated into the financial requirements detailed in Appendix G: Rental registry financial
requirements of this report, ensuring a comprehensive understanding of the financial costs required to
support the program.
Key findings
Internal build cost analysis and comparison with external solutions
The estimated cost for developing the rental registry system internally is approximately $466,234, which
includes a 20% contingency for unforeseen challenges and $100,800 for integrating assessor data. An internal
build offers Commerce full control over system design, customization, and updates, ensuring the platform
aligns with Washington's specific needs and regulatory requirements. Ongoing operational costs for the
internal system are projected at $184,545 per year, with only marginal increases tied to general factors such as
cost-of-living adjustments, rather than the number of registered units.
A key advantage of an internal build is its flexibility for customization. As requirements evolve, the internal
system can be easily updated to accommodate new features without relying on an external vendor. This ability
to adapt ensures Commerce can meet future program needs efficiently, without the delays or extra fees
associated with vendor modifications.
In contrast, external vendor solutions offer lower upfront costs, ranging from $20,000 to $75,000, depending
on the number of registered units. However, ongoing costs for vendor-managed systems increase as the
registry grows, since vendors typically charge based on the number of registrations. This can lead to
significant long-term expenses, especially for large-scale systems. Over time, the internal system becomes
more cost-effective, with the breakeven point occurring between years 10 and 18, depending on the growth
trajectory of the registry.
Additionally, because external vendors charge for system modifications, any customization needs would likely
move the breakeven point even earlier than the initial estimate. Vendor systems lack the inherent flexibility of
internal builds, as future customizations would require additional time and fees, further driving up costs.
WASHINGTON RENTAL REGISTRY STUDY 113
Ultimately, an internal build offers long-term financial stability, greater flexibility, and the ability to efficiently
adapt to changing needs, making it the more sustainable and economical choice for a large-scale, statewide
rental registry, both cost-efficiency and the ability to meet Washington’s evolving needs.
Implementation timeline
The timeline for developing the rental registry portal, whether through internal development or vendor
solutions, is estimated to take approximately nine months. While external vendors estimate a shorter
deployment time of three to six months, neither vendor includes the collection or processing of assessor data,
a task that is expected to take around nine months. As a result, both vendor solutions and the internal build will
ultimately follow a similar overall timeline, making any potential time savings negligible when comparing these
options.
Integration with existing local registries
Integrating data from local rental registries presents challenges due to differences in data types and system
architectures. Rather than attempting full integration, it is more practical for local registries to upload their
data via a standardized Excel template, reducing complexity and costs while ensuring the state system can
incorporate essential data from multiple sources.
Statewide implementation versus six largest counties
From a technical perspective, the costs to develop a system to support rental registry for all counties in the
state versus the six largest counties is relatively similar. Whether creating a system for one county or 39
counties, the system itself would be the same. The cost for the data storage would also be relatively similar.
The difference would be in the time and cost to incorporate assessor data from the additional 33 counties.
Introduction
During the 2023 legislative session, the Washington State Legislature included a proviso in the operating
budget to allocate resources for the Department of Commerce (Commerce) to develop a comprehensive
report on the creation or procurement of an online registry for rental units in Washington.
To meet the legislative mandate, Commerce engaged Artesia Systems, a firm with extensive experience in
similar projects, including the development of the Clean Buildings Registry Program and a current project on
tracking and registering supportive housing units funded by Commerce. Artesia Systems was tasked with
detailing the scope of work, producing detailed cost estimates and outlining an implementation timeline for a
portal that would be built and operated by Commerce. Additionally, Artesia Systems completed an analysis of
existing systems available for adoption, comparing the efficiency of building the portal internally versus
purchasing and adopting an external vendor-operated system.
This report is structured to address two portions of the proviso requirements:
1. A detailed definition of the scope of work required to create or procure the online rental registry
2. An in-depth analysis of the costs associated with both internal development and external procurement,
including potential timelines for each option
Defining a rental registry technical scope of work
To establish the scope of work for the online rental unit registry, we began by analyzing the details specified in
the proviso. The proviso mandates that “the online rental unit registry must have the capacity to collect and
WASHINGTON RENTAL REGISTRY STUDY 114
report out timely information on each rental unit in the state.” Additionally, “the scope of work must assume
integration with existing rental registries operated by local governments.”
Assumptions for initial rental registry portal design
To effectively scope the project and provide accurate cost estimates and timelines, the following assumptions
were established as a starting point, drawing on expected requirements and experiences from previous
registries:
Exclusion of tenant portal: The initial implementation will not include a tenant portal.
Fee collection: A fee structure will be implemented as part of the system.
Batch data upload: The system will allow landlords to upload data for multiple units simultaneously.
Exemption identification: Functionality will be included to identify and manage units that are exempt
from registration or payment requirements.
Integration with local registries: The system will support the upload and integration of data from
existing local government rental registries.
Property manager/owner access: Property managers and owners will be able to login, register their
properties, and view property status, including the date of the last update.
Change history tracking: The system will maintain a detailed history of key changes, such as rent
adjustments, transitions to owner-occupied status, or property sales.
Vacancy updates: The system will collect data regarding vacant units.
Data security via SecureAccess Washington (SAW): The system will utilize SecureAccess Washington to
ensure the security and confidentiality of the data
Comprehensive reporting capabilities: The system will feature a dedicated reporting portal, allowing
authorized users to generate reports on all data elements collected within the registry. This portal will
provide flexible access to data, enabling users to pull customized reports as needed. Permissions and
access levels will be carefully defined and configured to ensure that users can only access the
information relevant to their roles, maintaining data security and integrity throughout the reporting
process.
These assumptions were necessary to define the boundaries of the work, ensuring that the system's
functionality remains focused on meeting the proviso’s requirements while providing a clear framework for the
initial implementation. These design features were included in the cost estimates for the base system. More
analysis will be needed to identify the features required in the final system design.
Data element requirements
To identify best practices for rental registries, we conducted a thorough review of existing rental registry
portals, including both portals operated my municipalities and those available for purchase registries. This
WASHINGTON RENTAL REGISTRY STUDY 115
review allowed us to outline the system’s requirements, focusing on the data to be collected and the scope of
the initial system. While specific data elements were explicitly identified in the proviso, additional data points
were recommended to better align the system with the objectives of the proviso. The system's design and
associated costs were based on these foundational elements. Additional components, such as tenant access,
could be incorporated as needed, but these are not included in the current timeline or cost estimates. Further
decisions would be required depending on the broader purposes and goals of the registry, which are not fully
defined within the legislative intent of the proviso.
Core data elements
The initial step in determining the scope of work, cost and implementation timeline for the rental registry
system involved identifying the specific information that must be collected from property owners. Based on
the proviso language, the following core data elements were identified as essential to achieving the program's
objectives:
Physical address of rental unit
Identity information of the property owner
Monthly rent charged
Vacancy status
Additional data elements
In addition to the core elements, the following supplementary data elements were identified as essential to
support and enhance the core data. These elements were determined through a comprehensive review of
existing systems and collaborative discussions with stakeholders within the Commerce. By integrating these
additional data points, the system will be more robust and better positioned to achieve its goals, delivering a
more comprehensive and effective rental registry portal:
Property details:
• Name of housing complex (if applicable)
• Type of Rental (ADU, Duplex, Multi-Family)
• Parcel #/Property ID Number
Unit details:
• Unit size (number of bedrooms)
• If it is owner occupied
• Utilities and fees included in rent
• Vacancy date
• Date originally rented by the current tenant
• Date of last rent adjustment
Property owner:
• Physical address
• Mailing address
• Phone number
• Business name and Unified Business Identifier (if applicable)
• Type of ownership (partnership, LLC, corporation)
• Unified Business Identifier (optional)
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Local contact or property manager
Building an initial dataset from assessor data
A key component of the scope of work for developing the rental registry portal will be the collection and
analysis of assessor data. Using parcel information from assessor data for potential rental properties offers
two significant benefits. First, it enables targeted outreach to property owners identified as likely rentals,
informing them about the program and their obligation to participate. Second, it aids in compliance—once the
program is established, we can identify parcels that appear to be rentals and notify owners who have not
complied.
Without this base of assessor data, targeted outreach for the rental registry would be difficult, and
participation rates would likely be low. Incorporating assessor data from the start is essential to ensuring the
program's effectiveness and compliance.
Process to collect assessor data
Per WAC 458-53-030, counties in Washington are required to identify land use through a standardized two-digit
land use code. The most relevant codes for our purposes are the residential ones:
11: Household, single-family units
12: Household, 2-4 units
13: Household, multi-family units (5 or more)
14: Residential condominiums
15: Mobile home parks or courts
For single-family units, rental properties can potentially be identified by comparing the taxpayer's address to
the parcel address—if they differ, it may indicate a rental. However, this method isn’t foolproof, as it could also
capture cases where a tax preparer handles the taxes for the owner.
Using assessor data provides a starting point of parcels that may be rental units. While this data does not offer
100% certainty, it will give us a solid foundation for further analysis. The assessor data includes parcel and
land use information, but landlords will need to provide detailed unit-level data, such as the number of units,
type, rent, etc.
In order to estimate the time duration for this work we interviewed members of the Commerce Clean Buildings
project team. Their project required them to use assessor data from all 39 counties in Washington. The
gathering and processing for their project took approximately 18 months. The team faced delays as they
encountered challenges in identifying unique buildings across parcels. This would not be a challenge for
collecting data for the rental registry project. As such, we anticipate a shorter duration if this work were done in
support of the rental registry. Based on conversations with this team and knowledge of existing systems, we
estimate that this work would take approximately nine months
Data security considerations
When defining a scope of work for a new system, a critical consideration is the type and classification of data
that will be stored. In Washington, data is classified in the Data Classification Standard managed by WaTech.
Proper data classification is crucial to applying the correct cybersecurity and privacy protocols. Category 2 –
Sensitive Information is intended for official use only and is not legally protected from disclosure, though it is
generally not released to the public unless requested. Category 3 – Confidential Information, on the other hand,
is legally protected from both release and disclosure.
WASHINGTON RENTAL REGISTRY STUDY 117
For a rental registry, most data—such as landlord names, addresses, phone numbers, emails and rental
history—will likely fall under Category 2 – Sensitive Information. However, debit/credit card data used to pay
rental registry fees would be classified as Category 3 – Confidential Information, as it requires a higher level of
protection. This payment information will not be stored within Commerce systems but will be managed
through a third-party payment processor.
Commerce staff will have access to the rental registry system, but the specific data view will depend on the
user’s access role, which will be customized within the reporting portal. This role-based access ensures that
staff members can only view data relevant to their responsibilities, providing flexibility and enhanced security.
Commerce will have full access to reporting from the rental registry system, and any disclosed data will be
anonymized or aggregated to ensure privacy. Additionally, all data entered into the system will remain the
property of Commerce.
Integrating data from existing registries
Incorporating data from existing rental registries is a component in defining the scope of work for the Rental
Registry project. At present, no existing registries collect all of the data mandated by the legislative proviso, nor
do they adhere to the proposed timelines for the Statewide Rental Registry. Only Tacoma and Olympia actively
collect monthly rent amounts as part of their rental information. Other cities in Washington primarily focus on
property inspections and housing quality rather than comprehensive rental data collection.
Full integration of data from all existing registries is not feasible due to several challenges:
Data inconsistency: Each city collects different types of data, often focused on specific aspects like
property inspections or housing quality, rather than rental-specific information such as rent amounts.
These data sets are not standardized, making it difficult to merge them into a system without extensive
reformatting and customization.
Diverse system architectures: The technological infrastructure supporting each city's registry system
varies significantly. Developing custom integration solutions for each system would require specialized
work for every city, greatly increasing the complexity, time, and cost of the project.
Varied data collection timelines: Existing registries operate on different timelines for collecting and
updating data, which further complicates integration. For the Statewide Rental Registry to maintain up-to-
date information, constant synchronization would be necessary, and this would be difficult with
registries that are not designed to update data on a common schedule.
Given these challenges, the more feasible and efficient approach is to have existing registries download their
data into a standardized Commerce Excel template and upload it to the rental registry. Commerce will provide
an Excel template for existing registries to submit the data for the Statewide Rental Registry. Staff from these
registries will download their currently collected data and upload it to our system using this template. For data
they do not currently collect, registries can either update their own systems to capture the missing information
and then upload it to ours, or housing providers can manually enter the required details directly into the rental
registry.
This method allows for a practical transfer process and has been incorporated into our cost estimates. Initial
data from these registries will provide a valuable foundation for outreach and the analysis of compliance rates
across the state. This approach will enable the Statewide Rental Registry to identify gaps in data collection and
help inform future enhancements to the system.
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This approach has been successfully used in several existing Commerce applications, proving it to be a
reliable solution. While it facilitates the transfer of essential base information, fully integrating all systems
would require extensive custom development, significant costs, and extended timelines, making it an
impractical solution.
Statewide implementation versus six largest counties
From a technical perspective, the cost to develop a system that supports a rental registry for all counties in the
state versus just the six largest counties is largely the same. Building the portal itself incurs similar expenses
whether it's designed to collect data from one county or all 39 counties. The same data fields will be collected
on the portal screens, the reporting system will display the same types of information, and data storage costs
will increase only marginally as additional counties are included. Moreover, data storage represents a small
portion of the overall ongoing costs of maintaining the system.
The primary differences in cost and time arise from incorporating assessor data from the additional 33
counties and the program support required for a statewide rollout. As more than 70% of rental units are
estimated to be in the six most populous counties, we do not anticipate a large increase in cost for this work.
With more counties included, the system will also need to process a higher volume of payments, which would
add some additional ongoing costs. However, ongoing data maintenance costs will remain marginal.
Process flow of a potential online rental unit registry
Based on the data requirements, our analysis and discussions we developed prototypes of the potential online
rental unit registry. Following are details of the proposed process flow.
Setting up and accessing via SecureAccess Washington
The Landlord will access the rental registry through the existing SecureAccess Washington (SAW) system,
which restricts access to each housing provider’s specific property data. This SAW integration will be
completed in partnership with state IT staff, utilizing a process Commerce has successfully implemented in
previous projects. As a known and reliable process, the SAW integration and its associated costs are already
factored into the project’s cost estimates.
SecureAccess Washington (SAW) is Washington’s method of keeping access and data secure. SAW is used by
Washington residents and businesses to apply for a range of services from state agencies, update and report
information, and complete secure transactions. For the Rental Registry landlords and property managers will
need to create a SAW username and password (if they don’t already have one) to have secure access to the
Rental Registry portal.
The Commerce website will be updated to have a page explaining the Washington State Rental Registry and
will include instructions on signing up for a SAW account, and a link to the SAW Login page. Following are the
steps to set up a SAW account:
1) From the SAW Login page, you will select to go to the Sign Up page if you do not already have an account.
Once you fill in the required information, a confirmation email will be sent to the email address entered.
2) Click on the link in the email to activate the account. You will receive a message on this page that the
Account has been activated.
3) Click on the button to Login. You will be asked to login using the username and password you created.
4) Once logged in, the screen displays ‘Good Morning! What can we help you access today?’ Click on the
button to Add a New Service.
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5) Select to Browse by Agency. You will be presented a list of Agencies. Click on Department of Commerce.
6) The next page will display the list of applications for the Department of Commerce. Find Rental Registry
SAW and click on the Apply button.
7) You will see the Registration Complete page. Click on the OK button.
8) The next page will show the new service on your page. Click Access Now.
9) Your display will show Now Accessing with a message. Click Continue to go to the Rental Registry
Landlord Home Page.
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Figure H1: Setting up SecureAccess Washington (SAW) access
Commerce Website SAW Login page SAW Sign Up Page
for Rental Registry
Confirmation Email Account Activated SAW Login Page
Page
Add a New Service Browse by Agency List of Agencies
SAW Rental Registry Registration Complete Access Now
Apply
Accessing Rental
Registry
WASHINGTON RENTAL REGISTRY STUDY 121
Landlord landing page and property update
Once the landlord has successfully logged in via SecureAccess Washington (SAW), they will be taken to the
Landlord Landing Page. Figure 2 shows the process flow from that point. The Landlord Landing Page will
display any rental property that they have previously added to their account and will allow the landlord to add a
property and add unit details and contact information for a specific property.
Figure H2 - Rental registry landlord process flow
Landlord Landing Add Property Add Property Details
Page
Add Unit Details
Add Property Owner Contact Details
Contacts
Local Contact Details
Additional landlord functions
The following functions will be available to landlords in this system as identified in Figure H3:
Remove a property from their portal: The landlord will be asked why the property is being removed
(associated in error or sold for example) and the date the property was removed.
View past properties: This function displays those properties for the landlord that have been removed.
Request a unit exemption: This function allows the landlord to identify a unit exemption - for example, a
unit is owner-occupied.
Property history: This function displays the activities that have occurred related to a property such as
the date the registration was submitted.
Upload data for multiple units: This function allows a landlord to use a template to upload multiple units’
data rather than keying each unit individually.
Property geo view: This function shows a map view of the property location.
Review, submit and pay: This function allows the landlord to review the information they entered
regarding a property and unit, to submit their registration, and to pay the fees associated with the
property.
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Figure H3: Additional landlord functions
Landlord Home Page Past Properties
Property Detail Remove Property
Upload Data for Property Case History
Multiple Units
Request Unit
Exemption
Review and Submit Pay Now
Upload from existing registry
There are municipalities in Washington that have their own version of a rental registry. Our goal is to be able to
incorporate their data into the statewide rental registry. This custom system will have a template that can be
downloaded by the municipalities. They would update with their data and upload to the statewide rental
registry.
Figure H4: Upload from existing registry
Existing Registry Existing Registry Data
Template Data Upload
Commerce staff exemption review
Commerce staff managing the rental registry will have a function to review and approve unit exemptions.
Housing providers will submit information regarding units they believe should be exempt from fees (for
example, an owner-occupied unit). Commerce will have the ability to approve or reject these exemptions.
Standard security user roles will be used to limit access to the portal and for data security purposes.
Figure H5: Commerce staff exemption review
Staff Exemption Approve Unit
Review Exemption
WASHINGTON RENTAL REGISTRY STUDY 123
Commerce staff report portal
Commerce staff managing the rental registry will have a report portal focused on the rental registry data. The
report portal will have the ability to create pre-defined reports, as well as ad hoc reports selecting which data
fields would display on the report and what selection criteria will be used. This type of report portal has been
successfully developed and implemented for several Commerce systems.
Figure H6: Commerce report portal
Report Selection Report Review
Rental registry internal build cost estimates
This following section describes the estimated costs for implementation and ongoing support of the rental
registry from a technical perspective. Additional detail which incorporates these costs please review the
methodology for producing system cost estimates.
Please note: These ongoing costs have been incorporated into the financial requirements detailed in
Appendix G: Rental registry financial requirements of this report, ensuring a comprehensive understanding of
the financial costs required to support the program.
Rental registry internal design and build
One approach to implementing the Rental Registry portal is to design and develop the portal internally. To
assess the costs involved in this effort, the project team conducted a thorough analysis of the application
requirements, drawing from the specific details provided in the proviso. These requirements are further
detailed in the scope of work section of this report.
As part of the planning process, we developed mockups of the key screens and pages that will be required to
capture and manage data within the portal. These mockups served as a blueprint for understanding the user
interface and user experience design, as well as the technical functionalities that the portal must support, this
is shown in Table H1.
Table H1: Custom system functions and components
Function Components
Housing provider entry and update of property 18 screens
Existing registry data upload One screen/one upload template
Staff review and approval of exemptions Two screens/one notification
Reporting portal One screen for launchpad/10 reports/extracts
Administration and security Eight screens
Using these mockups, and the corresponding analysis, the team developed a comprehensive estimate of the
time and costs required to build the portal internally. This estimate offers a detailed breakdown of the
resources needed to complete each development phase, ensuring that all critical tasks are accounted for.
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The cost estimate for developing the custom system is based on an internal Commerce IT rate of $70 per hour
for development resources. This rate reflects the standard cost used for estimating software development
projects within the organization. As with any project estimate, there is inherent uncertainty regarding the
precise scope and details of all tasks included. To address this, we applied a 20% contingency to account for
potential inaccuracies due to uncertainties in the project definition. This approach aligns with best practices
based on our experience with projects that require further detailed scoping.
The estimate also includes an allowance for integrating assessor data. This figure is informed by discussions
with other programs and their experiences incorporating similar data. Adjustments were made to account for
the reduced complexity of handling assessor data for this specific project.
The methodology for developing the custom system estimate section at the end of this report provides a
breakdown of the estimated hours and associated costs for each task included in Table H2.
Table H2: Estimate for building and deploying an online registry portal
Task Hours Cost
Initial analysis and planning 160 $11,200
Analysis and specification 261 $18,256
Coding and implementation 3,168 $221,760
Portal testing 522 $36,512
Gathering and processing assessor data 1,440 $100,800
Total without contingency 5,550 $388,528
Contingency (20%) 1,110 $77,706
Total with contingency 6,660 $466,234
Commerce registry ongoing technical costs
In addition to the initial implementation costs, there will be ongoing expenses associated with maintaining the
Rental Registry. These ongoing costs fall into two categories: variable costs that change based on the number
of registrations, and fixed costs that remain constant regardless of registration volume. The following tables
outlines the types of costs required to support the Rental Registry portal on an ongoing basis.
Please note: The costs of an internal system and the ongoing operation costs identified in this appendix have
been incorporated into the financial requirements detailed in Appendix G: Rental registry financial
requirements of this report, ensuring a comprehensive understanding of the financial costs required to
support the program.
Table H3 shows costs that remain unaffected by the number of registrations. The estimated cost for
Enterprise Data Storage is $20,000 annually. Technical licensing for system components is estimated at
$1,545 per year, based on the assumption of three developers maintaining the system. The final three lines of
the table reflect technical support costs.
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To accurately estimate ongoing support needs, we consulted with Commerce Information Services, which
provided estimates for the required support based on different skillsets. The following are the estimated
portions of Full-Time Employees (FTE) and the associated costs for each required skill:
Ongoing application support and maintenance:
• 0.3 FTE Developer (Journey level) – $34,000 per year
• 0.2 FTE Business Analyst (Journey level) – $23,000 per year
• 0.2 FTE Data Management Analyst – $23,000 per year
Geographic Information System (GIS) support:
• 0.2 FTE Business Analyst/GIS Specialist (Journey level) – $23,000 per year
System administration (managing servers, users, security, etc.):
• 0.5 FTE System Administrator (Journey level) – $60,000 per year
Table H3: Estimated ongoing costs for operational support not affected by number of
registrations
Type of cost Annual cost
Enterprise data storage $20,000
Technical licensing for components $1,545
Business analysis/Geographic Information System support $23,000
Ongoing system administration support $60,000
Ongoing application support and maintenance $80,000
Total $184,545
Payment processing costs will vary by the number of registrations. Following are estimates based on number
of registrations and the fee charged per unit. There are 2 lines for Payment Processing Transactions. One line
assumes that Commerce will charge $10 per unit, and the other assumes $30 per unit. Both assume a 2.5%
transaction fee, the current rate that Commerce is charged.
Table H4: Estimated ongoing costs for operational support impacted by number of
registrations
Payment Processing 10,000 50,000 100,000 200,000 500,000
Transactions cost assumptions registrations registrations registrations registrations registrations
$10 per unit $2,500 $12,500 $25,000 $50,000 $125,000
$30 per unit $7,500 $37,500 $75,000 $150,000 $375,000
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Rental registry implementation timeline
The rental registry portal costs section of this report outlines the estimated hours required to build and deploy
the online registry portal. With a team of three developers, the projected timeline is nine months. As illustrated
in Figure H7, some development phases can overlap; however, based on our experience with similar projects,
adding more staff would result in diminishing returns and would not significantly accelerate the timeline.
Initial analysis and planning will take place during the first month. Portal analysis and specification
development will be conducted in months 2 and 3. Coding and implementation will span months 3 through 8,
while portal testing will be carried out over three months, beginning in month 7 and continuing through the end
of month 9. Throughout the project timeline, a data analyst will manage the processing of assessor data in
parallel with other activities, which will require the full nine months to complete.
Whether the system is designed for the entire state of Washington or just the six most populous counties, the
overall development timeline remains the same at nine months. While collecting data from fewer counties
would reduce the workload, this task is not the primary factor influencing the project's timeline.
Figure H7: Timeline to build and deploy an online registry portal
Existing software procurement analysis
We employed a two-pronged approach to system evaluation: first, by creating mockups of a potential internal
system based on these requirements and developing detailed cost estimates based on these designs, and
second, by assessing existing rental registry software options for adoption section also discusses the benefits
and challenges of building an internal system, along with the methodology used to evaluate the existing rental
registry software solutions.
Internal registry management versus using existing software provider
When evaluating the best approach for implementing a Rental Registry software portal, it is essential to
consider the benefits and challenges of two main options: building a custom internal system or utilizing an
existing software provider. Each option has its own advantages and potential obstacles, which are outlined
below.
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Developing a custom internal commerce system
Building an internal Rental Registry system offers several compelling benefits that align with program needs
and long-term goals. However, there are also challenges to consider.
Key benefits:
Enhanced customization: Developing the system internally allows for complete control over its design
and functionality. This means the application can be tailored to the Rental Registry program's unique
requirements, regulatory compliance, and data management practices. This is especially important if
regulations and purpose of the rental registry were to change over time.
Greater control over features and updates: With an internally developed system, Commerce has the
flexibility to determine the timing and scope of updates, new features, and enhancements. This
eliminates reliance on an external vendor’s schedule.
Alignment with internal standards: An in-house solution will be built by internal staff who are well versed
in Washington and Commerce policies. This ensures compatibility with existing systems, compliance
with security protocols, and Commerce policies.
Integration with existing systems: Utilizing core framework components from within the agency
facilitates easy integration with other internal systems and databases. This approach streamlines
maintenance efforts and promotes efficient data sharing across common enterprise resources, such as
user authentication, role management, and access to agency data.
Key challenges:
Higher initial development costs: One of the primary challenges of an internal solution is the higher
initial cost of development. This includes expenses related to specialized development, design, testing,
and quality assurance, which can be substantial compared to purchasing an off-the-shelf solution.
Demand for skilled staff: Successfully building and maintaining a custom in-house system requires
access to a team of skilled developers, designers, and IT professionals.
Procuring an existing software solution
Alternatively, leveraging an existing software provider offers a different set of benefits challenges to be
considered.
Key benefits:
Lower initial investment and upfront costs: The external software providers identified often involves a
subscription-based model, which requires a lower initial investment compared to building a custom
system.
Outsourced maintenance and updates: With a vendor-provided solution, the software provider is
responsible for ongoing updates and system maintenance. This reduces the internal IT team's workload.
WASHINGTON RENTAL REGISTRY STUDY 128
Key challenges:
Limited ability to customize: As one of many users on a software platform, there may be limits on
customizing the software to fully align with its specific program. This could impact the effectiveness of
the Rental Registry in meeting all needs.
Dependency on vendor for support and updates: When using an external provider, the organization relies
on them to deliver support and updates promptly. Even though vendors are carefully selected, there is
always a chance they might not meet expectations or might delay essential updates. Such issues could
negatively affect interactions with the public.
Data security: The external vendor needs to update their system to work with Secure Access Washington
(SAW). This means we depend on the vendor to complete this integration correctly and ensure it meets
our security requirements. If there are problems with this process, it could compromise data security and
compliance, and it might also lead to delays in deployment and higher costs.
Higher total cost of ownership over time: While the initial cost of using an external provider may be
lower, the total cost of ownership over time, including recurring subscription fees, customization
expenses, and potential increases in service charges, is generally higher. This can result in a more
expensive solution over time.
External existing software evaluation process
We reviewed numerous existing rental registry software systems and selected four that most closely align with
our identified requirements. The rental registry market is niche, with a limited number of specialized vendors.
Many municipalities have developed their own rental registry systems, and some software solutions are
geared more towards permitting and inspections, which are outside the scope of our current project.
Issuing a formal Request for Information was considered, however these requests often yield responses from
vendors whose solutions not directly relevant to our needs and can skew estimates. We focused on four
vendors whose software closely matches our requirements and reached out to them directly; three of the four
vendors responded to our initial inquiry.
To gain a clearer understanding of their companies and software applications, we provided each vendor with a
comprehensive questionnaire. This questionnaire was designed to gather detailed information on several key
areas, including the vendor's background, experience in developing rental registry systems, and their software's
specific features, functionality, and scalability. We also shared a list of our specific requirements, allowing the
vendors to understand how their software could meet our needs. The questions covered topics such as
system architecture, data security, integration capabilities, support and maintenance plans, and the flexibility
to customize the software for future needs.
Vendors were asked to provide information on their pricing models, licensing terms, and any additional costs
associated with implementation, support, and updates. The questionnaire also sought to understand the
vendors' experience working with other municipalities or government agencies and to assess their ability to
comply with local, state, and federal regulations.
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Existing software cost and timeline estimates
Two vendors provided a full response to our request for information. We made it clear from the outset that the
information provided would not be used to award any contract; instead, it would inform a report for the
Washington State Legislature.
Vendor A estimate
Vendor A provided estimates for the initial implementation of their system based on differing numbers of
registrations. The implementation costs range from $20,000 at a level of 10,000 registrations to $50,000 at a
level of 500,000 registrations. They have two different pricing scenarios for ongoing use of their application.
One is an annual flat rate, and the other is an annual rate per registration. Both of these increase in cost as the
number of registrations increase. See the following table with the details.
Table H5: Vendor A implementation and annual costs
Registrations Implementation Annual flat rate Annual price per registration rate Annual price per registration
10,000 $20,000 $50,000 $6.00 $60,000.00
50,000 $30,000 $75,000 $1.80 $90,000.00
100,000 $50,000 $100,000 $1.20 $120,000.00
200,000 $50,000 $200,000 $1.20 $240,000.00
500,000 $50,000 $250,000 $0.60 $300,000.00
Vendor A listed a number of factors and functionality that may impact the price. The one item that was listed
in our requirements, that is in Vendor A’s list that may impact the price is a process for bulk uploads for large
landlords. We have also identified that users would need to sign on through SecureAccess Washington (SAW).
Timeline: Vendor A has estimated six months for projects similar to ours. As the assessor data work would
need to be done by Commerce, which is estimated to take approximately nine months itself, this project would
take at least the same amount of time as an internal system.
Vendor B estimate
The one-time cost of implementing a rental registry for Vendor B typically ranges from $35,000 to $75,000.
This is not based on number of registrations and includes configuration of their rent registry solution to meet
customer requirements, including branding, reports, notice templates, workflows, intake forms, etc. This also
includes standard integrations (if required). Their estimate assumes that Commerce will provide a base
inventory of property and property owners from property tax data.
Vendor B also has an annual rate based on number of registrations ranging from $36,000 for 10,000
registrations to $325,000 for 500,000 registrations. See the following table for more details.
WASHINGTON RENTAL REGISTRY STUDY 130
Table H6: Vendor B annual costs
Registrations Annual rate
10,000 $36,000
50,000 $60,000
100,000 $85,000
200,000 $150,000
500,000 $325,000
Timeline: Per Vendor B, if we are primarily interested in implementing just the Rent Registry, without additional
features such as eviction tracking, they can complete the implementation within three to six months. As the
assessor data would work would need to be done by Commerce, which is estimated to take approximately
nine months itself, this project would take at least the same amount of time as an internal system.
Comparison of options
The initial implementation costs for a custom-built Commerce Rental Registry system versus using an existing
Rental Registry system vary widely. For a custom-built system, the bulk of the costs are front-loaded. A
Commerce custom system is estimated at $466,234, which includes $100,800 for assessor data processing
and analysis, plus 20% contingency. The Vendor A and Vendor B systems will still require obtaining assessor
data. That has not been included in their cost in the table below, but it is included in the cumulative costs in the
next section. The Vendor A cost ranges from $20,000 to $50,000 depending on how many registrations are
expected. The initial costs for these systems are low – the companies have already built their software and as
long as Commerce uses the software as designed, without changes, the initial implementation will remain low.
Table H7: Implementation costs – Commerce vs vendors
Provider Implementation costs
Commerce $466,234
Vendor A $20,000-50,000*
Vendor B $35,000-75,000
* Dependent on number of registrations
The ongoing costs of a vendor-based system vary depending on the number of registrations. Vendor A offers
either a flat rate or an annual price per registration, while Vendor B operates solely on an annual price per
registration. In contrast, for an internally built system by Commerce, the ongoing cost remains constant,
regardless of the number of registrations. The table below illustrates how annual costs increase rapidly as the
number of registrations grows.
Although the initial cost of a custom-built system is higher than that of vendor systems, the ongoing expenses
become lower as the number of registrations increases. The table outlines the cumulative costs for each
scenario (Commerce vs. vendors), starting with the implementation cost and extending through the first seven
WASHINGTON RENTAL REGISTRY STUDY 131
years. To ensure a fair comparison, $100,800 has been added to the vendor implementation costs to account
for the assessor data processing.
We assumed that registrations would increase over the first five years and then stabilize. Since one vendor’s
estimate caps out at 500,000 registrations, we used that as the maximum number to evaluate break-even
points. Commerce’s ongoing costs are projected to rise by 3% annually, and we assume vendors will follow a
similar pattern starting in year 6, with a 3% annual increase in their costs.
With these assumptions in mind, the custom-built system is expected to break even with Vendor B between
years nine and ten and will remain the cheaper option thereafter. For Vendor A, the custom system is projected
to break even between years seventeen and eighteen.
Table H8: Ongoing costs – commerce vs vendors
Registration Vendor A: annual Vendor A: annual price Vendor A: price per Commerce: annual
Vendor B: annual rate
s flat rate per registration rate registration expenses
10,000 $50,000 $6.00 $60,000 $36,000 $184,545
50,000 $75,000 $1.80 $90,000 $60,000 $184,545
100,000 $100,000 $1.20 $120,000 $85,000 $184,545
200,000 $200,000 $1.20 $240,000 $150,000 $184,545
500,000 $250,000 $0.60 $300,000 $325,000 $184,545
Table H10: Cumulative Costs – commerce vs vendors as registrations increase
Commerce Vendor A Vendor B
Year Commerce Vendor A Vendor B
cumulative cost cumulative cost cumulative cost
Year 0 $466,234.00 $466,234.00 $120,800.00 $150,800.00 $175,800.00 $175,800.00
year 1 -10,000 $184,545.00 $650,779.00 $50,000.00 $170,800.00 $36,000.00 $211,800.00
year 2 -50,000 $190,081.00 $840,860.00 $75,000.00 $245,800.00 $60,000.00 $271,800.00
year 3 -100,000 $195,784.00 $1,036,644.00 $100,000.00 $345,800.00 $85,000.00 $356,800.00
year 4 -200,000 $201,657.00 $1,238,301.00 $200,000.00 $545,800.00 $150,000.00 $506,800.00
year 5 -500,000 $207,707.00 $1,446,008.00 $250,000.00 $795,800.00 $325,000.00 $831,800.00
year 6 -500,000 $213,938.00 $1,659,947.00 $257,500.00 $1,053,300.00 $334,750.00 $1,166,550.00
year 7 -500,000 $220,356.00 $1,880,303.00 $265,225.00 $1,318,525.00 $344,793.00 $1,511,343.00
year 8 -500,000 $226,967.00 $2,107,270.00 $273,182.00 $1,591,707.00 $355,136.00 $1,866,479.00
year 9 -500,000 $233,776.00 $2,341,046.00 $281,377.00 $1,873,084.00 $365,790.00 $2,232,269.00
year 10 -500,000 $240,789.00 $2,581,836.00 $289,819.00 $2,162,902.00 $376,764.00 $2,609,033.00
year 11 -500,000 $248,013.00 $2,829,849.00 $298,513.00 $2,461,416.00 $388,067.00 $2,997,100.00
year 12 -500,000 $255,453.00 $3,085,302.00 $307,468.00 $2,768,884.00 $399,709.00 $3,396,809.00
year 13 -500,000 $263,117.00 $3,348,419.00 $316,693.00 $3,085,577.00 $411,700.00 $3,808,509.00
year 14 -500,000 $271,011.00 $3,619,430.00 $326,193.00 $3,411,770.00 $424,051.00 $4,232,561.00
WASHINGTON RENTAL REGISTRY STUDY 132
Commerce Vendor A Vendor B
Year Commerce Vendor A Vendor B
cumulative cost cumulative cost cumulative cost
year 15 -500,000 $279,141.00 $3,898,571.00 $335,979.00 $3,747,749.00 $436,773.00 $4,669,334.00
year 16 -500,000 $287,515.00 $4,186,086.00 $346,058.00 $4,093,807.00 $449,876.00 $5,119,210.00
year 17 -500,000 $296,141.00 $4,482,226.00 $356,440.00 $4,450,248.00 $463,372.00 $5,582,582.00
year 18 -500,000 $305,025.00 $4,787,251.00 $367,133.00 $4,817,381.00 $477,273.00 $6,059,855.00
year 19 -500,000 $314,176.00 $5,101,426.00 $378,147.00 $5,195,528.00 $491,592.00 $6,551,447.00
Figure H7: Cumulative costs – commerce vs vendors as registrations increase
$7,000,000
$6,000,000
$5,000,000
$4,000,000
$3,000,000
$2,000,000
$1,000,000
$0
Year 0 Year 1 Year 2 Year 3 Year 4 Year 6 Year 7 Year 8 Year 9 Year 10 Year 11 Year 12 Year 13 Year 14 Year 16 Year 17 Year 18 Year 19
Year 5 Year 15
Commerce Vendor A Vendor B
WASHINGTON RENTAL REGISTRY STUDY 133
Methodology for developing detailed custom system estimate
To estimate the costs for a system built internally by Commerce, the project was divided into five major types of hours:
Initial project startup, Analysis and specifications, Coding and implementation, and gathering and processing assessor's
data. Each task for this project was broken down into its subcomponents where necessary, these components and
subcomponents were assigned a complexity factor and an estimated number of hours for completion. These estimates
were based on defined requirements and detailed mockup screens. A 20% contingency was also added to the total
estimate to account for unforeseen challenges, as our experience shows that unexpected issues often arise during
projects. Including this contingency ensures the budget can accommodate any additional work that may be needed.
Table H11: Initial project analysis estimate
Task Component name Hours
Initial project analysis Project planning and startup 160
Total hours 160
Total cost $11,600
Table H12: Estimates for components of portal build by type of hour
Analysis and Coding and Portal
Complexity
Task Group Component name specification implementation testing
factor
hours hours hours
Screen development Property Landlord home page 20 9.2 92 18.4
Past properties 10 5.2 52 10.4
Property detail 10 5.2 52 10.4
Remove property 10 5.2 52 10.4
Add property 10 5.2 52 10.4
Add property details 10 5.2 52 10.4
Add unit details 10 5.2 52 10.4
Case history 10 5.2 52 10.4
Apply for unit
20 9.2 92 18.4
exemption
Contacts 10 5.2 52 10.4
Owner contact
10 5.2 52 10.4
details
Local contact details 10 5.2 52 10.4
Upload multiple units 50 21.2 212 42.4
Unit upload template 20 9.2 92 18.4
WASHINGTON RENTAL REGISTRY STUDY 134
Analysis and Coding and Portal
Complexity
Task Group Component name specification implementation testing
factor
hours hours hours
Geo view 10 5.2 52 10.4
Review and submit 10 5.6 56 11.2
Pay now 10 5.2 52 10.4
Payment data 30 13.2 132 26.4
Upload data from
Existing registry data 100 41.2 412 82.4
existing registry
Existing registry
50 21.2 212 42.4
template
Staff exemption
Staff review/approval 10 5.2 52 10.4
review
Approve unit
10 5.2 52 10.4
exemption
Notify landlord
10 5.2 52 10.4
regarding exemption
Reporting Reporting LaunchPad 20 8.8 88 17.6
Administration Admin - user search 10 5.2 52 10.4
Admin - user details 10 5.2 52 10.4
Admin - security role 10 5.2 52 10.4
Admin - security
role/component 10 5.2 52 10.4
access
Admin - user/role
10 5.2 52 10.4
assignment
SAW authentication 10 4 40 8
SAW/WaTech audit 20 8 80 16
Workflow
15 6 60 12
emails/database mail
Reporting Extracts Extract report 2 1 8
Extract report 2 1 8
Extract report 3 1 8
Extract report 4 1 8
Extract report 5 1 8
Formatted reports Formatted report 1 5 24
WASHINGTON RENTAL REGISTRY STUDY 135
Analysis and Coding and Portal
Complexity
Task Group Component name specification implementation testing
factor
hours hours hours
Formatted report 2 5 24
Formatted report 3 5 24
Formatted report 4 5 24
Formatted report 5 5 24
DataBase SQL server Create SQL Objects 50 200
Data
25 100
auditing/retention
Data warehouse
25 100
provisioning
Total hours 261 1440 522
Task cost $18,256 $100,800 $36,512
Table H11: Estimates for incorporating in assessor data
Complexity Gathering and Processing
Task Group/view Component name
factor assessor data hours
Assessor data Assessor data Build a base for a rental registry using assessor data 50 1440
Total hours 1440
Total cost $100,800
Questionnaire for software vendors:
1) Company name, address, contact name, phone and email address.
2) Provide a brief history of the company including number of years in business and experience in the
industry.
3) What is the name of the Rental Registry software?
4) Approximately how many customer implementations of this Rental Registry software solution has your
company conducted over the past 3 years?
5) How many customers currently use this software?
6) What percentage of current customers are government agencies?
7) Please provide one or more government clients that we could talk to regarding the Rental Registry
8) Functional and Technical Requirements – identify whether each requirement is covered or not by your
software product. Software business features:
a) Capacity to collect information on each rental unit in the state
b) Data to collect:
i) Rental unit details:
(1) Address, Unit, City, State, Zip, Name of complex (if applicable)
(2) Unit size (2 BR, 1 BR, Studio, etc.)
WASHINGTON RENTAL REGISTRY STUDY 136
(3) Owner occupied property?
(4) Type of rental – ADU, Detached ADU, Duplex, Multi-Family 5+ units
(5) Parcel #/Property ID Number
(6) GIS – captured from address, not from data entry
(7) Verify that address is in USPS format
ii) Identity of the property owner:
(1) Owner Name(s)
(2) Physical Address
(3) Mailing Address (if different from Physical Address)
(4) Phone
(5) Business Name (if available)
(6) Type of Ownership (Corp, LLC, Partnership, etc.)
(7) Business license/UBI (not required)
iii) Local Contact/Property Manager info
iv) Monthly rent charged (by unit). Are utilities and all fees included? Identify what is included:
(1) Electricity
(2) Water
(3) Sewer garbage
(4) Parking
v) Vacancy Status – system will be updated any time there is a vacancy
vi) When was unit originally rented by the current tenant and when did the rent last change?
vii) Is this property part of an existing rental registry? If so, which one(s)?
viii) History of changes – particularly rent changes, when a unit goes off market (convert to just owner
occupied, sold into home ownership). Need way to deregister a unit and track what happened.
c) Technical Requirements:
i) Need the ability to collect the fee as part of the portal
ii) Allow upload from existing rental registries
iii) Manager or owner can log in and register. View their own property status. Capture the date last
updated.
9) Technical questions:
a) Is your solution a Software as a Service (SaaS) solution?
b) Is your solution web-based or web-enabled?
c) Is your solution responsive in design? Adaptable to various devices including mobile devices?
d) Does the system allow for single sign-on for internal Commerce users?
e) Describe the technologies/platforms used to build your solution.
f) Which database management systems can your solution be hosted on? Which are preferred?
g) Does your product use/require SQL Server authentication, Windows authentication or both?
h) What kind(s) of database-level customization does your product allow?
i) Does each client have a separate version of the software, or do they all share one version? How is that
managed?
10) Data retention, security, access requirements:
a) At what geographic location is your data physically stored?
b) Do you use multi-factor authentication? And if so, what kind do you use?
c) Washington users would need to sign on through SecureAccess Washington (SAW). Is that feasible
with your product?
d) Do you have a data privacy agreement or policy?
e) Do you follow a specific security standard (Examples: NIST, ISO 27001, FIPS).
WASHINGTON RENTAL REGISTRY STUDY 137
f) System must meet or exceed the Web Accessibility Policy set forth by the WA ST Office of the Chief
Information Officer (OCIO). These standards are consistent with the digital access sections of Web
Content Accessibility Guidelines (WCAG) 2.0 and Section 508.
11) Reporting requirements – Provide reporting functions for Commerce to answer questions regarding rentals
in the state:
a) Does your software have a function for creating ad hoc reports?
12) Additional features:
a) What additional rental registry features are part of your solution?
i) Inspection tracking
ii) Business license tracking
13) Which companies/solutions are your biggest competitors in this market? Why is your product superior?
14) Pricing and cost structure:
15) What is your pricing model for the rental registry?
16) What are your standard fees and costs associated with implementation, training and ongoing support?
17) Implementation and support:
a) What is your implementation timeline for projects similar to ours?
b) What kind of training and support do you provide during and after implementation?
c) What is your customer support process for resolving issues and addressing concerns?
d) What is your SLA (Service Level Agreement) for response times and resolution of critical issues?
WASHINGTON RENTAL REGISTRY STUDY 138
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