Lender PML/SEL vs City Compliance
No. Freddie Mac Chapter 64 states that Scenario Expected Loss-475 (SEL-475) is used instead of the older term Probable Maximum Loss (PML) for Seismic Risk Assessment. City compliance under Ordinance 183893 still needs Department County Recorder certificate acts and engineer statements on approved plans — a lender PML/SEL does not equal the city package.
Last updated: September 7, 2026
Why are they separate requirements?
The lender PML/SEL answers the mortgage underwriting question: Freddie Mac Chapter 64 lists Seismic Risk Assessment Requirements and that Scenario Expected Loss-475 (SEL-475) is used instead of the older term Probable Maximum Loss (PML), citing ASTM Standard Guide E2026-16a and Form 1102 for the underwriting package. The city package answers the ordinance question under Ordinance 183893: Department County Recorder certificate acts and engineer statements on approved plans. Different recipients, different purposes, different standards.
| Document type | Recipient | Purpose | Satisfies LADBS city compliance? |
|---|---|---|---|
| Lender PML/SEL (SEL-475; older term PML) | Lender or servicer | Freddie Mac Seismic Risk Assessment for the underwriting package (Chapter 64; ASTM E2026-16a title) | No |
| County Recorder certificate (§91.9306.6) | LADBS / County Recorder | At order service: Department files scope/order certificate with County Recorder; may later file certificate terminating recorded status (§91.9306.6) per Ordinance 183893 | Published ordinance text (Department act) |
| Statement on approved plans (§91.9310.2) | LADBS via design professional | Engineer’s or Architect’s Statement on the approved plans (design-time text, not an Order-dismiss act) (§91.9310.2) | Published ordinance text (design-time) |
What does the city require?
Per Ordinance 183893, §91.9306.6 states that at the time the Department serves the order, the Department shall file with the Office of the County Recorder a certificate stating that the subject building has been determined to be within the scope of this division. The same section states that the Department shall file a certificate terminating the above recorded status if the building is thereafter demolished, found not to be within the scope, or is determined to be structurally capable of resisting minimum seismic forces as a result of structural alterations or analysis. §91.9310.2 states that the responsible engineer or architect shall provide statements on the approved plans — design-time plan text, not an Order-dismiss act. §91.9305.1 states that a civil or structural engineer or architect licensed by the state of California prepares the structural analysis. The lender's PML/SEL is not part of this process.
| Document | Preparer | Listed in ordinance? |
|---|---|---|
| County Recorder certificate (§91.9306.6) | Department | Yes |
| Statement on approved plans (§91.9310.2) | Design professional (California civil or structural engineer or architect per §91.9305.1) | Yes |
| Lender PML/SEL (Seismic Risk Assessment) | Lender's engineer (Freddie Mac underwriting package) | No |
LADBS Soft-Story Compliance Timelines
Per the DBS Soft-Story Retrofit Program, the property owner must comply with the ordinance within the following time limit from the receipt of the Order to Comply:
| Deadline | Requirement |
|---|---|
| 2 years | Submit proof of previous retrofit, or plans to retrofit or demolish |
| 3.5 years | Obtain permit to start construction or demolition |
| 7 years | Complete construction |
Source: DBS Soft-Story Retrofit Program (Ordinance 183893 / Ordinance 184081). Soft Story Retrofit Program Status as of February 1, 2024 lists 12,347 soft story buildings and OBTAINED CERTIFICATES OF COMPLIANCE.
Frequently asked questions
Lender PML/SEL vs City Compliance?
No. Freddie Mac Multifamily Seller/Servicer Guide Chapter 64 states that Scenario Expected Loss-475 (SEL-475) is used instead of the older term Probable Maximum Loss (PML) for Seismic Risk Assessment — not LADBS city compliance. Ordinance 183893 §91.9306.6 lists Department County Recorder certificate acts; §91.9310.2 lists engineer/architect statements on the approved plans. A lender PML/SEL does not equal the city package.
Can the same engineer prepare both the PML/SEL and city compliance documentation?
Yes, if separately engaged. Per Ordinance 183893 §91.9305.1, a civil or structural engineer or architect licensed by the state of California prepares the structural analysis for the city path. The same California-licensed professional may also prepare a lender Seismic Risk Assessment (SEL-475 / older PML term) for the Freddie Mac underwriting package when separately engaged — distinct scope, recipients, and requirements.
Why are the lender PML/SEL and the city package separate requirements?
Freddie Mac Chapter 64 lists Seismic Risk Assessment Requirements and that SEL-475 is used instead of the older term PML. That SRA sits in the Seller/Servicer underwriting package. The city package answers the ordinance question under Ordinance 183893: Department County Recorder certificate acts (§91.9306.6) and engineer statements on approved plans (§91.9310.2). Different recipients, different purposes.
What does the city require under Ordinance 183893?
Per Ordinance 183893, §91.9306.6 states that at the time the Department serves the order, the Department shall file with the Office of the County Recorder a certificate stating that the subject building has been determined to be within the scope of this division. The same section states that the Department shall file a certificate terminating the above recorded status if the building is thereafter demolished, found not to be within the scope, or is determined to be structurally capable of resisting minimum seismic forces as a result of structural alterations or analysis. §91.9310.2 states that the responsible engineer or architect shall provide statements on the approved plans — design-time plan text, not an Order-dismiss act. §91.9305.1 states that a civil or structural engineer or architect licensed by the state of California prepares the structural analysis. The lender's PML/SEL is not part of this process.
What deadline ladder does the DBS Soft-Story Retrofit Program list after an Order to Comply?
The DBS Soft-Story Retrofit Program states that each property owner will be sent an order to comply, then: 2 years — submit proof of previous retrofit, or plans to retrofit or demolish; 3.5 years — obtain permit to start construction or demolition; 7 years — complete construction. Ordinance 184081 amends service-of-order windows. A lender PML/SEL does not substitute for that ladder.
Related
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