PML/SEL Report Close City Order?
No — a PML/SEL report does not close a city Order to Comply. 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). City close under Ordinance 183893 still needs Department County Recorder certificate acts and engineer statements on approved plans.
Last updated: September 7, 2026
What is the difference?
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 | Purpose | Recipient | Closes Order? |
|---|---|---|---|
| PML/SEL (SEL-475; older term PML) | Freddie Mac Seismic Risk Assessment for the underwriting package (Chapter 64; ASTM E2026-16a title) | Lender or servicer | No |
| County Recorder certificate (§91.9306.6) | At order service: Department files scope/order certificate with County Recorder; may later file certificate terminating recorded status (§91.9306.6) per Ordinance 183893 | LADBS / County Recorder | Published ordinance text (Department act) |
| Statement on approved plans (§91.9310.2) | Engineer’s or Architect’s Statement on the approved plans (design-time text, not an Order-dismiss act) (§91.9310.2) | LADBS | Published ordinance text (design-time) |
What closes the Order?
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 PML/SEL is not submitted to LADBS and does not satisfy these city requirements.
| Requirement | Document | Submitted to LADBS? |
|---|---|---|
| County Recorder certificate (§91.9306.6) | At order service: Department files scope/order certificate with County Recorder; may later file certificate terminating recorded status (§91.9306.6) | Yes (Department act) |
| Statement on approved plans (§91.9310.2) | Engineer’s or Architect’s Statement on the approved plans (design-time text, not an Order-dismiss act) (§91.9310.2) | Yes (via design professional) |
| Lender Seismic Risk Assessment (SEL-475 / older PML) | Freddie Mac underwriting package (Chapter 64) | 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
PML/SEL Report Close City Order?
No. A PML/SEL report does not close a city Order to Comply. 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 Order dismissal. 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 close the city Order.
Why doesn't LADBS accept the PML/SEL?
PML/SEL answers the mortgage underwriting question. Freddie Mac Chapter 64 lists Seismic Risk Assessment Requirements and that SEL-475 is used instead of the older term PML for the underwriting package. The Soft-Story Retrofit Program Order to Comply path under Ordinance 183893 is separate: §91.9306.6 lists County Recorder recordation at order service and a later certificate terminating the recorded status after demolition, not-in-scope finding, or structural alterations or analysis. §91.9310.2 lists engineer/architect statements on the approved plans (design-time text, not an Order-dismiss act). §91.9305.1 lists civil or structural engineer or architect.
What is the difference between a PML/SEL and the city Order?
PML/SEL is a Freddie Mac Seismic Risk Assessment (SEL-475; older term PML) for the Seller/Servicer underwriting package per Chapter 64 and ASTM Standard Guide E2026-16a. The city Order to Comply under the Soft-Story Retrofit Program requires ordinance compliance documentation under Ordinance 183893 — Department County Recorder certificate acts and engineer statements on approved plans. Separate requirements, different recipients, different standards.
What does Ordinance 183893 say about what closes the Order?
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 PML/SEL is not submitted to LADBS and does not satisfy these city requirements.
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 PML/SEL report does not substitute for that ladder or close the Order.
Related
- Does a lender PML close an LADBS soft-story Order, or does the owner still buy a separate ordinance engineering package?
- Does PML Close LADBS Soft-Story Order?
- Lender PML/SEL vs City Compliance
- LADBS Soft-Story Order Close Process
- Retrofit Order Dismissal Documentation
- PML/SEL Structural Engineer Licensing