IS UN BUNDLING OF HOUSING SERVICES FROM RENT AMOUNTS PAID legally allowed in the city of Los Angeles in RSO properties built before 1978? The answer appears to be “no”.
Part I of II
The word unbundling means that rather than have the landlord pay for all utilities, the landlord separates them from the rent paid and may charge the tenant for each utility separately. Housing services can be parking, electric, gas, sewer, trash, water, etc. Another way of saying this is that the rent paid includes all utilities. My conclusion is based on talking with landlords as well as tenants as well as lawyers. I have also done some research online as well as read some of the laws involved. I am not a lawyer, nor is this legal advice. As is typical with anything, some landlords are doing things just because there’s no one to stop them from doing it or question it, even if it might be unlawful. In addition, I have talked with a few people with excellent arguments, but those arguments seem to be more based on opinion than on any actual law. I thought it was important to look at what housing services were bundled with the previous tenant, but I found that was not answering all my questions. But I was able to find laws that seem to apply to both the old tenant as well as a new tenant. I provide you with the local city laws that I base my opinion on, and you can come to your own conclusion. If you are a new tenant applicant trying to move into an older building, and if you have questions as to the unbundling of utilities, I would simply ask the landlord what law their actions are based on. Hope this helps a lot of tenants. Good luck. LAMC 151.02 Rent. “The consideration, including any bonus, benefits or gratuity, demanded or received by a landlord for or in connection with the use or occupancy of residential real property, including, but not limited to, monies demanded or paid for the following: meals when required by the landlord as a condition of the tenancy; parking; furnishings; other housing services of any kind; subletting; or security deposits.” LAMC 151.02. Housing Services. “Services connected with the use or occupancy of a rental unit including, but not limited to, utilities (including light, heat, water and telephone), ordinary repairs or replacement, and maintenance, including painting. This term shall also include the provision of elevator service, laundry facilities and privileges, common recreational facilities, janitor service, resident manager, refuse removal, furnishings, food service, parking and any other benefits, privileges or facilities.” (Amended by Ord. No. 154,808, Eff. 2/13/81.) From Google AI: “Yes, utilities are considered a core component of housing services. Agencies like the U.S. Department of Housing and Urban Development (HUD) and the Internal Revenue Service (IRS) classify basic services—such as electricity, water, gas, and trash collection—as fundamental housing expenses required to make a dwelling livable.” “In the Los Angeles Municipal Code (LAMC), rent is broadly defined as any consideration—including bonuses, benefits, gratuity, or received services—demanded or received by a landlord for the use or occupancy of a residential rental unit. This includes parking, furnishings, and all associated housing services.” “Under the Rent Stabilization Ordinance (LAMC Chapter XV), rent is more extensively defined to include not just the base monthly housing payment, but all connected privileges and services. Key components of this legal definition include:
Included Services: Rent covers all “housing services, privileges, furnishings and facilities” supplied by the landlord, such as garage and parking facilities.
Value Received: The definition is not limited to cash payments; it includes any “bonus, benefit, or gratuity” demanded or received from the tenant in connection with the unit. Covered Properties: This definition applies to all rental units, ranging from standard apartments and condominiums to mobile homes and rooms occupied for 30 or more consecutive days. Value Received: The definition is not limited to cash payments; it includes any “bonus, benefit, or gratuity” demanded or received from the tenant in connection with the unit. “
So I would conclude, absent separate meters for utilities (that might be another law governing that), that such services as gas, electric, water, trash, sewer, and parking have to be bundled into the rent amount agreed to. No separate charges outside of the rent agreement amount are allowed. This has been a discussion of statutory law, but it may be valuable to research case law on these issues.
Part II OF II
For related examples, to show the city’s inconsistencies, arbitrary, and discriminatory enforcement of, or lack thereof, of city policies. First, a few years back, the city passed the landlord-tenant anti-harassment law. A few years later, a newspaper report showed that the city government had received over 10,000 complaints of harassment. The investigation showed that only a handful of those complaints were referred to the city attorney’s office or the police department. IMO this proves that the city had no intention of enforcing that law. Second, in 2022, the city government passed a building code requiring that, for those Wi-Fi-based door entry intercom systems installed, the building owner has to have an interface (or monitor) in each unit. Such a system was installed in my building in 2023. I have made monthly code enforcement and building department complaints on this, and now, four years later, none of the 18 units here have an interface in their unit. (accessibility requirement under building code “11B-708.4.2 Residential dwelling unit interface. The residential dwelling unit system interface shall include a telephone jack capable of supporting voice and TTY communication with the common use or public use system interface.” ) “City code enforcement has refused to cite the owner of this property; such constitutes disability discrimination against myself by city government employees.” 11/11/2025 08:41 PM. Council File No: 25-0160-S93.
Regarding RUBS. City Housing documents state December 2025: “This report presents key policy recommendations for a proposed third-party billing ordinance designed to regulate RUBS practices citywide.” The word “proposed” IMO means there is no current law mandating RUBS. Further, Hall claims, “Approximately 19% of rental units subject to the City’s RSO are master-metered. For these properties, landlords have several options:● Include utilities in their rent as part of the monthly rental.● Charge a separate utility fee to tenants.● Utilize a third-party billing company, such as a Ratio Utility Billing System (RUBS), to allocate costs for master-metered or other unmetered utility services.” IMO, it is important that Hall uses the word “options”; she does not say mandated and she does not say “by law”. Hall says, “Landlords may utilize third-party billing companies to separately bill each rental unit for any utility service.” IMO, Hall uses the word “may”, not “must”. IMO, tenants are not required to comply with RUBS. Hall claims state law “does not define whether utilities are considered part of rent, thereby allowing for the use of RUBS.” But she ignored the portion of LAMC that defines the utilities as part of the rent. Based on an eleven-page letter from LAHD General Manager Tiena Johnson Hall. 2025-12-29 . See Los Angeles City Council file no. 22-0178, publicly accessible.
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LA Rent Control (RAC) and Permits (LADBS) 