The Los Angeles Housing Department (LAHD) is coming down hard on owners of buildings that lack clear documentation regarding the legal building use. This is a serious problem for the owners of apartment buildings constructed prior to 1923, because in those days the Los Angeles Department of Building and Safety (LADBS) was not required to issue a certificate of occupancy. The certificate of occupancy or “C of O” is the governing document used by stakeholders to substantiate the legal use of a building. I have recently been resolving issues relating to missing or inaccurate C of O’s with the LADBS. One of these projects is a historic 8 unit apartment building located just north of the University of Southern California. The building was constructed in the early 1900’s and as such a great deal of important documentation was missing or unavailable, and the documentation that was available often contained conflicting or inaccurate information. The owner’s problem began when the LAHD issued an “order to comply” demanding the removal of 3 units. After inspecting the building and researching the permit history I was able to put together a package for the Los Angeles Department of Building and Safety that ultimately led to a determination by the LADBS that the correct unit count was 8 units. This meant that the owner could keep all their units.