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HomeMy WebLinkAbout5.4 Introduction of an Ordinance Amending Chapter 4.04 (Business Registration) of the Dublin Municipal Code STAFF REPORT CITY COUNCIL Page 1 of 3 Agenda Item 5.4 DATE: June 17, 2025 TO: Honorable Mayor and City Councilmembers FROM: Colleen Tribby, City Manager SUBJECT: Introduction of an Ordinance Amending Chapter 4.04 (Business Registration) of the Dublin Municipal Code Prepared by: Felicia Escover, Economic Development Manager EXECUTIVE SUMMARY: The City Council will consider introducing an Ordinance amending Dublin Municipal Code Chapter 4.04, which governs the City’s business registration program. These updates are intended to improve clarity, enhance operational efficiency, and support a better customer experience for businesses. The changes are informed by best practices and a policy review conducted by Hinderliter de Llamas & Associates (HdL), as well as Staff’s experience administering the program. STAFF RECOMMENDATION: Waive the reading and introduce an Ordinance Amending Section 4.04 of the Dublin Municipal Code, Related to Business Registration. FINANCIAL IMPACT: None. DESCRIPTION: Background The City of Dublin requires all businesses operating within its jurisdiction to register in accordance with Chapter 4.04 of the Dublin Municipal Code. The Business Registration Program is administered by the Economic Development Division and includes registration for both Dublin-based businesses and businesses located outside the City that conduct operations within City limits. Registration types include commercial businesses, home occupations, massage establishments, and out-of-city businesses. On February 18, 2025, the City Council approved a Contractor Services Agreement with Hinderliter de Llamas & Associates (HdL) for business license software and administration 90 Page 2 of 3 services. HdL’s platform offers a streamlined, user-friendly interface for registration, renewal, closure, and payment functions, and includes compliance, audit, and discovery tools. Concurrent with the implementation of the new business license software, Staff undertook a comprehensive review of the City’s business registration ordinance to identify opportunities for process improvements and code clarifications. The intent was to ensure that operational changes were supported by a modern, efficient, and enforceable policy framework. This review aligns with Goal 6 of the City Council’s adopted E conomic Development Strategy (October 1, 2024): “Strengthen startup and growth opportunities for small businesses by pursuing improvements to City processes and maintaining and marketing supportive services and programs.” Business Registration Ordinance Review Staff began by comparing Dublin’s ordinance with those of other Tri-Valley jurisdictions. Although each city's program structure varies, it became clear that there were opportunities to simplify and modernize Dublin’s approach. To support this effort, the City engaged HdL to conduct a formal review of Chapter 4.04 and provide an external perspective informed by industry best practices and their experience administering business license programs for more than 100 municipalities. Based on frequent questions f rom businesses and observations from administering the program, Staff identified four key areas for evaluation:  Renewal Cycle  Proration of Fees  Delinquency and Penalties  Exemptions HdL’s Ordinance Review Brief (Attachment 4) included a comparative analysis and specific recommendations for code improvements. Proposed Changes Staff recommends adopting the changes proposed by HdL, which include:  Transition to an Anniversary-Based Renewal Cycle: Replace the fixed October 1 renewal date with a system where businesses renew one year from their initial registration date. This will distribute workload evenly throughout the year and improve the customer experience.  Maintain Full Annual Fees Without Proration: Continue collecting full registration fees regardless of the start date, as the cost of administration remains constant throughout the year.  Adopt a Flat Penalty Structure: Replace the existing compounded 7% monthly penalty with a flat percentage (25%) applied monthly, capped at 100% of the original fee. This simplifies calculations and is easier for businesses to understand.  Clarify and Streamline Exemption Categories: Limit exemptions to those required under state or federal law while encouraging voluntary registration to support business data collection. 91 Page 3 of 3 In addition to HdL’s recommendations, Staff is proposing further revisions based on common challenges experienced during program administration, including:  Clarified Definitions and Enforcement Language: Updates to reflect modern business practices, such as digital advertising, and expanded enforcement authority.  Revocation Criteria and Amendment Process: Clear guidance for when a license may be revoked and a requirement that businesses notify the City of certain changes within seven days. These changes aim to improve clarity, ensure consistent application, and support a more business-friendly and enforceable program. Next Steps If the proposed ordinance is introduced and subsequently adopted, Staff will work with HdL to incorporate the new requirements into the software system, revise internal procedures, and conduct outreach to notify impacted businesses of the changes. Updated forms, website content, and business license materials will be develope d to inform businesses and ensure a smooth transition. STRATEGIC PLAN INITIATIVE: Strategy 1: Economic Development, Small Business Support, and Downtown Dublin Objective A: Support the implementation of the 2024 Economic Development Strategy, including pursuing growth industries. NOTICING REQUIREMENTS/PUBLIC OUTREACH: The City Council Agenda was posted. ATTACHMENTS: 1) Ordinance Amending Section 4.04 of the Dublin Municipal Code, Related to Business Registration 2) Exhibit A to the Ordinance – Amendments to Section 4.04 of the Dublin Municipal Code, Related to Business Registration 3) Amendments to Section 4.04 of the Dublin Municipal Code, Related to Business Registration – Redline Version 4) Ordinance Review Brief 92 Attachment 1 Ord. No. XX-25, Item X.X, Adopted XX/XX/2025 Page 1 of 2 ORDINANCE NO. XX – 25 AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF DUBLIN AMENDING SECTION 4.04 OF THE DUBLIN MUNICIPAL CODE, RELATED TO BUSINESS REGISTRATION WHEREAS, the City of Dublin requires all businesses operating within its jurisdiction to register in accordance with Chapter 4.04 of the Dublin Municipal Code; and WHEREAS, the City administers its Business Registration Program through the Office of Economic Development, including registrations for commercial businesses, home occupation s, massage establishments, and out-of-city businesses operating within Dublin; and WHEREAS, on February 18, 2025, the City Council approved a Contractor Services Agreement with Hinderliter de Llamas & Associates (HdL ) for business license software and administration services to replace the Energov Permitting and Licensing (EP&L) system, which had presented administrative and user experience challenges; and WHEREAS, City staff and HdL conducted a comprehensive review of Dublin Municipal Code Chapter 4.04 to identify policy updates and process improvements that align with the City's new software system, modernize operations, and enhance service delivery; and WHEREAS, the recommended amendments improve clarity, increase operational efficiency, and align the business registration program with best practices used in other jurisdictions; and WHEREAS, the proposed amendments are consistent with Goal 6 of the City Council - adopted Economic Development Strategy to strengthen startup and growth opportunities for small businesses by pursuing improvements to City processes. NOW, THEREFORE, the City Council of the City of Dublin does ordain as follows: Section 1. Chapter 4.04 of the Dublin Municipal Code is hereby amended to revise the City’s Business Registration requirements as shown in Exhibit A. Section 2. Effective Date. This Ordinance shall take effect and be enforced 30 days following its final adoption. Section 3. Posting. The City Clerk of the City of Dublin shall cause this Ordinance to be posted in at least three public places in the City of Dublin in accordance with Section 36933 of the Government Code of the State of California. {Signatures on the following page} 93 Ord. No. XX-25, Item X.X, Adopted XX/XX/2025 Page 2 of 2 PASSED, APPROVED AND ADOPTED this __th day of _______ 2025, by the following vote: AYES: NOES: ABSENT: ABSTAIN: ______________________________ Mayor ATTEST: _________________________________ City Clerk 94 Dublin Municipal Code Chapter 4.04 BUSINESS REGISTRATION Page 1/6 The Dublin Municipal Code is current through Ordinance 1-25, passed February 4, 2025. Chapter 4.04 BUSINESS REGISTRATION Sections: 4.04.010 Purpose—Authority. 4.04.020 Definitions. 4.04.030 Registration fees—Limitations on effect of license. 4.04.040 Provisions not exclusive. 4.04.050 Business registration fee required—Exceptions. 4.04.060 Exemptions—Generally. 4.04.190 Evidence of doing business. 4.04.200 Branch establishments—Separate licenses. 4.04.205 Master license—Festival organizers. 4.04.210 License—Contents—Issuance conditions. 4.04.220 Application—First license. 4.04.225 Application—Amendments. 4.04.230 Application—Renewal license. 4.04.240 Payment—Time and method. 4.04.250 Business registration fee. 4.04.270 Denial and Revocation of license—Grounds. 4.04.280 Transferability—Change of ownership or location. 4.04.300 Posting and display of licenses. 4.04.310 Collector’s powers—Filing deadline. 4.04.320 Business registration fee—Penalty. 4.04.330 Doing business without license does not waive requirements. 4.04.340 Enforcement authority—Inspection of premises. 4.04.350 Appeal procedure. 4.04.360 Violations—Infraction. 4.04.370 Violation—Remedies cumulative. 4.04.380 First license required by October 1, 199 0. 4.04.010 Purpose—Authority. This chapter is enacted to register businesses, trades, occupations and professions in the city of Dublin solely for the purpose of regulation and is enacted pursuant to Business and Professions Code Sections 460 and 16000 an d California Constitution Article XI, Section 7. (Ord. 10-90 § 1) 4.04.020 Definitions. For the purposes of this chapter, the following definitions shall apply: “Business” means and includes professions, trades and occupations, and all and every kind of ca lling, whether or not carried on for profit. “City” means the city of Dublin, a municipal corporation of the state of California. “Collector” means the Finance Director or any other person the City Manager may designate to administer the business registration program. “Engaging in business” means commencing, conducting or continuing in business, and also the exercise of corporate or franchise powers, as well as liquidating a business when the liquidators thereof hold themselves out to the public as conducting such business. “Person” and “persons” means and includes all domestic and foreign corporations, associations, syndicates, joint stock corporations, partnerships of every kind, clubs, trusts, societies and individuals acting and carrying on any business in the city, other than as an employee. “Person” and “persons” shall also include the operator of a festival, fair, farmers’ market or similar event for which one person (the “organizer”) obtains required permits and licenses Attachment 2 Exhibit A to the Ordinance 95 Dublin Municipal Code Chapter 4.04 BUSINESS REGISTRATION Page 2/6 The Dublin Municipal Code is current through Ordinance 1-25, passed February 4, 2025. and which includes other persons who sell or offer to sell goods and/or food at the event (“purveyors”) through contract with the organizer or otherwise. (Ord. 11 -20 § 2: Ord. 10-98 § 1; Ord. 10-90 § 2) 4.04.030 Registration fees—Limitations on effect of license. The terms “license” and “registration,” as used herein, shall not be construed to mean a permit. The fees prescribed by Section 4.04.210 of this chapter do not constitute a tax for revenue purposes, but are regulatory fees. The payment of a business registration fee required by this chapter and its acceptance by the city, and the issuance of such license to any person, shall not entitle the holder thereof to carry on any business unless he or she has complied with all of the requirements of this chapter and all other applicable laws, nor to carry on any business in any building or any premises designated in such license in the event that such building or premises are situated in a zone or locality in which the conduct of such business is in violation of any law. (Ord. 10 -90 § 3) 4.04.040 Provisions not exclusive. Persons required to pay a business registration fee for transacting and carrying on any business under this chapter shall not be relieved from the payment of any license fee or permit for the privilege of doing such business required under any other ordinance of the city, and shall remain subject to the regulatory provisions of other ordinances. (Ord. 10-90 § 4) 4.04.050 Business registration fee required—Exceptions. A. There are imposed upon the businesses, trades, professions, calling and occupations specified in this chapter business registration fees in the amounts set forth in Section 4.04.250. It is unlawful for any person to transact, carry on and/or engage in any business, trade, profession, calling or occupation in the city without first having procured a license from the city to do so and paying the prescribed business registration fee, and without complying with any and all applicable provisions of this chapter. B. This section shall not be construed to require any person to obtain a license prior to doing business within the city if such requirement conflicts with applicable statutes of the United States or of the state of California. Persons not so required to obtain a license prior to doing business within the city nevertheless are encouraged to comply with the reporting requirements of this chapter as set forth in Section 4.04.220. (Ord. 10 -90 § 5) 4.04.060 Exemptions—Generally. A. Any person claiming an exemption shall submit to the Collector, upon a form provided by the Collector, a request for such exemption and statement of the facts upon which exemption is claimed, and in the absence of such request and statement substantiating the claim, such person shall be liable for the payment of the fees imposed by this chapter. (Ord. 11-20 § 3: Ord. 10-90 § 6) B. Any business that is exempt from business license fees or local regulatory licensing under federal or state law shall be exempt from local business registration fees that would otherwise apply under this program. 4.04.190 Evidence of doing business. When any person makes use of signs, circulars, cards, telephone books or newspapers, websites, social media platforms, and advertises, holds out or represents that he or she is in busi ness in the city, or when any person holds an active license or permit issued by a governmental agency indicating that he or she is in business in the city, and such person fails to deny by an affidavit sworn to before a person authorized to take oaths or a declaration or certificate under penalty of perjury given to the Collector that he or she is conducting a business in the city, after being requested to do so by the Collector, then these facts shall be considered prima facie evidence that he or she is conducting a business in the city. (Ord. 11-20 § 4: Ord. 10-90 § 19) 4.04.200 Branch establishments—Separate licenses. A separate license must be obtained for each branch establishment or location of the business transacted and carried on, and for each separate type of business at the same location, and each license shall authorize the licensee to transact and carry on only the business licensed thereby at the location or in the manner designated in such license; provided, that warehouses and distributing plants used in connection with and incidental to a business licensed under the provisions of this chapter shall not be deemed to be separate places of business or branch establishments, and provided further that only one (1) license is required for the rental or lease of real property within the city regardless of the number of locations or units of real property being rented or leased. (Ord. 12 -91 § 2) 96 Dublin Municipal Code Chapter 4.04 BUSINESS REGISTRATION Page 3/6 The Dublin Municipal Code is current through Ordinance 1-25, passed February 4, 2025. 4.04.205 Master license—Festival organizers. The organizer of a festival, fair, farmers’ market or similar event shall obtain a master license for himself and all purveyors of goods and/or food who will participate in the event. No individual purveyors shall be required to obtain a separate license. (Ord. 10-98 § 2) 4.04.210 License—Contents—Issuance conditions. Every person required to have a license under the provisions of this chapter shall make application as hereinafter prescribed for the same to the Collector, and upon the payment of the prescribed business registration fee, the Collector shall issue to such person a license, which shall contain the following information: A. The name of the person to whom the license is issued; B. The name of the business licensed; C. The place where such business is to be transacted and carried on; D. The date of the expiration of such license; and E. Such other information as may be necessary for the enforcement of the provisions of this chapter. (Ord. 10 -90 § 21) 4.04.220 Application—First license. A. Upon a person making application for the first license to be issued under this chapter, or for a newly established business, such person shall furnish to the Collector, upon a form provided by the Collector, the following information: 1. The exact nature or kind of business for which a license is re quested; 2. The place where such business is to be carried on, along with all required documentation confirming approval to operate at that site, and if the business is not to be conducted at a permanent place of business, the residential addresses of the business owners shall also be provided; 3. In the event that application is made for issuance of a license to a person doing business under a fictitious name, the application shall set forth the names and places of business of those owning the business; 4. In the event that the application is made for the issuance of a license to a corporation or a partnership, the application shall set forth the names and places of business of the officers or partners thereof; 5. For established and operating businesses: the daily average number of employees employed in furtherance of the business being licensed during the ninety (90) day period preceding the date of application. For new businesses: the daily average number of employees anticipated to be employed to conduct the business during the ninety (90) day period following the date of the application; 6. In the event the application is made for issuance of a master license to a festival organizer, the application shall set forth the names and addresses of all purveyors, and the goods and/or food to be purveyed; 7. Any further information which the Collector may require to enable him or her to issue the license. B. The Collector shall not issue to any such person another l icense for the same or any other business until such person has furnished to him or her the information required by subsection A of this section and paid the business registration fee as herein required. (Ord. 11-20 § 5: Ord. 10-98 § 3; Ord. 10-90 § 22) 97 Dublin Municipal Code Chapter 4.04 BUSINESS REGISTRATION Page 4/6 The Dublin Municipal Code is current through Ordinance 1-25, passed February 4, 2025. 4.04.225 Application—Amendments. A. If any information provided in the application filed with the city changes, or if the business ceases operations, the applicant shall report these changes to the city within seven days of such changes or cessation.. B. Amendments shall not be used to change the business location or ownership. Any such changes must follow the procedures outlined in Section 4.04.280. 4.04.230 Application—Renewal license. A. The applicant for the renewal of a license shall submit to the Collector, on or before the expiration date of the license, the applicable renewal fee and, on a form provided by the Collector, the information described in Section 4.04.220. (Ord. 11-20 § 6: Ord. 10-90 § 23) B. All licenses shall be valid through the last day of the month preceding the one -year anniversary of the date of issuance, unless revoked, suspended, or otherwise subject to a different expiration period under the terms of the individual license. 4.04.240 Payment—Time and method. Unless otherwise specifically provided, all annual business registration fees under the provisions of this chapter shall be due and payable in advance on the first day of October of each year. (Ord. 10 -90 § 24) 4.04.250 Business registration fee. The business registration fees, which are found to be commensurate with the cost of issuance of the license, shall be as fixed by the City Council by resolution. (Ord. 2-18 § 1(A): Ord. 10-98 § 4: Ord. 10-90 § 25) 4.04.270 Denial and Revocation of license—Grounds. A business license may be denied or revoked by the Collector for any of the following causes: A. The application is incomplete, not submitted on the required form, or contains materially false information; B. The applicant or licensee has failed to comply with the requirements of this chapter or other applicable provisions of the Dublin Municipal Code, including but not limited to zoning, land use, or building regulations ; C. The business premises or associated vehicle is unsafe, inadequate, or noncompliant with applicable laws or codes; D. The applicant or licensee has outstanding administrative citations or unresolved code violations; E. The business would interfere with or unreasonably obstruct the free flow of vehicular traffic, or with other means of travel on any public street, or with pedestrian traffic on the sidewalks; F. Required permits from the City or other agencies have not been obtained ; or G. The proposed or ongoing business activity violates local, state, or federal law or will interfere with the preservation of the public peace, health, safety or welfare of the public. (Ord. 10 -90 § 27) 4.04.280 Transferability—Change of ownership or location. No license issued pursuant to this chapter shall be transferable; provided, that where a license is issued authorizing a person to transact and carry on a business at a particular place, such licensee may, upon application therefor, have the license amended to authorize the transacting and carrying on of such business under the license at some other location to which the business is or is to be moved. Provided further, that transfer, whether by sale or otherwise, to another person under such circumstances that the real or ultimate ownership after the transfer is substantially similar to the ownership existing before the transfer shall not be prohibited by this section, provided application is made for transfer of the license and a fee to the Collector in an amount as fixed by the City Council by resolution. (Ord. 2 -18 § 1(C): Ord. 12-91 § 3; Ord. 10-90 § 28) 4.04.300 Posting and display of licenses. A. Any licensee transacting and carrying on business at a fixed place of business in the city shall keep the license posted in a conspicuous place upon the premises where such business is carried on. 98 Dublin Municipal Code Chapter 4.04 BUSINESS REGISTRATION Page 5/6 The Dublin Municipal Code is current through Ordinance 1-25, passed February 4, 2025. B. Any licensee transacting and carrying on business but not operating at a fixed place of business in the city shall keep the license upon his or her person or in the vehicle used for the business at all times while transacting and carrying on the business for which it is issued. (Ord. 10 -90 § 30) 4.04.310 Collector’s powers—Filing deadline. A. In addition to all other power conferred upon him, the Collector shall have the power, for good cause shown, to extend the time for filing any required application for a period not exceeding thirty (30) days, and in such case to waive any penalty that would otherwise have accrued. B. For the purposes of regulation under this chapter, the Collector shall also have the power to determine whether or not a person is engaged in business in the city when such question arises as a result of an occasional or a single isolated transaction during the course of one (1) or more calendar years. (Ord. 11 -20 § 7: Ord. 10-90 § 31) 4.04.320 Business registration fee—Penalty. A. A penalty of twenty-five percent (25%) of the unpaid business registration fee shall be added for each month or portion thereof that the fee remains unpaid, beginning thirty (30) days after the license’s expiration date. Penalties shall continue to accrue monthly at this rate, up to a maximum total penalty equal to one hundred percent (100%) of the original registration fee. B. In addition, on the first day of each month that the registration fee remains unpaid, interest in the amount of 1.5% of the delinquent amount excluding penalties and previously accrued interest shall be added to the amount due. C. The amount of any business registration fee and penalty imposed by the provisions of this chapter shall be deemed a debt to the city but may be reduced or waived, in the discretion of the Collector or on appeal, where appropriate. An action may be commenced in the name of the city in any court of competent jurisdiction for collection of such amounts. (Ord. 12-91 § 6) 4.04.330 Doing business without license does not waive requirements. The conviction and punishment of any person for transacting any business without a license shall not excuse or exempt such person from the payment of any fee due or unpaid at the time of such conviction, and nothing herein shall prevent a criminal prosecution of any violation of the provisions of this chapter. (Ord. 10 -90 § 33) 4.04.340 Enforcement authority—Inspection of premises. A. It shall be the duty of the Collector, and they are hereby directed, to enforce each and all of the provisions of this chapter, and Collector or designees shall render such assistance in the enforcement hereof as may from time to time be required by the Collector. B. The Collector, in the exercise of the duties imposed upon him or her hereunder, and acting through his or her deputies or duly authorized assistants, shall examine or cause to be examined all places of business in the city to ascertain whether the provisions of this chapter have been complied with. Absent consent to enter the premises, the Collector shall request the City Attorney to obtain the necessary judicial authority for entry and inspection. C. The Collector, and each and all of their designees and peace officers shall have the power and authority (upon obtaining an inspection warrant therefor) to enter, free of charge, and at any reasonable time, any place of business required to be licensed herein, and demand an exhibition of its license. Any person having such license theretofore issued, in his or her possession or under control, who willfully fails to exhibit the same on demand, is guilty of an infraction, and subject to the penalties provided for by the provisions of this chapter. (Ord. 12 -91 § 5; Ord. 10-90 § 34) 4.04.350 Appeal procedure. Any person aggrieved by any decision of the Collector with respect to the issuance, refusal, or revocation of such license may appeal to the City Manager pursuant to the provisions of Section 1.04.050 of this code. (Ord. 10 -90 § 35) 4.04.360 Violations—Infraction. Violation of the provisions of this chapter shall be an infraction. Upon determination by the Collector or any other city enforcement officer that a violation of this chapter has taken place, the officer is authorized to issue an 99 Dublin Municipal Code Chapter 4.04 BUSINESS REGISTRATION Page 6/6 The Dublin Municipal Code is current through Ordinance 1-25, passed February 4, 2025. administrative citation that may result in administrative fines in accordance with Chapter 1.06 of the Dublin Municipal Code. (Ord. 10-90 § 36) 4.04.370 Violation—Remedies cumulative. All remedies prescribed hereunder shall be cumulative and the use of one or more remedies by the city shall not bar the use of any other remedy for the purpose of enforcing the provisions hereof. (Ord. 10 -90 § 37) 4.04.380 First license required by October 1, 1990. Notwithstanding the provisions of Sections 4.04.240 and 4.04.260, no license shall be required under this chapter and no business registration fee shall be due until October 1, 1990. (Ord. 10 -90 § 39) 100 Dublin Municipal Code Page 1/8 Chapter 4.04 BUSINESS REGISTRATION Sections: 4.04.010 Purpose—Authority. 4.04.020 Definitions. 4.04.030 Registration fees—Limitations on effect of license. 4.04.040 Provisions not exclusive. 4.04.050 Business registration fee required—Exceptions. 4.04.060 Exemptions—Generally. 4.04.070 Exemptions—Agriculture. 4.04.080 Exemptions—Attorneys. 4.04.090 Exemptions—Banks. 4.04.100 Exemptions—Benefit activities. 4.04.110 Exemptions—Charitable purposes. 4.04.120 Exemptions—Disabled veterans. 4.04.130 Exemptions—Federal and state entities. 4.04.140 Exemptions—Insurance companies. 4.04.150 Exemptions—Inter-city freight carriers. 4.04.160 Exemptions—Nonprofit activities. 4.04.170 Exemptions—Part-time occupations. 4.04.180 Exemptions—Miscellaneous. 4.04.190 Evidence of doing business. 4.04.200 Branch establishments—Separate licenses. 4.04.205 Master license—Festival organizers. 4.04.210 License—Contents—Issuance conditions. 4.04.220 Application—First license. 4.04.225 Application—Amendments. 4.04.230 Application—Renewal license. 4.04.240 Payment—Time and method. 4.04.250 Business registration fee. 4.04.270 Denial and Revocation of license—Grounds. 4.04.280 Transferability—Change of ownership or location. 4.04.290 Duplicate license. 4.04.300 Posting and display of licenses. 4.04.310 Collector’s powers—Filing deadline. 4.04.320 Business registration fee—Penalty. 4.04.330 Doing business without license does not waive requirements. 4.04.340 Enforcement authority—Inspection of premises. 4.04.350 Appeal procedure. 4.04.360 Violations—Infraction. 4.04.370 Violation—Remedies cumulative. 4.04.380 First license required by October 1, 1990. 4.04.010 Purpose—Authority. This chapter is enacted to register businesses, trades, occupations and professions in the city of Dublin solely for the purpose of regulation and is enacted pursuant to Business and Professions Code Sections 460 and 16000 and California Constitution Article XI, Section 7. (Ord. 10-90 § 1) 4.04.020 Definitions. For the purposes of this chapter, the following definitions shall apply: Attachment 3 101 Dublin Municipal Code Chapter 4.04 BUSINESS REGISTRATION Page 2/8 “Business” means and includes professions, trades and occupations, and all and every kind of calling, whether or not carried on for profit. “City” means the city of Dublin, a municipal corporation of the state of California. “Collector” means the Finance Director or any other person the City Manager may designate to administer the business registration program. “Engaging in business” means commencing, conducting or continuing in business, and also the exercise of corporate or franchise powers, as well as liquidating a business when the liquidators thereof hold themselves out to the public as conducting such business. “Person” and “persons” means and includes all domestic and foreign corporations, associations, syndicates, joint stock corporations, partnerships of every kind, clubs, trusts, societies and individuals acting and carrying on any business in the city, other than as an employee. “Person” and “persons” shall also include the operator of a festival, fair, farmers’ market or similar event for which one person (the “organizer”) obtains required permits and licenses and which includes other persons who sell or offer to sell goods and/or food at the event (“purveyors”) through contract with the organizer or otherwise. (Ord. 11-20 § 2: Ord. 10-98 § 1; Ord. 10-90 § 2) 4.04.030 Registration fees—Limitations on effect of license. The terms “license” and “registration,” as used herein, shall not be construed to mean a permit. The fees prescribed by Section 4.04.210 of this chapter do not constitute a tax for revenue purposes, but are regulatory fees. The payment of a business registration fee required by this chapter and its acceptance by the city, and the issuance of such license to any person, shall not entitle the holder thereof to carry on any business unless he or she has complied with all of the requirements of this chapter and all other applicable laws, nor to carry on any business in any building or any premises designated in such license in the event that such building or premises are situated in a zone or locality in which the conduct of such business is in violation of any law. (Ord. 10-90 § 3) 4.04.040 Provisions not exclusive. Persons required to pay a business registration fee for transacting and carrying on any business under this chapter shall not be relieved from the payment of any license fee or permit for the privilege of doing such business required under any other ordinance of the city, and shall remain subject to the regulatory provisions of other ordinances. (Ord. 10-90 § 4) 4.04.050 Business registration fee required—Exceptions. A. There are imposed upon the businesses, trades, professions, calling and occupations specified in this chapter business registration fees in the amounts set forth in Section 4.04.250. It is unlawful for any person to transact, carry on and/or engage in any business, trade, profession, calling or occupation in the city without first having procured a license from the city to do so and paying the prescribed business registration fee, and without complying with any and all applicable provisions of this chapter. B. This section shall not be construed to require any person to obtain a license prior to doing business within the city if such requirement conflicts with applicable statutes of the United States or of the state of California. Persons not so required to obtain a license prior to doing business within the city nevertheless are encouraged to comply with the reporting requirements of this chapter as set forth in Section 4.04.220. (Ord. 10-90 § 5) 4.04.060 Exemptions—Generally. A. Any person claiming an exemption to Sections 4.04.070 through 4.04.180 shall submit to the Collector, upon a form provided by the Collector, a request for such exemption and statement of the facts upon which exemption is claimed, and in the absence of such request and statement substantiating the claim, such person shall be liable for the payment of the fees imposed by this chapter. (Ord. 11-20 § 3: Ord. 10-90 § 6) B. Any business that is exempt from business license fees or local regulatoryion licensing under federal or state law shall be exempt from local business registration fees that would otherwise apply under this program. 102 Dublin Municipal Code Chapter 4.04 BUSINESS REGISTRATION Page 3/8 4.04.070 Exemptions—Agriculture. The provisions of this chapter shall not require the payment of a business registration fee on the business of agriculture, except for the retail activities conducted in connection therewith. (Ord. 10-90 § 7) 4.04.080 Exemptions—Attorneys. The provisions of this chapter shall not apply to any natural person licensed to practice law in the state of California when such a person is practicing law. (Ord. 12-91 § 1) 4.04.090 Exemptions—Banks. The provisions of this chapter shall not apply to any state or national bank which pays an “in lieu” tax provided for in Article 13, Section 27 of the California Constitution. (Ord. 10-90 § 9) 4.04.100 Exemptions—Benefit activities. The provisions of this chapter shall not require the payment of a business registration fee for the conducting of any entertainment, concert, exhibition or lecture on scientific, historical, literary, benevolent or moral subjects within the city whenever all the gross receipts of any such entertainment, concert, exhibition or lecture are to be appropriated to any church or school, or to any benevolent purpose within the city. (Ord. 10-90 § 10) 4.04.110 Exemptions—Charitable purposes. The provisions of this chapter shall not require the payment of a business registration fee to conduct, manage or carry on any business, occupation or activity by any organization which qualifies for tax exemption under Internal Revenue Code Section 501(c). (Ord. 10-90 § 11) 4.04.120 Exemptions—Disabled veterans. Any veteran who is unable to obtain a livelihood by manual labor due to any physical disability may obtain a license to hawk or peddle any goods, wares or merchandise without payment of any business registration fee, by applying to the Collector and producing a certificate from a duly licensed physician showing the applicant to be physically disabled, evidence of being a legal voter of the state, and a copy of an honorable discharge. (Ord. 10-90 § 12) 4.04.130 Exemptions—Federal and state entities. Nothing in this chapter shall be deemed or construed to apply to any person transacting and carrying on any business on behalf of any agency, department or political subdivision of the United States or of the state of California. (Ord. 10-90 § 13) 4.04.140 Exemptions—Insurance companies. The provisions of this chapter shall not apply to any insurer which pays an “in lieu” tax provided for in Article 13, Section 28 of the California Constitution. As used herein, “insurer” does not include insurance brokers. (Ord. 10-90 § 14) 4.04.150 Exemptions—Inter-city freight carriers. The provisions of this chapter shall not apply to inter-city freight carriers who are paying an in-lieu tax to the state under the Highway Carriers Uniform Business License Tax Act; provided, however, this exemption shall not be deemed to prohibit the levying of any excise or license tax authorized pursuant to Division 2 of the Revenue and Taxation Code of the state. (Ord. 10-90 § 15) 4.04.160 Exemptions—Nonprofit activities. A. The provisions of this chapter shall not require the payment of a business registration fee for the conducting of any entertainment, dance, concert, exhibition or lecture by any benevolent, charitable, fraternal, educational, military, state, county or municipal organization or association whenever the receipts of any such entertainment, dance, concert, exhibition or lecture are to be appropriated for the purpose and objects for which such organization or association was formed and from which profit is not derived, either directly or indirectly, by an individual. B. No license under this chapter shall be required of any nonprofit institution, corporation, organization or association organized or conducted for nonprofit purposes only, when the receipts derived are to be wholly for the benefit of such organization and not in whole or in part for the private gain of any person. This exemption shall not apply to promoters employed by such nonprofit institutions, corporations, organizations or associations. (Ord. 10-90 § 16) 103 Dublin Municipal Code Chapter 4.04 BUSINESS REGISTRATION Page 4/8 4.04.170 Exemptions—Part-time occupations. The provisions of this chapter shall not apply to any natural person under the age of eighteen or over the age of sixty-five (65) engaged in any part-time occupation, or any person who performs manual labor only, on an hourly or other time basis, and who furnishes only such tools and incidentals as may be required in the performance of such manual labor. (Ord. 10-90 § 17) 4.04.180 Exemptions—Miscellaneous. The provisions of this chapter shall not apply to the following: A. Cafe musicians, as defined in Business and Professions Code Section 16000.5. B. Commercial travelers, as defined and described in Business and Professions Code Section 16002. C. Real estate auctioneers, as defined and described in Business and Professions Code Section 16002.1. D. Persons renting, leasing or operating laundry equipment which is not coin-operated laundry equipment owned and operated by a retail establishment providing coin-operated laundry equipment for general public use. E. Persons renting, leasing, or operating coin-operated vending machines. (Ord. 10-90 § 18) 4.04.190 Evidence of doing business. When any person makes use of signs, circulars, cards, telephone books or newspapers, websites, social media platforms, and advertises, holds out or represents that he or she is in business in the city, or when any person holds an active license or permit issued by a governmental agency indicating that he or she is in business in the city, and such person fails to deny by an affidavit sworn to before a person authorized to take oaths or a declaration or certificate under penalty of perjury given to the Collector that he or she is conducting a business in the city, after being requested to do so by the Collector, then these facts shall be considered prima facie evidence that he or she is conducting a business in the city. (Ord. 11-20 § 4: Ord. 10-90 § 19) 4.04.200 Branch establishments—Separate licenses. A separate license must be obtained for each branch establishment or location of the business transacted and carried on, and for each separate type of business at the same location, and each license shall authorize the licensee to transact and carry on only the business licensed thereby at the location or in the manner designated in such license; provided, that warehouses and distributing plants used in connection with and incidental to a business licensed under the provisions of this chapter shall not be deemed to be separate places of business or branch establishments, and provided further that only one (1) license is required for the rental or lease of real property within the city regardless of the number of locations or units of real property being rented or leased. (Ord. 12-91 § 2) 4.04.205 Master license—Festival organizers. The organizer of a festival, fair, farmers’ market or similar event shall obtain a master license for himself and all purveyors of goods and/or food who will participate in the event. No individual purveyors shall be required to obtain a separate license. (Ord. 10-98 § 2) 4.04.210 License—Contents—Issuance conditions. Every person required to have a license under the provisions of this chapter shall make application as hereinafter prescribed for the same to the Collector, and upon the payment of the prescribed business registration fee, the Collector shall issue to such person a license, which shall contain the following information: A. The name of the person to whom the license is issued; B. The name of the business licensed; C. The place where such business is to be transacted and carried on; D. The date of the expiration of such license; and E. Such other information as may be necessary for the enforcement of the provisions of this chapter. (Ord. 10-90 § 21) 104 Dublin Municipal Code Chapter 4.04 BUSINESS REGISTRATION Page 5/8 4.04.220 Application—First license. A. Upon a person making application for the first license to be issued under this chapter, or for a newly established business, such person shall furnish to the Collector, upon a form provided by the Collector, the following information: 1. The exact nature or kind of business for which a license is requested; 2. The place where such business is to be carried on, along with all required documentation confirming approvaling to operate operations at that site, and if the same business is not to be conducted at a permanent place of business, is not to be carried on at any permanent place of business, the residential addresses of the places of residence of the business owners of sameshall also be provided; 3. In the event that application is made for issuance of a license to a person doing business under a fictitious name, the application shall set forth the names and places of business of those owning the business; 4. In the event that the application is made for the issuance of a license to a corporation or a partnership, the application shall set forth the names and places of business of the officers or partners thereof; 5. For established and operating businesses: the daily average number of employees employed in furtherance of the business being licensed during the ninety (90) day period preceding the date of application. For new businesses: the daily average number of employees anticipated to be employed to conduct the business during the ninety (90) day period following the date of the application; 6. In the event the application is made for issuance of a master license to a festival organizer, the application shall set forth the names and addresses of all purveyors, and the goods and/or food to be purveyed; 7. Any further information which the Collector may require to enable him or her to issue the license. B. The Collector shall not issue to any such person another license for the same or any other business until such person has furnished to him or her the information required by subsection A of this section and paid the business registration fee as herein required. (Ord. 11-20 § 5: Ord. 10-98 § 3; Ord. 10-90 § 22) 4.04.225 Application—Amendments. A. If any information provided in the application on filed with the city changes, or if the business ceases operations, the applicant shall report these changes to the city within seven days of theirsuch changes or cessation. occurrence. B. Amendments mayshall not be used to change the business location or ownership. Any sSuch changes must follow the proceduresess outlined in Section 4.04.280. 4.04.230 Application—Renewal license. A. The applicant for the renewal of a license shall submit to the Collector, on or before the expiration date of the license, the applicable renewal fee and, on a form provided by the Collector, the information described in October 1st of each year, the correct amount of fee and, upon a form provided by the Collector, the information described in Section 4.04.220. (Ord. 11-20 § 6: Ord. 10-90 § 23) B. All licenses shall be valid through the last day of the month preceding the one-year anniversary of the date of issuance, unless revoked, suspended, or otherwise subject to a different expiration period under the terms of the individual license. 4.04.240 Payment—Time and method. Unless otherwise specifically provided, all annual business registration fees under the provisions of this chapter shall be due and payable in advance on the first day of October of each year. (Ord. 10-90 § 24) 4.04.250 Business registration fee. The business registration fees, which are found to be commensurate with the cost of issuance of the license, shall be as fixed by the City Council by resolution. (Ord. 2-18 § 1(A): Ord. 10-98 § 4: Ord. 10-90 § 25) 105 Dublin Municipal Code Chapter 4.04 BUSINESS REGISTRATION Page 6/8 4.04.270 Denial and Revocation of license—Grounds. A business license or renewal of a license may be denied or revoked by the Collector for any of the following causes: A. The application is incomplete, not submitted on the required form provided, or does not contain the required information; B. The application contains materially false information; CB. The applicant or licensee has failed to comply with the requirements of this chapter or other applicable provisions of the Dublin Municipal Code, including but not limited to zoning, land use, or building regulationsNoncompliance with requirements of this chapter; C. The business premises or associated vehicle is unsafe, inadequate, or noncompliant with applicable laws or codes; D. The applicant or licensee has outstanding administrative citations or unresolved code violations; EE. The business would interfere with or unreasonably obstruct the free flow of vehicular traffic, or with other means of travel on any public street, or with pedestrian traffic on the sidewalks; FF. Required permits from the City or other agencies have not been obtainedAppropriate permits for the business have not been obtained from the city; or GG. The conduct of the business or activity will be contrary to law; or H. The conduct of the business orproposed or ongoing business activity violates local, state, or federal law or will interfere with the preservation of the public peace, health, safety or welfare of the public. (Ord. 10-90 § 27) 4.04.280 Transferability—Change of ownership or location. No license issued pursuant to this chapter shall be transferable; provided, that where a license is issued authorizing a person to transact and carry on a business at a particular place, such licensee may, upon application therefor, have the license amended to authorize the transacting and carrying on of such business under the license at some other location to which the business is or is to be moved. Provided further, that transfer, whether by sale or otherwise, to another person under such circumstances that the real or ultimate ownership after the transfer is substantially similar to the ownership existing before the transfer shall not be prohibited by this section, provided application is made for transfer of the license and a fee to the Collector in an amount as fixed by the City Council by resolution. (Ord. 2-18 § 1(C): Ord. 12-91 § 3; Ord. 10-90 § 28) 4.04.290 Duplicate license. A duplicate license may be issued by the Collector to replace any license previously issued hereunder which has been lost or destroyed, upon the licensee filing a statement of such fact, and at the time of filing such statement paying to the Collector a duplicate license fee in an amount as fixed by the City Council by resolution. (Ord. 2-18 § 1(D): Ord. 12-91 § 4; Ord. 10-90 § 29) 4.04.300 Posting and display of licenses. A. Any licensee transacting and carrying on business at a fixed place of business in the city shall keep the license posted in a conspicuous place upon the premises where such business is carried on. B. Any licensee transacting and carrying on business but not operating at a fixed place of business in the city shall keep the license upon his or her person or in the vehicle used for the business at all times while transacting and carrying on the business for which it is issued. (Ord. 10-90 § 30) 106 Dublin Municipal Code Chapter 4.04 BUSINESS REGISTRATION Page 7/8 4.04.310 Collector’s powers—Filing deadline. A. In addition to all other power conferred upon him, the Collector shall have the power, for good cause shown, to extend the time for filing any required application for a period not exceeding thirty (30) days, and in such case to waive any penalty that would otherwise have accrued. B. For the purposes of regulation under this chapter, the Collector shall also have the power to determine whether or not a person is engaged in business in the city when such question arises as a result of an occasional or a single isolated transaction during the course of one (1) or more calendar years. (Ord. 11-20 § 7: Ord. 10-90 § 31) 4.04.320 Business registration fee—Penalty. A. A penalty of twenty-five percent (25%) of the unpaid business registration fee shall be added for each month or portion thereof that the fee remains unpaid, beginning thirty (30) days after the license’s expiration date. Penalties shall continue to accrue monthly at this rate, up to a maximum total penalty equal to one hundred percent (100%) of the original registration fee. B. In addition, on the first day of each month that the registration fee remains unpaid, interest in the amount of 1.5% of the delinquent amount excluding penalties and previously accrued interest shall be added to the amount due. A penalty in the amount of seven percent (7%) compounded monthly of any delinquent business registration fee shall accrue on the thirtieth day following the due date of any business registration fee, up to a maximum penalty equal to the amount of the business registration fee. C. The amount of any business registration fee and penalty imposed by the provisions of this chapter shall be deemed a debt to the city but may be reduced or waived, in the discretion of the Ccollector or on appeal, where appropriate. An action may be commenced in the name of the city in any court of competent jurisdiction for collection of such amounts. (Ord. 12-91 § 6) 4.04.330 Doing business without license does not waive requirements. The conviction and punishment of any person for transacting any business without a license shall not excuse or exempt such person from the payment of any fee due or unpaid at the time of such conviction, and nothing herein shall prevent a criminal prosecution of any violation of the provisions of this chapter. (Ord. 10-90 § 33) 4.04.340 Enforcement authority—Inspection of premises. A. It shall be the duty of the Collector, and he or shethey is are hereby directed, to enforce each and all of the provisions of this chapter, and the zoning investigator Collector or designees shall render such assistance in the enforcement hereof as may from time to time be required by the Collector. B. The Collector, in the exercise of the duties imposed upon him or her hereunder, and acting through his or her deputies or duly authorized assistants, shall examine or cause to be examined all places of business in the city to ascertain whether the provisions of this chapter have been complied with. Absent consent to enter the premises, the Collector shall request the City Attorney to obtain the necessary judicial authority for entry and inspection. C. The Collector, and each and all of his or hertheir assistants and any police officer,designees and peace officers shall have the power and authority (upon obtaining an inspection warrant therefor) to enter, free of charge, and at any reasonable time, any place of business required to be licensed herein, and demand an exhibition of its license. Any person having such license theretofore issued, in his or her possession or under control, who wilfullywillfully fails to exhibit the same on demand, is guilty of an infraction, and subject to the penalties provided for by the provisions of this chapter. (Ord. 12-91 § 5; Ord. 10-90 § 34) 4.04.350 Appeal procedure. Any person aggrieved by any decision of the Collector with respect to the issuance, or refusal, or revocation to issueof such license may appeal to the City Manager pursuant to the provisions of Section 1.04.050 of this code. (Ord. 10-90 § 35) 4.04.360 Violations—Infraction. Violation of the provisions of this chapter shall be an infraction. Upon determination by the Collector or any other city enforcement officer that a violation of this chapter has taken place, the officer is authorized to issue an 107 Dublin Municipal Code Chapter 4.04 BUSINESS REGISTRATION Page 8/8 administrative citation that may result in administrative fines in accordance with Chapter 1.06 of the Dublin Municipal Code. (Ord. 10-90 § 36) 4.04.370 Violation—Remedies cumulative. All remedies prescribed hereunder shall be cumulative and the use of one or more remedies by the city shall not bar the use of any other remedy for the purpose of enforcing the provisions hereof. (Ord. 10-90 § 37) 4.04.380 First license required by October 1, 1990. Notwithstanding the provisions of Sections 4.04.240 and 4.04.260, no license shall be required under this chapter and no business registration fee shall be due until October 1, 1990. (Ord. 10-90 § 39) 108 i | P a g e SUBMITTED BY HdL Companies 120 S. State College Blvd., Ste 200 Brea, CA 92821 hdlcompanies.com CONTACT Eric Myers T: (424) 228-8517 Ext. 1022 E: emyers@hdlcompanies.com May 8, 2025 Business License Registration: Ordinance Review Brief Dublin City of Attachment 4 109 ii | P a g e DUBLIN ORDINANCE REVIEW TABLE OF CONTENTS Introduction ..................................................................................................................... 1 Methodology .................................................................................................................... 1 Summary of Findings and Recommendations ................................................................. 1 A. Exemptions ............................................................................................................. 1 B. Renewal Cycle ........................................................................................................ 2 C. Pro-ration of Fees ................................................................................................... 2 D. Penalties ................................................................................................................. 3 110 1 | P a g e Introduction This brief outlines key findings and recommendations from HDL Companies’ review of the City of Dublin’s business registration ordinance. The recommendations presented aim to support the City in ensuring comprehensive compliance, effective enforcement, and streamlined service delivery to the business community. Overview of Areas Analyzed  Exemptions  Renewal Cycle  Pro-ration of Fees  Penalties Methodology Our approach included:  A review of procedures established for administration as set forth in the Dublin’s municipal code.  A comparative analysis with three cities Palo Alto, Lodi, and Glendale selected for their use of business registration programs and relevance in terms of size, structure, and policy model.  The identification of best practices in each area, informed by HDL’s experience supporting over 100 jurisdictions with business license compliance and tax administration, and industry standards. Summary of Findings and Recommendations A. Exemptions Summary of Current Provisions Dublin exempts several categories from paying the business registration fee, including banks, insurers, attorneys, nonprofit organizations, state/federal agencies, and individuals with limited or low-income business activity. While some exemptions follow legal requirements, others are based on occupation or purpose. Notably, exempt entities are not required to register, though the City encourages voluntary compliance for data and tracking purposes. Comparison Highlights 111 2 | P a g e  Palo Alto provides exemptions for home-based businesses, nonprofits with fewer than one FTE, and transitory vendors. Registration is not required for exempt groups.  Lodi allows exemptions for certain nonprofit, veteran, or low-income home-based activities, but requires registration/payment for paid contractors.  Glendale: Requires most businesses, including nonprofits, to register. Exemptions are linked to land use rather than organization type. General Recommendations  Exempt businesses as required under state and federal law, and streamline the code language to clearly and concisely cover these exemptions. Examples includes but are not limited to Nonprofit organizations with 501 (C) (3) status, banking institutions, attorneys or public agencies, depending on the applicable legal frameworks. B. Renewal Cycle Summary of Current Provisions Dublin currently uses a fixed renewal deadline for all businesses—October 1st each year. Regardless of the registration date, all businesses must renew by this single date and submit updated business information along with the annual registration fee. Comparison Highlights  Palo Alto: Fixed annual renewal due by March 31.  Lodi: Annual renewal due January 1, with delinquency starting February 1.  Glendale: Uses an anniversary-based renewal system—each registration is valid for one year from issuance. General Recommendations  Transition to an anniversary-based renewal cycle, where each business renews one year from its original registration date.  This model spreads renewals throughout the year, reducing administrative bottlenecks. Should the City choose to adopt this model, a transitional strategy can be implemented to phase in the change for existing businesses over time. C. Pro-ration of Fees Summary of Current Provisions Dublin currently does not offer pro-ration. Businesses must pay the full annual fee regardless of when they begin operations. Comparison Highlights 112 3 | P a g e  Neither Glendale, Palo Alto and Lodi currently offer pro-rated fees. General Recommendations  If Dublin adopts the anniversary-based renewal model, each business will already receive a full year of coverage from its registration date.  As such, a pro-ration policy would not be necessary and could be avoided for administrative simplicity.  Furthermore, prorating a fee whose purpose is to cover the cost of the registration would be counterproductive because the cost of registration processing is the same no matter when the registration is completed in the year. D. Penalties Summary of Current Provisions Dublin applies a 7% penalty, compounded monthly, on late payments starting 30 days after the due date, up to a maximum of 100% of the original fee. Comparison Highlights  Palo Alto uses a flat fee model for delinquencies. A $25 late fee is applied to payments received after April 30, with an additional $25 fee applied to those received after May 30. There is no compounding or percentage-based penalty, and no explicit cap is needed under this structure. However, there is no reference to reapplication requirements for businesses that remain noncompliant for an extended period.  Lodi does not have a separate business license penalty structure detailed in its business registration provisions. Instead, it relies on its general penalty ordinance, which classifies violations as infractions subject to escalating fines: $100 for the first offense, increasing for repeat violations. There is also no administrative reapplication process outlined for prolonged delinquency.  Glendale, notably, does not impose a specific monetary penalty for late renewals. Instead, any registration not renewed within 30 days before expiration is automatically deemed expired, and the business must submit a new application to continue operating. General Recommendations  We recommend that the City of Dublin adopt a standard delinquency penalty structure that applies a flat percentage each month to the unpaid fee, with penalties accruing until they reach a 100% cap of the original registration amount. This method aligns with structured financial penalties that are common among municipalities, is straightforward to administer, is easy for businesses to understand, and ensures that the full penalty is assessed within a defined timeframe. 113 4 | P a g e  We do not recommend requiring businesses to reapply after a period of delinquency. Instead, maintaining the original registration and treating the outstanding amount as a debt owed to the City ensures continuity, avoids duplicate records, and streamlines enforcement. 114