No additional professional skills will be required to comply with the emergency rule. A prohibition on charging late rent fees during a public health emergency does not create a new administrative function.
Accommodation for Small Business
Many of the landlords affected by this rule are “small businesses.” However, no accommodations or special exceptions have been planned because none are needed.
Conclusion
This rule will have little, perhaps no, adverse effect on businesses, including “small businesses,” by temporarily prohibiting the charging of late rent fees or late rent penalties during a public health emergency. The department does not know how many residential tenants are currently being charged late rent fees or late rent penalties during the public health emergency. Negative effects, if any, of prohibiting such charges will be few and limited.
Because this rule will not have a significant adverse effect on “small business,” it is not subject to the delayed “small business” effective date provided in Wis. Stat. s 227.22 (2) (e). Due to its emergency nature, the change will go into effect upon publication in the official state newspaper.
Dated this ______ day of _________________, 2020.
STATE OF WISCONSIN
DEPARTMENT OF AGRICULTURE,
TRADE AND CONSUMER PROTECTION
By __________________________________
Lara Sutherlin, Administrator
Division of Trade and Consumer Protection
