11VAC20-30-130 (B)(C)(E)(F)

This regulation completely oversteps the department's boundaries. Landlords should not have to register anywhere. People are free to lease to whomever and from whomever they choose without restrictions.

To prohibit a landlord (or immediate family with the overly broad definition) from obtaining services or loaning money to anyone associated with an organization (or immediate family with the overly broad definition) is beyond the authority of the department. Landlords have a right to choose whomever they want to make a loan or hire someone for other work.

This item needs to be stricken or changed to take out these items which go beyond their authority.

11VAC20-30-130(L) "...a landlord shall provide to the department the records, including financial records, that the department deems necessary to complete an inspection, audit or investigation. The department may suspend or revoke the registration of a landlord who refuses to provide the requested records..." needs to be stricken. 

This goes way above and beyond the department's ability to ask for such broad authority.  Too broad and too inclusive.