BL2024-478: what Metro wants to change about owner-occupied permits

There is a bill working its way through Metro Council right now that would change who is allowed to hold an owner-occupied short-term rental permit in Davidson County. If you hold one, or you are counting on getting one, this is worth twenty minutes of your attention.

BL2024-478 was introduced on July 30 and had its public hearing on October 1 (NASTRA's summary of the ordinance). The short version of what it does:

  • Natural persons only. An owner-occupied permit could be held by a human being, not by an LLC, trust, or other entity.

  • Four residency documents. Applicants would have to prove the property is genuinely their primary residence with multiple forms of documentation rather than one.

  • Revocation on ownership change. If the property changes hands, the permit goes away with the previous owner rather than traveling with the house.

What this is actually aimed at

Metro has not issued new non-owner-occupied permits in residentially zoned areas since 2022, which is why the permit itself is the asset and the nightly rate is just the yield. When you close one door, pressure moves to the door that is still open — and the door still open is the owner-occupied permit. The city's read, as far as I can tell from the record, is that some owner-occupied permits are held by entities or by people who do not really live there, and that the residency requirement has been easier to assert than to verify.

Whether you think that is fair depends a lot on which side of it you are sitting on. But the direction of travel is not ambiguous, and it has been consistent for two years: Nashville is making short-term rental permits harder to get, harder to keep, and less transferable.

What it would mean if it passes

If you hold an owner-occupied permit in your own name and you actually live there: probably not much day to day, other than more paperwork at renewal. Get your residency documents organized now — driver's license, voter registration, utility bills, tax documents — and stop assuming one of them is enough.

If your owner-occupied permit sits inside an LLC or a trust: this is the one to take seriously. Talk to your attorney about it before the bill moves rather than after. I am a property manager, not a lawyer, and this is exactly the kind of question where the cheap hour of legal advice pays for itself.

If you are buying a home with an existing permit: stop treating the permit as part of the purchase. A revocation-on-transfer provision means you are buying a house, not a house with a permit attached, and your underwriting should say so.

If you are counting on selling a permitted property at a premium: the premium is real today because permits are scarce. A rule that kills the permit on transfer would move that value from the asset to the operator. That is a big deal and it deserves a place in your model.

The Boost part: we do the permit work

We handle permitting for the homes we manage. That means the application, the documentation package, the follow-up with Metro Codes, and the renewal — not a PDF emailed to you with a good-luck note.

Two details that matter here:

Permits run 365 days and have to be renewed. Metro sends renewal notices in advance, but every expiration date for every home we manage sits in our system with its own reminder chain, because I do not want a producing asset going dark over a city email that landed in a junk folder. We start the renewal well ahead of the deadline.

Permit work is included with management. You pay Metro's own application and renewal fees — those are the city's, not ours, and we do not add a markup to them. For owners who want the permit help without the management, we do it as a standalone service. Either way you are dealing with people who file these regularly and know what Codes will bounce.

If you are self-managing and want to do this yourself, that is completely reasonable. Start at Metro Codes' short-term rental page, read the requirements for your specific permit type, and build the document package before you start the application rather than during it.

What I would do this month

  1. Find your permit. Confirm the type, the holder's name, and the expiration date.

  2. If the holder is an entity rather than a person, call your attorney this week.

  3. Build a residency file if you hold owner-occupied: four documents, current, in one folder.

  4. Put a 90-day reminder on your renewal date. Then put a second one at 45 days.

  5. Watch the bill. Council takes short-term rental items one at a time, in public, and this one has been moving all fall.

None of that is glamorous. All of it is cheaper than losing a permit you cannot replace.

If you own a Nashville short-term rental and you want somebody to look at your permit situation before the rules change again, talk to Boost Rentals. Send the address and the permit number and I will tell you what I see. No obligation, and you should know where you stand either way.

— Chris Hetzner, Boost Rentals