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SMALL PROPERTY OWNERS OF SAN FRANCISCO v. CITY AND COUNTY OF SAN FRANC. Part II
Local ordinance requiring landlords to pay 5 percent interest on security deposits did not constitute an unconstitutional regulatory taking. Where landlords were not compelled to invest the funds in instruments paying a return of less than 5 percent. Any losses resulting from the investment in money market was small, avoidable--since the ordinance only applied if the deposit was held more than a year--and offset by the benefit to the landlord of holding the security.

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