Free Multi-State CAM Disclosure Matrix

Most states do not have specific statutory CAM disclosure requirements. Commercial lease terms are generally governed by the lease agreement itself. The notable exception is California, which enacted SB 1103 to establish disclosure rights for qualified commercial tenants. Several other states have market-standard practices for reconciliation statement timing (typically 90 to 180 days after year-end) that are widely used in institutional leases even without statutory backing. The matrix covers the 15 largest CRE markets with notes on both statutory requirements and market-standard practices.

Under California market practice and the SB 1103 framework for qualified commercial tenants, CAM reconciliation statements are typically delivered within 90 days following the end of the reconciliation year. For SB 1103 qualified commercial tenants (small businesses meeting the statutory definition), the reconciliation must be delivered on time to preserve the landlord's right to collect any balance due. Late delivery can forfeit the landlord's recovery rights for that year under SB 1103.

California SB 1103, which took effect January 1, 2025, establishes specific protections for qualified commercial tenants (generally small businesses with 5 or fewer employees and annual gross revenues under $2.5 million). For leases with qualified commercial tenants, landlords must provide itemized CAM estimates before the lease year, deliver itemized reconciliation statements within the required timeframe, and allow tenants to audit CAM charges. The matrix includes a dedicated row for SB 1103 requirements alongside general California market standards.

No. There are no federal statutes governing CAM disclosure in commercial leases. Commercial real estate is regulated at the state level, and most states leave CAM terms entirely to the lease agreement. The federal Truth in Lending Act (TILA) and Real Estate Settlement Procedures Act (RESPA) apply to residential and certain mixed-use transactions but do not govern commercial CAM. The matrix is a state-level reference only.