Immediate Compliance Required: Revised 3-Day Forms Now Available

SCRHA has made important revisions to several 3-Day Notice forms, effective immediately. These updates respond to procedural clarifications in the California Court of Appeal’s decision in Eshagian v. Cepeda (2025), ensuring your notice practices remain legally sound and clearly documented. 

Legal Update 

The Eshagian ruling clarified several key procedural requirements: 

• Reinforced requirement: Notices must clearly state that Saturdays, Sundays, and court holidays are excluded from the 3-day compliance period. SCRHA’s forms have long reflected this standard, and the court has now formally reinforced its necessity. 

• New requirement: The date the notice is signed must match the date of service. The notice must be signed and served on the same day. 

• New requirement: Notices must include a specific expiration date, calculated by excluding weekends and court holidays where applicable. 

SCRHA’s updates reflect these requirements not by changing our practices—but by making them more explicit and easier to document. 

Updated Forms & Key Adjustments 

• 400: 3-Day Notice to Pay Rent or Quit 
  • Added exclusion language in three sections and structured expiration field 
• 405: 3-Day Notice to Quit (Surrender Possession)
  • Removed exclusion language for weekends/holidays; clarified expiration timing 
• 410: 3-Day Notice to Comply or Quit 
  • Added exclusion language and refined expiration documentation 
• 410.5: 3-Day Notice to Comply or Quit – Monetary (Non-Rent) 
  • Same updates as Form 410 for consistency and compliance 

Forms for Members >

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Recommended Best Practice

We strongly recommend that members use Form 455 – Declaration of Service: Notice to Resident when serving any 3-Day Notice. 

Form 455 is for internal records only and is not served to the resident. 

Access & Transition

SCRHA is actively working with TurboTenant to ensure the updated forms are posted to their platform. In the meantime, all revised forms will be available in the Member Compass portal for the next 30 days. After this transition period, they will be fully integrated into our standard forms library. 

SCRHA’s Commitment to Members

SCRHA closely monitors legal developments and acts quickly to translate them into practical updates for housing providers. These latest revisions reflect our ongoing commitment to legal accuracy, operational clarity, and timely support. 

Please contact us if you have questions or need guidance on implementing the new forms.