MemphisShort-term rental rules

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Memphis has run a citywide short-term rental license since Ordinance 5856 took effect in 2023. There is no primary-residence rule or numeric cap, and the code says plainly that a permit does not transfer on sale.

Research reviewed Oct 18, 2026. Original city review.

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Does the operating permit transfer?: New application
The permit cannot be transferred or assigned to another person or address; a buyer must apply fresh. A pre-ordinance grandfathered rental loses its exemption the moment the property sells.
Can the land-use approval continue?: Verify the property approval
The operating-permit rule does not establish whether this parcel’s zoning approval, variance or older-use protection continues. Obtain the actual approval and its conditions.
Can this buyer obtain approval?: Non-owner-occupied rentals are allowed citywide with no primary-residence rule and no numeric cap; one permit is required per unit, with no density limit found.
License or registration: The Division of Planning and Development issues a single Short-Term Rental License for $300, renewable every two years for $150.
Application availability: Confirm current availability
Application availability was not separately reverified for this explorer. Check the city’s current program, cap, lottery or waitlist before relying on the seller’s rental history.
Timing to verify: No sale-specific deadline was established in this summary. Ask the issuing office about filing, renewal and any interruption in operation.
Changes and uncertainty: The ordinance is unchanged since March 2023; no litigation or amendment found through the Dec. 2025 supplement.

What this means for the appraisal

Obtain the buyer application requirements and confirm the earliest approved operating date before assuming continuity of rental income.
Verify the property’s land-use approval and continuation conditions. Research finding: Verify the property approval.
Check the proposed buyer against the recorded requirements: Non-owner-occupied rentals are allowed citywide with no primary-residence rule and no numeric cap; one permit is required per unit, with no density limit found.
In the assignment analysis, identify the evidence supporting the proposed rental use, any operating interruption and any unresolved assumptions.

Use these prompts to plan the property review. The appraiser must evaluate the evidence and reach the assignment-specific conclusions.

Record the property evidence in a worksheet

Request documents from the owner or agent

Copy this market-specific request, add the property address and edit it for the assignment.

Read or select the document request

Document request for Memphis

Subject: STR property document request | Memphis, TN

Please provide the following documents for the property under review. Identify any item that is unavailable or does not apply.

1. Property address, parcel ID and confirmation of the governing jurisdiction.
2. Current operating permit or registration, named holder, expiration date and renewal history, if applicable.
3. Written ownership-change instructions from the issuing office. Guide finding: The permit cannot be transferred or assigned to another person or address; a buyer must apply fresh. A pre-ordinance grandfathered rental loses its exemption the moment the property sells.
4. Zoning approval, conditional-use permit, variance or grandfathering record, including conditions and evidence of continued use. Guide finding: The operating-permit rule does not establish whether this parcel’s zoning approval, variance or older-use protection continues. Obtain the actual approval and its conditions.
5. Documents addressing the proposed buyer and property requirements: Non-owner-occupied rentals are allowed citywide with no primary-residence rule and no numeric cap; one permit is required per unit, with no density limit found.
6. Current confirmation of application availability, including any cap, waitlist, lottery or separation rule. Guide finding: Application availability was not separately reverified for this explorer. Check the city’s current program, cap, lottery or waitlist before relying on the seller’s rental history.
7. Recorded covenants, HOA or condominium rental restrictions and applicable lease restrictions.
8. Rental operating statements and booking records, with the periods covered and any anticipated interruption at closing.

Market research reviewed: 2026-10-18. These requests need property-specific verification.
Official research sources:
Memphis Code of Ordinances, Title 5, Chapter 5-44, Short Term Rental Ordinance: https://library.municode.com/tn/memphis/codes/code_of_ordinances?nodeId=TIT5REFI_CH5-44SHTEREOR
Develop901 (Memphis and Shelby County Division of Planning and Development), Short-Term Rental Registration: https://www.develop901.com/strr

Subject: STR property document request | Memphis, TN

Please provide the following documents for the property under review. Identify any item that is unavailable or does not apply.

1. Property address, parcel ID and confirmation of the governing jurisdiction.
2. Current operating permit or registration, named holder, expiration date and renewal history, if applicable.
3. Written ownership-change instructions from the issuing office. Guide finding: The permit cannot be transferred or assigned to another person or address; a buyer must apply fresh. A pre-ordinance grandfathered rental loses its exemption the moment the property sells.
4. Zoning approval, conditional-use permit, variance or grandfathering record, including conditions and evidence of continued use. Guide finding: The operating-permit rule does not establish whether this parcel’s zoning approval, variance or older-use protection continues. Obtain the actual approval and its conditions.
5. Documents addressing the proposed buyer and property requirements: Non-owner-occupied rentals are allowed citywide with no primary-residence rule and no numeric cap; one permit is required per unit, with no density limit found.
6. Current confirmation of application availability, including any cap, waitlist, lottery or separation rule. Guide finding: Application availability was not separately reverified for this explorer. Check the city’s current program, cap, lottery or waitlist before relying on the seller’s rental history.
7. Recorded covenants, HOA or condominium rental restrictions and applicable lease restrictions.
8. Rental operating statements and booking records, with the periods covered and any anticipated interruption at closing.

Market research reviewed: 2026-10-18. These requests need property-specific verification.
Official research sources:
Memphis Code of Ordinances, Title 5, Chapter 5-44, Short Term Rental Ordinance: https://library.municode.com/tn/memphis/codes/code_of_ordinances?nodeId=TIT5REFI_CH5-44SHTEREOR
Develop901 (Memphis and Shelby County Division of Planning and Development), Short-Term Rental Registration: https://www.develop901.com/strr

Research and guide updates

Oct 18, 2026 Research record: Research recorded for this market. Original city review. See the findings, open questions and official sources below.
Nov 1, 2026 Guide tools: Added assignment prompts, a document request and consistent research questions. This tool update does not change the market research date.

Changes and uncertainty to verify

The ordinance is unchanged since March 2023; no litigation or amendment found through the Dec. 2025 supplement.

Sources and research limits

Carried forward from the October 18, 2026 city research. The explorer separates the operating permit from land-use rights; this is not a new verification of all current city rules.

Use this summary to identify the documents and questions for a property review. A seller's rental history alone does not establish a buyer's permission to operate.

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