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Gross overturning

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I have a plan check comment stating that a 1.5 F.O.S. is required for gross overturning on any building shear wall from seismic loads at ASD level.  The project is under the 97 UBC; I have been unable to find any code section that requires a 1.5 F.O.S, the only requirement is for earth retaining walls.  Could anyone please comment on where I can find the section?  Or how they have resolved a similar situation?
 
Thank you