On June 13, 2024, DHCR issued Operational Bulletin 2024-1 titled “Rent Registration Filing Deadlines and Penalties for Delinquent Registrations.” This operational bulletin responds to the passage of Chapter 760 of the Laws of 2023 (Bill A6216B/2980C), effective December 22, 2023.
Key Points of Operational Bulletin 2024-1
Reminders for Building Owners
- Initial Registrations: Owners must file initial registrations within ninety (90) days after an apartment becomes subject to rent stabilization.
- Annual Registrations: Owners are required to register their rent-stabilized apartments annually with DHCR by July 31st of the registration year.
New Penalty Provisions
The most notable feature of DHCR’s Operational Bulletin is the new law authorizing DHCR to fine building owners $500 per unregistered unit, per month.
Enforcement Measures
According to the Rent Stabilization Law § 26-517(e) and the Emergency Tenant Protection Act § 12-a(e):
- Notice of Delinquency: Failure to file annual registrations will trigger a notice of delinquency from DHCR. This notice will be sent to the owner via electronic mail and mail to the address listed in the owner’s most recent registration statement.
- Fines for Non-Compliance: If the building owner fails to address the notice of delinquency, DHCR has the authority to fine the building owner $500 per unregistered unit each month.
Compliance Recommendations
It is important that owners ensure:
- Their buildings’ DHCR registration statements are up to date (See DHCR Form RA-44).
- There are no annual apartment registrations missing from the DHCR registration statements.
Assistance from BBG
BBG is happy to assist our clients in all aspects of building registrations. For more information or if you have any questions, please reach out to your BBG attorney of record.
Written by Diana R. Strasburg, Partner, Administrative Law Department