Key Points
- Standardized applications – The package must include forms, questionnaires and supporting document requirements as well as transfer requirements.
- Timelines for acknowledging submissions – Boards must acknowledge submissions and state whether they are “complete” within 15 days by email and registered mail.
- Timelines for review – The Board must review the application within a defined period.
Effective July 28, 2026, cooperatives face new requirements governing the way in which they process applications to purchase apartments.
As many of you know, New York City Council held hearings concerning three proposed bills relating to cooperatives. The “reasons” bill and the financial disclosure bill did not come to the full Council for a vote. The Council adopted a modified version of Int. 1120-2024 to establish standardized procedures and deadlines for cooperative corporations to act in response to submission of a package. While then-Mayor Eric Adams vetoed the bill, City Council overrode his veto and the law goes into effect on July 28, 2026.
Cooperatives will want to work with their legal counsel and managing agent to review and update their application package requirements, disclosures and procedures based on the new law.
What must be included in the application package?
Cooperatives must have a standardized written application package that includes forms, questionnaires and supporting document requirements. A cooperative must also provide purchasers with its “transfer requirements,” which is a complete list of requirements for the sale as well as instructions for submission. The application and transfer requirements must be delivered to a purchaser and seller “promptly” upon request.
What are the processing timelines?
Within 15 days after receiving an initial and any subsequent application submission, the board (typically through the managing agent) must send a written acknowledgment by email and registered mail stating whether the application is “complete” and, if not, what items are missing, with a reference to the application requirement. Boards may also request additional materials for clarification. If no acknowledgement is sent within the 15-day period, the application is deemed complete.
Within 45 days after the board acknowledges a completed application or an application is deemed complete, it must notify the purchaser or agent, via email, whether consent is granted unconditionally, granted with conditions or denied. The board may unilaterally extend the 45-day time period once, for no more than 14 days, provided it notifies the purchaser. A purchaser can also agree to extend the date. The board may request additional materials for clarification or completion within the time for determination, and we await guidance on whether that will act as a toll or an extension.
What happens during the summer if the board is in recess?
Time periods are tolled during the “summer recess period,” which is defined as the time during July and August when the board does not typically meet. To take advantage of the toll, boards must maintain a notice identifying the summer recess period and noting when the recess is deemed to terminate.
Are there penalties?
In the event a corporation is in violation of this law, civil penalties may be imposed. They are $1,000 for a first violation, $1,500 for a second and $2,000 per violation thereafter. The Department of Housing Preservation and Development is charged with enforcement.
The law excludes certain regulated cooperatives and those with fewer than ten apartments.
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