The City Council Committee on Housing and Buildings regarding the Mayor's Housing Plan

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The Real Estate Board of New York (REBNY) is the City’s leading real estate trade association representing commercial, residential, and institutional property owners, builders, managers, investors, brokers, salespeople, and other organizations and individuals active in New York City real estate. REBNY appreciates the opportunity to provide testimony at today's oversight hearing on the Mayor's Housing Plan and several housing-related bills.

The Mayor's Housing Plan (Oversight)

REBNY supports the Administration's efforts to increase housing production and is encouraged by many of the reforms outlined across the Mayor's Housing Plan. At a time of acute housing scarcity, policies that make it easier, faster, and less expensive to build and modernize housing are essential. The reforms identified in the SPEED and Block-by-Block reports have the potential to address the longstanding barriers that delay projects and increase costs. We particularly support efforts to streamline permitting and inspections, reduce duplicative requirements, advance rezonings and transit-oriented development, facilitate office-to-residential conversions, modernize building and construction codes, improve the affordable housing and voucher lease-up processes, and strengthen interagency coordination and project management. As the Administration moves these initiatives forward, it must ensure they are adequately staffed and funded, and carefully evaluate any proposal that could counteract these goals by increasing construction costs, complicating project underwriting, or making affordable housing harder to finance.

We also urge the Administration to apply the same focus on efficiency and coordination when it comes to supervising the operation of the City's existing housing stock. Ultimately, responsible housing providers and tenants share the same goal: safe and well-maintained housing where issues are identified and resolved quickly. The City should build systems that make it easier for tenants to raise legitimate concerns, for owners to understand and comply with requirements, and for all parties to resolve problems efficiently. In addition to strengthening enforcement, the Administration should prioritize measures that help owners address violations in a timely manner and ensure owners are not unjustly penalized when tenants refuse access to address issues. REBNY has long advocated for this type of coordination, including, for example, through coordinated inspections for voucher-holders, where poor communication leaves apartments vacant, delays housing for tenants, and creates unnecessary administrative burdens for owners.

A substantial gap in the housing plan is a lack of focus on how projects will be financed. Building new and re-investing in existing housing requires attracting capital that lenders and investors do not have to put into New York City real estate. For this reason, the plan must ensure that financing tools are available for all types of housing at the scale necessary to address the city’s needs and that the administering agencies are appropriately resourced to process applications.

We encourage the Administration to continue pursuing a practical, process-oriented approach to solving the housing crisis, which will require reducing the barriers to building new housing while also making the systems governing existing housing work better for everyone involved. By pairing meaningful production reforms with better communication, coordination, and targeted enforcement, the City can deliver the outcome owners, tenants, and the Administration all want.

BILL: Intro 0178-2026

SUBJECT: Establishing an office of conversion assistance

SPONSORS: Council Members Epstein, Louis, Marte, Hanif, Caban, Morano

This bill would establish an Office of Conversion Assistance to provide technical assistance to developers and owners seeking to convert non-residential space into residential units, maintain an online portal for this purpose, and coordinate with agencies on conversion-related issues.

REBNY supports efforts to make the City’s building conversion process more transparent, coordinated, and easier to navigate. Converting underutilized commercial properties to residential use plays an important role in expanding the City’s housing supply, but owners and developers must often navigate requirements across multiple City agencies, each with its own processes, timelines, and jurisdiction. Intro 0178 could help address some of these challenges by creating a centralized resource on the conversion process and a point of coordination among relevant agencies. An office that can help clarify requirements, identify appropriate agency contacts, and facilitate communication across agencies could provide real value to property owners and developers undertaking complicated conversion projects.

That said, a new office should not inadvertently become another layer of bureaucracy in an already complicated approval process. Its mandate should be clearly defined and focused on coordination and technical assistance, not on duplicating the responsibilities of existing agencies or adding new discretionary requirements. We also encourage the Council to consider how this proposal builds upon the City's prior work in this space, including the Office of Conversion Accelerator, so that the City leverages existing expertise and institutional knowledge rather than recreating functions that already exist elsewhere in government.

BILL: Intro 0649-2026

SUBJECT: Requiring the posting of a sign identifying the owners of multiple dwellings

SPONSORS: Council Members Restler, Krishnan, De La Rosa, Louis, Brewer, Caban, Nurse

This bill would require the owner of a multiple dwelling to post a sign identifying the owner or owners of the multiple dwelling. Where the owner is a corporation, limited liability company, or partnership, the sign would need to identify the relevant beneficial owners or partners.

REBNY has serious concerns with Intro 0649, which would require the public disclosure of information about the individuals behind privately held ownership entities by posting such information in a building lobby.

Existing City requirements require that information be posted in a building lobby that identifies the owner, managing agent, and agent designated by the owner for the collection of rental payments if different from the managing agent. Existing requirements also require posting the name and contact information for the superintendent or janitor responsible for maintaining the property on a day-to-day basis. These sensible regulations ensure tenants can identify the building owner and who to contact to address issues that may arise.

This legislation goes further and would impose significant additional disclosure obligations on property owners. This sweeping mandate raises serious privacy concerns for owners as it would subject private individuals to disclosure for limited public purposes. For LLC’s, these disclosure obligations would extend to all beneficial owners, regardless of whether they exercise any control over the building and without regard to whether they are minors or other individuals who may have a legitimate reason to protect their names and contact information from disclosure. In the case of a building owned by a publicly traded corporation, the legislation appears to require disclosure of all shareholders in the public corporation, for which compliance would be impractical and serve no public purpose.

The City already has mechanisms to obtain ownership information for law enforcement investigations or other legitimate public purposes. Requiring owners to post identifying information publicly in the lobby would expose them and their families to unwanted contact, harassment, or other inappropriate conduct. Such disclosure is not warranted as existing rules already require disclosure of the owner and managing agent to ensure that owners know who owns their building and who to contact when problems arise.

Given these concerns, REBNY does not believe the additional public disclosure mandated by this version of the legislation justifies the privacy violations and compliance obligations it would impose on property owners.

BILL: Intro 0717-2026

SUBJECT: Requiring the Department of Buildings (DOB) to inform property owners of permit sign-off requirements

SPONSORS: The Public Advocate (Mr. Williams) and Council Members Salaam, Louis, Brooks-Powers, Hankerson, Epstein, Schulman, Nurse, Morano, Paladino, Vernikov

This bill would require DOB to notify property owners with open permits that the permits must receive DOB sign-off. This notification would also inform the property owners of the consequences of failing to obtain sign-off.

REBNY appreciates the intent behind Intro 0717. Clear, timely information about permit sign-off requirements could help property owners and applicants better understand what is necessary to close out construction work and obtain final approvals. In particular, the proposal could improve permit close-out compliance among homeowners and smaller property owners who may be less familiar with the permitting process. Notifications could also be useful where permitted work, such as a tenant buildout, is managed by a tenant or other party responsible for obtaining permits and scheduling required inspections. To be effective, however, notices should provide clear, actionable information about applicable sign-off requirements, outstanding inspections, and the consequences of failing to close out a permit.

Further, the bill should be structured to avoid unnecessary administrative burdens or a notification process that does not account for the realities of complex construction projects. Notices should be timed around meaningful inspection, expiration, or close-out milestones and provided to both the property owner and permit applicant, where appropriate. The Council should also consider whether DOB has the capacity and technological infrastructure to implement an automated notification system and absorb any resulting increase in inspection and sign-off requests without creating additional delays.

Finally, the bill's effectiveness should not be measured simply by whether DOB administers more notices. Providing information about outstanding requirements will have limited value if owners and applicants are still left to navigate lengthy or unclear processes to obtain the necessary sign-off. The City should therefore pair clear notifications with greater accountability for timely inspections and permit close-out once all substantive work is complete. The bill should also clarify that an owner or applicant's underlying obligation to close out a permit does not depend on receiving a DOB notification, so that missing or inaccurate notices do not create disputes regarding reinstatement fees, penalties, or other enforcement actions. With these adjustments, REBNY believes Intro 0717 could help improve permit close-out compliance while ensuring that the notification system is practical, targeted, and aligned with DOB's operational capacity.

BILL: Intro 0860-2026

SUBJECT: The inspection and enforcement of street numbers on buildings

SPONSORS: Council Members Brewer, Louis, Aldebol, Morano

This bill would authorize the Department of Housing Preservation and Development (HPD) and the New York City Fire Department (FDNY) to inspect buildings for required physical street numbers during their routine building inspections. If either agency finds that the building is noncompliant, it may take enforcement actions consistent with the rules and regulations established by the Department of City Planning (DCP).

REBNY supports the intent behind Intro 0806, as clearly visible street numbers serve an important public safety function by allowing emergency responders, delivery personnel, and residents to identify a property. However, we have concerns about the proposed enforcement structure and whether HPD and FDNY are the appropriate agencies to assume these additional responsibilities. DCP establishes the underlying street number and signage requirements, which fall outside HPD's and FDNY's core functions. In particular, requiring FDNY to investigate non-life-threatening signage complaints could divert limited resources from fire-safety inspections and other high-priority public safety responsibilities. Allowing complaints to be directed to either HPD or FDNY also creates potential ambiguity regarding which agency is ultimately responsible for investigation and enforcement, while requiring coordination among DCP, HPD, and FDNY could create an unnecessarily fragmented enforcement process.

We encourage the Council to consider whether DOB would be a more appropriate agency to oversee these requirements, given its existing role in building inspections and enforcement. DOB also already has enforcement powers for other signage requirements such as those for POPs established by DCP. More broadly, compliance should not require property owners or the City to navigate multiple agencies to address what should be a relatively straightforward issue. We also urge the Council to ensure that minor deficiencies in street number displays are not treated as an opportunity to impose overly severe fines or other punitive measures. Before this legislation advances, we recommend that the City assess which agency is best positioned to assume these responsibilities and whether it has the capacity and resources to do so without affecting its core functions. The Council should also ensure that the implementation timeline provides sufficient time to establish procedures, train personnel, and develop an appropriate 311 referral process.

BILL: Intro 0905-2026

SUBJECT: Giving qualified entities a first opportunity to submit a statement of interest and a first opportunity to purchase certain properties

SPONSORS: The Brooklyn Borough President (Mr. Reynoso) and Council Members Nurse, Epstein, Caban, Santosuosso, Brooks-Powers, Aviles, Stevens, Justin Sanchez, Pierina Ana Sanchez, Gutierrez, Hanif, Brewer, Hudson, De La Rosa, Aldebol, Restler, Schulman, Farias, Osse, Thomas-Henry, Won, Joseph, Krishnan, Abreu, Encarnacion, Lee, Wilson

Intro 0905, also known as the Community Opportunity to Purchase Act (COPA), would give qualified nonprofit organizations enhanced opportunities to purchase certain multifamily residential buildings before those properties can be sold to other buyers. The bill would require owners of covered properties to notify HPD and other eligible nonprofit purchasers before proceeding with a sale. Qualified entities would then have a designated period to express interest, conduct due diligence, and submit an offer. If an owner does not proceed with a nonprofit purchaser, the bill would also provide a right of first refusal through an "offer subject to match" process that would allow a qualified entity to match certain third-party offers.

Intro 905 includes meaningful changes from prior versions of COPA. Most significantly, the bill now applies to a substantially narrower universe of projects by excluding certain 421-a buildings and buildings with more than 100 units subject to affordability restrictions, while also amending the distress criteria from an average of one Class B or C violation per unit to three. The overall transaction timeline has been shortened from 160 days to 145 days, and HPD's authority to extend deadlines has been narrowed to the offer period. These changes are significant improvements that help to ensure the legislation is appropriately tailored to buildings appropriate for this type of process and that the process will not inadvertently undermine transactions.

Building on these improvements, additional changes can ensure that the acute intervention into property transactions is targeted and operates through a clear, predictable process. Specifically, we encourage the Council to modify the bill to:

Establish reasonable limits on lawsuits and penalties. The bill authorizes private civil actions and allows courts to award injunctive relief, attorneys’ fees, expert witness fees, and other costs, with no statute of limitations and no cap on damages or penalties. We urge the Council to add a defined limitations period for private actions and reasonable ceilings on damages and fees, so that owners and lenders can price and close transactions without exposure to open-ended liability.

Clarify the “offer subject to match” timeline. The bill’s right-of-first-refusal process does not specify when the matching period begins, how it is triggered, or when it definitively closes. We urge the Council to set explicit start and end dates for matching rights, tied to unambiguous triggering events, so that disputes over deadline calculations do not stall deals.

Limit HPD’s ability to expand COPA administratively. The bill gives HPD rulemaking authority to establish additional criteria for covered buildings. The universe of properties subject to COPA is a significant policy choice that the Council should make through legislation, not expanded later through agency rulemaking without further legislative input.

Set firm limits on timeline extensions. While the bill narrows HPD’s extension authority to the offer period, it does not cap how long or how many times that period can be extended. We urge the Council to add an explicit maximum extension to provide certainty for all parties involved in the transaction.

Exempt affordable homeownership conversions and HDFC transactions. As drafted, the bill would affect certain homeownership conversion projects and HDFC transactions, which already serve affordability and homeownership goals and are typically subject to their own public review and approval process. These transactions should be explicitly excluded to avoid duplicative process and delay.

Create an off-ramp for buildings that are no longer distressed. The bill has no mechanism for a building to exit COPA coverage once the distress conditions that triggered coverage have been cured. We urge the Council to add a clear, administrable process for owners to demonstrate compliance and remove a property from COPA once conditions are resolved.

BILL: Intro 1015-2026

SUBJECT: Extending the J-51 tax abatement for alterations and improvements to certain multiple dwellings

SPONSORS: Sanchez, Lee, Joseph, Gennaro, Marte, Epstein, Hudson, Krishnan, Nurse, Schulman, Sanchez, Hanif, Dinowitz, Osse, Abreu, Louis, Farias, Caban, Ung, Felder, Brewer, Hankerson

This bill would implement recent New York State changes to the J-51 tax abatement for certain alterations or improvements, including projects completed on or after June 30, 2026, and before June 30, 2036. Reforms include expanded eligibility for co-ops and condos where the assessed value of an apartment is $60,000 or less, and increasing the maximum benefit to 100 percent of total certified reasonable cost for eligible buildings. HPD would establish and regularly update a certified reasonable cost schedule.

REBNY supports Intro 1015. Property owners need effective preservation tools to make necessary improvements to residential buildings, including modernization and retrofit projects needed to comply with local law. While J-51 has been renewed over the years, its overall benefit structure has changed little even as additional requirements have been added. As a result, program participation has declined, as the costs, compliance obligations, and potential penalties associated with participation can outweigh the benefits for otherwise eligible buildings. We are encouraged that the changes authorized by this legislation will help increase program uptake and make J-51 a more effective tool for preserving the City's aging housing stock.

As the program is implemented, it is critical that HPD accurately and regularly update its certified reasonable cost schedule to reflect current construction and rehabilitation costs. The schedule should account for the full range of expenses associated with completing eligible work, including soft costs such as design and permitting, as well as significant capital work owners are already required to undertake, including energy, facade, resiliency, and other code-driven improvements. Ensuring the benefit accurately reflects the real cost of necessary work will be essential to making the expanded J-51 program an effective incentive for owners to utilize over the next decade.

FILE #: T2026-1780

SUBJECT: Authorizing electronic registration of dwellings with HPD

SPONSORS: Banks

This bill would allow property owners who need to register their property with HPD to do so through an electronic registration system. Signatures obtained this way would be deemed sufficient for registration purposes, but property owners would still have the option to submit written signatures for at least 180 days.

REBNY supports this bill. Owners regularly encounter unnecessary administrative barriers when using HPD's Property Registration System, which can impact an owner's ability to proceed in Housing Court or secure a building permit. Modernizing registration to allow electronic submission is a straightforward, low-cost fix that reduces paperwork and administrative burden for HPD staff.

Thank you for your consideration of these points.

CONTACT:

Kate Goldmann

Senior Housing and Planning Analyst

Real Estate Board of New York