Testimony
Basha Gerhards
Executive Vice President, Public Policy
•April 22, 2026
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. An important part of the housing ecosystem we represent is the owners and managers of tens of thousands of rent-stabilized units. Thank you to the members of the New York City Rent Guidelines Board (RGB) for the opportunity to provide our perspective regarding rent adjustments for the city’s rent-regulated apartments as part of this year’s proceedings.
The annual rent guidelines issued by this board are the only systemwide mechanism for aligning rents with rising costs, covering basic apartment turnover expenses, and, by extension, for preserving housing quality in stabilized apartments.
We strongly support tenants receiving aid and support, amongst ongoing affordability pressures, such as through city and state voucher programs. However, long-term housing quality and financial sustainability for stabilized buildings require that rent adjustments keep pace with cost growth, given the current regulatory structure of rent-stabilized housing in NYC.
To help inform the Board’s decision with the most current data available, REBNY commissioned a study led by HR&A Advisors to analyze more current income and expense data and changes since 2019. Based on prior conversations with the Board, staff, and the NYU Furman Center, we made a point of gathering more information on buildings with fewer than 11 units, whose information is not available to the board from their current data pulls from the Department of Finance (DOF). This is the fifth year REBNY has conducted this survey.
The April 2026 TC 201 study [enclosed in the Appendix - NYC Housing Operating Expenses Analysis] includes data for 2025 that was submitted to the City of New York in March 2026. The study was conducted in April of this year with outreach by REBNY and industry partners SPONY and NYAA to the owners and managers of rent-stabilized housing.
This study utilized a longitudinal dataset of 2,533 entries spanning reporting years 2017 through 2025, across approximately 1,025 buildings, to examine rising owner expenses and their impact on income over time. That includes 365 forms from small buildings with fewer than 20 units, including 33 submissions in the 2025 sample from buildings with fewer than 11 units. 66 percent of 2025 submissions came from buildings in the 90 to 100 percent stabilized category.
The latest TC201 data shows that owners continue to face significant operating cost pressure. Taxes remain the largest expense category, while insurance, utilities, and fuel have seen some of the sharpest increases since 2019. Per-unit insurance costs are up 109 percent since 2019, utilities are up 56 percent, and fuel is up 37 percent. While some categories moderated from 2024 to 2025, those shifts should not be mistaken for a return to financial health. Costs in several key categories remain well above pre-pandemic levels, especially for older buildings with less ability to absorb them due to constrained rents and higher rental arrears. In pre-1974 buildings, insurance costs remain far above pre-2019 levels, and from 2024 to 2025, net operating income fell 6 percent. The oldest and most heavily stabilized portions of the housing stock are under the greatest strain.
To keep buildings in good physical condition for the people who live in them, we encourage this Board to take a holistic view in its 2026 guidelines deliberations, one that considers operating expenses, the share of distressed properties, and localized financial pressures. The most recent RGB Income and Expense Study shows that while citywide net operating income (NOI) increased 6.2 percent between 2023 and 2024, the citywide average masks serious geographic disparities. NOI declined 0.1 percent in the Bronx, and outside Core Manhattan, inflation-adjusted NOI rose just 0.9 percent. These borough-level differences highlight growing concerns about the long-term financial sustainability of stabilized housing across much of the city and the continued bifurcation in the financial futures of pre and post 1974 rent stabilized housing. From 2023 to 2024, costs rose 4.9 percent in 100 percent stabilized buildings, while rent collections rose 3.8 percent and NOI rose just 2.4 percent. Now more than ever, the RGB has a responsibility to ensure rent adjustments do not fall behind expense growth.
Core Manhattan’s NOI must also be viewed in context. Many of those properties include market-rate units because of the way they were developed and financed, which makes them structurally different from older stabilized buildings outside Core Manhattan and those 100% stabilized and affordable projects subject to city, state and federal programs. The RGB’s own report notes that post-1974 buildings generally entered rent stabilization because owners received tax benefits, and those post-1974 properties accounted for just 9 percent of buildings and 16 percent of units in their RPIE analysis. These newer Manhattan Core properties carry higher rents due to elevated development costs and have higher labor costs as a requirement of the programs that built them. As a matter of practice, to remain competitive for those market-rate rents, those buildings will also have higher routine maintenance costs, to maintain accessory spaces such as amenity rooms, and employ more building service workers. They also generate substantial one-time tax revenue from construction and financing, which further distinguishes them from the rest of the stabilized housing stock.
Unlike the story for this smaller segment of newer buildings, the TC201 data shows that many owners, especially of older, more highly stabilized buildings, are operating under mounting financial pressure. We can understand why these conditions are attributed to bad actors. However, the City’s housing challenges are not explained by broad claims about “bad owners” alone. Recent REBNY research shows that the most serious violations and evictions are highly concentrated in a relatively small share of buildings, while most buildings do not show those same severe patterns. The Board should not adopt a rent freeze that risks worsening those conditions.
Lastly, we often in these proceedings discuss the need for and availability of data to make decisions. We believe both DHCR and DOF must continue to improve access to critical, already collected data by the agencies on rent-stabilized housing, including regular publication of building-level registration data with stabilization percentage by quartile and ZIP code-level data on vacancies and IAI activity. Better access to this data would help the Board and the public evaluate the health of the stabilized stock more consistently. We would encourage the board, for example, to request the 2025 TC 201 forms for those buildings with less than 11 units for next year’s proceedings. In the interim, we hope the board will consider the points we raised today and the spirit in which this data is collected, which is to provide real-time information.
As long as policy continues to limit revenue while property taxes keep rising, we will continue to see further erosion in the quality of the rent-regulated housing stock and worsening conditions for the New Yorkers who live in these apartments. We urge the Board to adopt guidelines that reflect the financial realities facing large swaths of rent-stabilized buildings today and ensure the long-term health of this critical segment of the city’s affordable housing.
Thank you again for the opportunity to present the 2026 TC201 survey and offer this testimony.
CONTACT:
Basha Gerhards
Executive Vice President, Public Policy
Real Estate Board of New York
bgerhards@rebny.com
Henry Perez-Tlatenchi
Senior Data and Policy Researcher
Real Estate Board of New York
hpereztlatenchi@rebny.com