To its credit, HPD has put that use in the new rule in conformity with the M-L reform amendments but the wording should be made clearer to read: This misinterpretation is clear when in the narrative before the actual proposed rule changes, the HPD wrote: “Prohibit charges to shareholder and/or tenants’ groups, committees or other shareholder and/or tenants’ organizations for the use of a community or social room for organizational events.” That misinterpretation leaves out the right for cooperator organizations to have events and organizational activities in the lobbies, mail areas, backyards and plazas and in front of the buildings. In fact the intention of the M-L reform amendment and NYS law RPL 230 is to facilitate and allow full use of all common areas for cooperator organizational purposes. The new rule includes this wording §9(5): “.shareholder and/or tenants’ groups, committees or other shareholder and/or tenants’ organizations shall have the right to meet without being required to pay a fee in any location on the premises.”īut the HPD new rule as proposed follows this sentence with a comma which can make it appear that the rule is only eliminating the charge for cooperator organizations to use the community room or other locations for which there has been a charge. To support and encourage democratic co-op practices, the new HPD rule should be clearer that ALL common spaces should be available for use by cooperators and cooperator groups and organizations. HPD should consider extending the limit to 24 months to discourage low bids followed by multiple change orders. Also, the change order process is a mechanism encouraging low bids and then building the cost by multiple change order additional expenses. Many construction projects take longer than one year. The limit to 12-month for notification when a housing company incurs charges from any vendor or service provider that in the aggregate equal or exceed $100,000 is too short. I also welcome the amendments supporting more democracy at M-L co-ops to the Private Housing Finance Law which became law one year ago in March of 2022. I welcome this opportunity to comment on the HPD’s proposed rule changes. I agree with HPD’s having rate of pay and staffing information. I agree with the insertion to the website of the redacted Board contracts and essential information. I agree with all Directors go through essential training with HPD In favor without objection to this ruling. Where it reads: In the event that any Director /Officer, Shareholder, employee, or agent of any housing company shall be directly or indirectly connected with any person, firm, or corporation which may submit any bid or to whom any contract is proposed or awarded shall be part of the minutes and submitted to HPD. I object to having the housing company’s attorney or accountant monitor the election instead have an independent company handle the election process in its entirety. Where it reads: Prohibit the housing company attorney or account from serving as the election monitor. Board Directors and the Managing agent need to be accountable for every expense authorized by them. ” I totally agree with this change and should be enacted without objection. Page# 3 paragraph # 10 Require the Managing agent to notify HPD if the housing company makes payments to and /or incurs charges from any vendor or service provider that in the aggregate equal or exceeds $100.000 in any twelve-month thereafter prohibits further charges to be incurred without the prior written approval of HPD. I object to this unless adequate training or information is given to all employees prior to enacting it. Page # 3 paragraph # 7 – Require the Housing company to remove any of its onsite employees where any such employee has violated the Private Housing Finance Law and/or applicable rules and directives, consistent with any internal grievance procedures -I questioned whether this includes “Union Employees like 32bj ? ” Many are not familiar or knowledgeable in Private Finance Laws and Procedures including Management.
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