Question 1

How often must I file DHCR rent registrations?

Accepted Answer

Every year. New York requires owners of rent-stabilized buildings to file an apartment-level registration (form RR-2A) for each regulated unit annually. The filing window typically runs from April through July.

Question 2

What happens if I miss the registration deadline?

Accepted Answer

You become barred from collecting any rent increase until your registrations are brought current. You also expose yourself to overcharge complaints that can look back four to six years, plus potential treble damages where willful overcharge is found.

Question 3

What is the difference between an IAI and an MCI?

Accepted Answer

An IAI (Individual Apartment Improvement) is an in-unit upgrade that may justify a rent increase for that single apartment. An MCI (Major Capital Improvement) is a building-wide upgrade that may justify increases across every unit. The evidence and approval process differ significantly.

Question 4

How long does a rent overcharge claim look back?

Accepted Answer

Under HSTPA, DHCR can examine the entire rent history available — often back decades — to determine the correct legal rent, but recoverable overcharges are typically limited to six years. Treble damages may apply to the most recent two years where willful overcharge is found.

Question 5

Do I need to register vacant units?

Accepted Answer

Yes. Vacant rent-stabilized units must still be registered annually with the legal regulated rent and a vacant status code. Skipping vacant units is a common error that creates unnecessary exposure.

Question 6

Can I deregulate a unit through high-rent vacancy?

Accepted Answer

No. HSTPA eliminated high-rent vacancy and high-rent/high-income deregulation in 2019. The only remaining paths to permanent deregulation are the original co-op/condo conversion, substantial rehabilitation, and a handful of narrow exemptions.

Question 7

How long does a typical engagement with DHCR Proficiency take?

Accepted Answer

It depends on scope. A single-building annual registration can be completed in a week. A full rent history audit for a portfolio typically runs four to eight weeks. We scope and quote each engagement up front so there are no surprises.

Question 8

Do you work with attorneys on contested matters?

Accepted Answer

Yes. We coordinate directly with our network of rent-stabilization attorneys when a matter requires litigation, hearings, or formal representation. We handle the compliance and documentation work that supports their legal strategy.

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