New Law Imposes Strict Time Limits Requiring Co-Op Boards to Promptly Respond to Purchase Application
On January 29, 2026, the NY City Council passed into law INT-1120-B, the “timings” bill, setting strict and short limits on the time in which co-op boards have to act on a prospective purchaser’s application.
The new law goes into effect on July 28, 2026, and establishes several new requirements in connection with prospective sales:
First, a coop must have a standard application form, which is to be furnished to a prospective purchaser “promptly upon request;”
THE INITIAL APPLICATION SUBMISSION
– Within 15 days of a purchaser’s initial submission of the completed application to the board, the board must provide a written notice to the purchaser or purchaser’s agent:
- acknowledging receipt of the application;
- advising the purchaser whether the application is complete and, if deemed incomplete, the purchaser must be provided with an itemized list of what is lacking, with a citation to the section of the original application setting forth the requirement;
- requesting any additional materials the board feels it requires for “clarification or completion of previously submitted materials.”
– If no acknowledgement is sent, the application will be deemed complete as of the 15th day after the initial submission.
ACTION UPON COMPLETED APPLICATION
– Once an application is complete, the coop has 45 days to issue its determination, which can be unconditional approval, conditional approval, or a denial of the application
– The coop can extend this date once by no more than 14 days by way of email notice to the purchaser or purchaser’s agent. Further extensions require the consent of the purchaser. A prospective purchaser may also request an extension.
– If the coop board does not meet in July and August, the timing requirements are tolled for that time
VIOLATIONS AND ENFORCEMENT
– Violations are subject to civil penalties of $1,000.00 for the first violation, $1,500.00 for the second, and $2,000.00 for a third or subsequent violation.
– The law will be enforced by the Department of Housing Preservation and Development, which is tasked with developing regulations for its implementation prior to the effective date.
The law does not apply to condominiums.
In light of these new requirements, the board should appoint a member to ensure compliance. Additionally, if it has not already done so, a uniform application for prospective purchasers should be adopted.