Int. 1120, which comes into effect on July 28, requires co-op boards to confirm by email and certified mail within 15 days whether your application package is complete and, if not, what is missing. If you do not receive confirmation of receipt within 15 days, the application will be considered complete.
Then, 45 days after the board indicates it has received your completed application, the board (or administrator) must notify you or your broker by email whether your application has been approved or denied. A board can also extend that period by a maximum of fourteen days; only one extension is allowed.
Co-op buyers get some control
Until now, there has been no requirement for co-op buildings to trade within a certain time frame, a quirk that makes buying a co-op in NYC a teeth-grinding experience.
“This is a change that boards are paying attention to,” says Peter Massa, partner in the real estate practice at Fox Rothschild. He advises managers on how to implement new protocols to comply with the law and is co-author of Fox Rothschild partner Julie Schechter a guide to the new timeline requirements for reviewing co-op purchases.
Some management companies are not happy with the new fifteen day requirement to acknowledge a completed application. “Their job is to respond very quickly” to applications that can span hundreds of pages, Massa added.
In addition, the new law requires cooperatives to provide standardized applications, with forms, questionnaires and supporting documents and a list of pre-sale requirements, as well as submission instructions.
The new law does not apply to HDFC and Mitchell Lama cooperatives; It also excludes cooperative buildings with fewer than ten apartments; these generally do not use management companies. It does not apply to condominiums, where boards can exercise or waive the right of first refusal to purchase a unit.
One of the three bills concerned cooperatives
Initially, the city council’s Housing and Buildings Committee considered three bills related to cooperatives at the end of 2025. The ‘reasons’ bill, a controversial proposal that would have required cooperative boards to provide an explanation for why they rejected an applicant, and a bill on financial disclosure, did not come up for a vote in the full Council. The latter would have made a lot of financial information about the building and its shareholders available to a potential buyer.
The Council has adopted an amended version of Int. 1120 to establish standardized procedures and deadlines for cooperatives to respond to governance package submissions. Mayor Eric Adams vetoed the bill, but the City Council overrode his veto.
What if a board is absent or does not adhere to the rules?
Boards do not normally meet in July and August and the clock stops for this period, but boards must publish the dates of their summer recess, Massa said.
His advice for boards: Discuss your application process with your attorney and make sure you follow the rules. Tip: take a look at Habitat Magazine new compliance checklist.
If a co-op building fails to comply, fines of $1,000 for a first violation, $1,500 for a second violation, and $2,000 for third and subsequent violations may be imposed. The Department of Housing Preservation and Development is responsible for enforcement.
Massa’s suggestion for a buyer who hasn’t heard from a co-op in 45 days: You could “in theory” take the position that the application has been approved. To be clear, it is a new law, so it has not yet been tested, he added.
And while you may have the option to file a complaint with HPD, keep in mind that this would be a very aggressive way to ingratiate yourself with your future neighbors.
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