Comments

Lyndsey Anderson Fri, 02/22/19 - 11:08 I oppose HPD the proposoal not to allow households from internally transferring to bigger apartments if the applicant's household income exceeds 125% of the bigger apartments income limit. I think this regulation has potential devastating effects the integrity and longevity of individuals and families in our community for those who make nominally more than 125% as those of us marry, or grow our families. I think this proposed rule has the potential to result in a transient community of people who know they will never build families here and not invest emotionally, physically and/or an influx of people on the waiting list to immediately move into large apartments that might not immediately invest in the community in the way that those who have “grown-up here” would...or, worst of all, a community who doesn’t aspire to do more and be more, because their higher income would prohibit them from a transfer. Overall, I think this new rule would damage the longevity of families who are still moderate income remaining in the buildings in which they reside if their family size changes.

Craig Leibner Fri, 02/22/19 - 17:27 I strongly support the HPD proposed rule change regarding Feasibility Studies for Mitchell-Lama Coops which will require a 2/3 super-majority vote to authorize expenditure of coop funds on a feasibility study. The current 50% simple majority requirement is not sufficient to prevent Mitchell-Lama coops from going down the destructive path towards privatization. Additionally, new HPD rules governing Mitchell-Lama coops should require funds from a feasibility study to come from a special assessment on shareholders and not from general operating funds or reserve funds.

Anne Abbott Fri, 02/22/19 - 18:54 I support the proposal to increase the requirement from a majority to two-thirds of the dwelling units to approve the proposed expenditure of funds for the preparation of a feasibility study ad also expressly require that such a study include financial estimates comparing privatization with conversion to an Article XI housing development fund company development.

Courtney McQuade Fri, 02/22/19 - 19:46 I am strongly for this change. Two thirds majority should be needed to change a Mitchell-Lama to a private building. This program benefits so many families by providing affordable housing and we should not be able to change over so easily. People need this program and end up on the street when they can no longer afford their home after privatization. Please help us keep our homes affordable!!

Ellen Sheehy Sat, 02/23/19 - 6:33 I strongly support the HPD Proposal regarding Feasability Study for Mitchell-Lama coops to require a 2/3 majority vote to authorize expenditure of Coop funds on a Feasability study. Funds should derive from a special assessment on shareholders and not from general operating funds or reserve funds.

Lyndsey Anderson Mon, 02/25/19 - 14:44 I strongly support the HPD proposed rule change regarding Feasibility Studies for Mitchell-Lama Coops which will require a 2/3 super-majority vote to authorize expenditure of coop funds on a feasibility study.

David Tambini Mon, 03/4/19 - 7:12 I'm a member of Keep Our Building Affordable, KOBA, which was formed by concerned shareholders of the Rosalie Manning Mitchell-Lama cooperative in response to the threat of privatization and I want to express my support for the HPD proposed rule change to the Mitchell-Lama rules, Section 3-14 (i) which would require a two-thirds (2/3) majority vote of approval by shareholders before a Mitchel-Lama housing company could expend funds to investigate privatization. Since two-thirds (2/3) majorities are required to both approve an offering plan and to proceed with dissolution and/or reconstitution, it makes sense that money should be spent on the process only if it enjoys the overwhelming support of the shareholders. I want to thank you for proposing this change. It will certainly help us in our struggle to keep Rosalie Manning available for middle income New Yorkers.

Arona Testamark Wed, 03/6/19 - 17:36 I agree with the lottery for the units that become available through the opening of a waiting list must be advertised through the New York City Housing Connect/Mitchell-Lama Connect lottery system or any successor program administered by HPD to market vacant Mitchell-Lama units.

Alex Simon Sun, 03/10/19 - 14:24 Having the hearing between the hours of 3 and 5pm during the weekday unfairly prohibits many of who work during those hours and can't take the time off to attend. It would be more inclusive to hold this hearing after 6pm on weekdays or on a weekend so more working Mitchell-Lama co-operators could attend. I support the HPD proposed rule change regarding Feasibility Studies for Mitchell-Lama Coops which will require a 2/3 super-majority vote to authorize expenditure of coop funds. The cost of living in New York continues to skyrocket, and incomes that might be considered high don’t go as far as they used to. In addition to our maintenance fees, many of us have fixed expenses including student loans, transportation/car expenses and rising healthcare costs. I also strongly oppose HPD the proposal to not allow households from internally transferring to larger apartment if the applicant's household income exceeds 125% of the larger apartment’s income limit. I think this regulation will have major effects to the integrity and longevity of individuals and families in our community; especially for those who make slightly more than 125% as we marry and/or grow our families. This proposed rule limits the potential for shareholders to better themselves financially and emotionally in our buildings. I second what Lyndsey Anderson wrote that enacting this amendment will create “a transient community of people who know they will never build families here and not invest emotionally, physically and/or an influx of people on the waiting list to immediately move into large apartments that might not invest in the community in the way that those who have “grown-up here” would… or worst of all, a community who doesn’t aspire to do more and be more, because their higher income would prohibit them from a transfer.” Considering a potential surcharge increase would be a more realistic option. Throughout any given time, an individual’s/family income can fluctuate based on employment status. Our current socio-political climate is one of unease and uncertainty. Many economists and financial experts predict a recession in the coming years. A family that might make slightly more than the income requirements are still outside of the potential for an apartment for market value. The Mitchell-Lama program was created to help keep middle income families in urban areas. By enacting this amendment now, during this time, offers no protection to middle income families who are the most likely to suffer during an economic downturn. I also oppose the amendment limiting the lateral transfer within your existing building. A person might want to move closer to a family member, friend or caregiver within the building or move away from a troublesome neighbor.

Ellen Sheehy Mon, 03/11/19 - 6:28 Feasability monies should come from a special assessment, not from building reserves

Ellen Sheehy Mon, 03/11/19 - 6:56 Feasability monies should come from a special assessment, not from building reserves

Andrew Seville Mon, 03/11/19 - 8:49 I support the HPD's proposed rule change regarding Feasibility Studies for Mitchell-Lama Coops which will require a 2/3 super-majority vote to authorize expenditure of coop funds on a feasibility study. The current 50% simple majority requirement is not sufficient to prevent Mitchell-Lama coops from going down the destructive path towards privatization. Feasibility Studies are costly. New HPD rules governing Mitchell-Lama coops should require funds for a feasibility study to come from a special assessment on shareholders who vote for the study and not from general operating funds or reserve funds.

David Schmerler Tue, 03/12/19 - 14:46 I strongly support the HPD proposed rule change regarding Feasibility Studies for Mitchell-Lama Coops -- which will require a 2/3 super-majority vote to authorize expenditure of coop funds on a feasibility study. The current 50% simple majority requirement is not at all sufficient to prevent Mitchell-Lama coops from going down the destructive path towards privatization. Also, new HPD rules governing Mitchell-Lama coops should require funds for a feasibility study to come from a special assessment on shareholders. Such funds should not come from general operating funds or reserve funds.

ann bluestein Tue, 03/12/19 - 16:05 I strongly oppose the change the rule of a 50% majority to a supermajority of two third to approve a feasibility study. As a resident of a building that is looking into privatization I've become aware of the underhanded tactics that some residents will go to to thwart the majority of residents wishes to look into the pros and cons of staying in the ML program or leaving. As I've told many of my neighbors I have no plan to move. I'm not looking for a financial return. I would like to leave the program because of the government oversight of the building and the arbitrary implementations of the regulations. This new proposal is an example of the reason to leave the program. the opinion and push to change the rules in the middle of the game is ridiculous. Of course, it is in HPD's best interest to keep buildings in the program. We all know that there are many tenants who do not play by the rules. Non residents, but relatives get vacant apartments rather than on the legitimate list. Why hasn't there been follow through on this regulation? I also feel that there is no incentive for tenants to upgrade their apartments if we stay in ML. I have put a substantial amount of money into my apartment and that money can never be recouped under the present rules. If apartments aren't upgraded the building itself will deteriorate. When I moved into my apartment 10 years ago it was basically uninhabitable. I spent years saving the money just to have a kitchen. The asbestos tiles were corroded and dangerous . I was just able to replace them at a considerable cost which cannot be recovered. In addition the basic premise of ML was to upgrade a deteriorating neighborhood. Many original people in the neighborhood were left without homes and had to leave their neighborhood. The people in initially moved into ML have done their job and should be able to follow the original (standing) regulations and vote by simple majority. Once again the government is trying to save their own jobs and standing by kowtowing to the shrinking number of residents who don't want change.There are residents in my building who will go to any lengths to prevent going private and enlist politicians and the agency itself to wear down the residents who want to have more of a say in their homes future.

David Stronger Tue, 03/12/19 - 18:11 I disagree with the proposed rule change to require a 2/3 majority to initiate a feasibility study. That is a nearly impossible hurdle. Many cooperators don't vote or involve themselves in the building at all. Many are elderly & don't understand what's being voted on. (There are of course many well informed elderly, but sadly it is not all of them.) Some cooperators are simply uninformed & fall prey to false rumors. Many people in my building believe they can not afford to buy their coop were we to reconstitute. Despite the fact that they already own it & would not pay any price. The feasibility study is their 1st chance to get factual information. And the Red Herring, Black Book & final decision to reconstitute already require 2/3 votes. Becoming more informed (through a feasibility study) should not be discouraged.

Ellen Sheehy Wed, 03/13/19 - 17:15 I support wholeheartedly HPD Proposal re Feasability Study for Mirchell-Lama to REQUIRE 2/3 Majority vote to aiw expenditure if Coop funds for Feasability. Funds should derive from Special Assessment and not from general operating fund nor Reserve funds

Ellen Sheehy Wed, 03/13/19 - 17:28 I too am a member of Keep Our Building Affordable. KOBA My home at Rosalie Manning has been the best 22 years, building is well-kept by terrific staff. I could not ask for better neighbors, seniors, young families with children, who will have opportunities to receive the best educations. All of us here, si fortunate, would like to see HPD require 2/3 majority vote re Feasability Study, to allow expenditures of Coop funds for Feasability. Reserve funds, general operating funds should not be used, should come from special assessment.

Irene Symmonds Thu, 03/14/19 - 9:20 I am anti-privatization, these buildings were made for people that can’t afford a pvt market rate coop. These are families, elderly, single ppl that finally can feel like it’s HOME. And by changing that rule, then those ppl are shaken to the core. Many of us come from modest backgrounds who worked hard and caught a break by getting into a ML building. And this vote for Feasibility Studies is a vote to take away that security. I am in Rosalie Manning I say no to privatization and feasibility studies!

Jay Hauben Thu, 03/14/19 - 23:34 At the RNA House M-L co-op in the UWS, in recent votes, the cooperators who favor staying in the M-L program numbered more than 1/3 while those who favor considering privatization numbered less than 2/3. Those who favor staying in M-L will likely be enough to defeat any red herring allocation vote. But up until now that number would not necessarily be enough to defeat a feasibility study allocation vote. Without the proposed change, RNA might have annual allocations for a feasibility study followed by annual defeats of allocations for a red herring. That would be a waste of co-op money but also the source of continuous tension among the the RNA cooperators. RNA House is not the only M-L co-op that has such a division of sentiment. A rule that uses the same required 2/3 majority to pass all three necessary dissolution votes is likely to remove the possibility of multiple feasibility studies in close succession. But also requiring a 2/3 super majority is justified because the change toward which the votes are going would be an involuntary major structural change for those who want to stay in a M-L co-op. I support changing the rule so that all three votes, to allocate money for a feasibility study, to allocate money for a red herring and to dissolve and reconstitute should require 2/3 or more affirmative votes to pass.

Jay Hauben Thu, 03/14/19 - 23:41 Why should there be a 2/3 rule rather than just a simple majority for all three necessary votes toward privatization? In general, 2/3 or supermajority rules are adopted by political bodies and organizations to ensure that major changes like constitutional amendments are only taken with great care and with substantial support. In the US, changing the constitution, overriding a president's veto or ratifying a treaty all require supermajority votes in favor. Changing the structure of a corporation can have major consequences. The 2/3 rule is a precaution that such a major change should not be taken lightly or easily. But also, changes may affect stockholders or shareholders differently. A supermajority rule is considered necessary when an action might alter the rights of a minority. Everyone living at a M-L co-op has chosen to join a limited equity co-op, which means a not-for-profit co-op. That was known when they put themselves on the waiting list and all the time they lived at their co-op. Acceptance at a M-L co-op is on the premise that this is what you are offered and are getting into. For many, cooperative living together not based on money or profit considerations has worked well. Changing that reality for those who do not want to change their limited equity, not for profit way of life would be a major blow to those people. Their right to continue to live as they and their neighbors chose should not be taken away easily or to satisfy some or even half of their neighbors. The 2/3 rule is there to insure that at least that many of their neighbors are willing to make the change despite the sacrifice it will be for those who prefer living without considerations of profit. All three votes are part of the same process toward privatization so I support adding to the HPD M-L rules that the first step require an affirmative vote of 2/3 or more of the dwelling unit occupants, 1 vote per unit.

Chad Marlow Fri, 03/15/19 - 16:51 HPD should not implement the proposed rule to "increase the requirement from a majority to two-thirds of the dwelling units to approve the proposed expenditure of funds for the preparation of a mutual housing company’s feasibility study." While requiring a super-majority vote to withdraw from the Mitchell-Lama program arguably makes sense to protect minority shareholder rights, a super-majority vote should not be required to obtain information upon which to make an informed judgment. It should be the goal of HPD to provide tenants with information they desire where a majority of the tenants express an interest in obtaining it, not to use restrictive voting procedures to maintain their ignorance. I am not aware of any other voting procedure at any level of government where multiple super-majority votes are required to take action. Such biased voting requirements essentially disenfranchise tenants and are highly inappropriate.

Sam Moskowitz Mon, 03/18/19 - 12:18 have lived in Mitchell-Lama for almost 30 years and currently serve as a board member. While most of these new rules seem positive, I strongly urge you to reconsider the following two as their unintended consequences may outweigh their benefits: 1. Specify that current tenant/cooperators will always be given priority to move to a smaller unit, but that current tenant/cooperators will now only get priority for the first three out of every four apartments that become available for moving to a larger unit. - This rule will result in overcrowding. Our complex has very few 3br apartments and families often wait longer than ten years for an internal transfer. This rule change would add several more years wait time for these families. I do not oppose this rule for transfers up to a 1br or 2br, as there are many more units of those sizes available. Disclosure: I have two children but am not on the list for a 3br as they are both of the same sex. 2. Prohibit individuals convicted for crimes involving theft from serving on a mutual housing company’s board of directors. - This seems like a well-intentioned rule but it is both a privacy issue and is an inefficient and ineffective use of limited resources. Who conducts these background checks? Who has access to the results? Why specifically only theft and not violent or other serious crimes? Mitchell-Lama is already highly regulated with checks and balances between the board, management, audits, and HPD. A background check is an additional barrier for people to serve on the board, even for people with 100% clean records. This rule equates Petit Larceny with Grand Larceny. It would apply to anyone who got caught stealing gum or jumping a turnstile, and given our criminal justice system's propensity to target minorities for minor infractions, this rule will have an unjust impact on some Mitchell-Lama residents.

Marsha Slaughter Tue, 03/19/19 - 21:32 I’m opposed to the elimination of the lateral transfers. The reason in being is due to frictions between neighbors a transfer would be the best solution. If you want to change the rules how about stricter rules on loud noises from unruly neighbors. Also to eliminate transfers to a larger apt based on family size not and not based on opposite sex. I live with three people we are all same sex but older people who need our space. Also to cut the fees to be based on the vacancy list instead of paying $50,000 to $70,000 plus. We are here because we can’t afford the fair market rent. I hope that this will be taken in consideration.

Nelson Esp Wed, 03/20/19 - 18:20 There should be a stricter rule regarding the use of renovations in apartments. Renovations of any kind can not last more than 45 days with no extensions allowed - per year. The tenant must get permission from management and specify what is being done. A card should be given specifying the beginning and end dates. Any days not used could be used and can be used at a later date before the end of the year of when the tenant first began. Tenants must also put on their door that they have permission from management and are allowed to make the necessary noises for that type of construction - along with the beginning and end dates posted. No one can make these types of renovating noises other than those who have those notices on their door. Noises must only be allowed from 9:30 am to 4 pm no exceptions and any disturbance complaints from other tenants must be addressed immediately by management the very next day. This is to allow for peaceful habitation for all and to avoid any tenants using their apartments as workshops who disguise their work as renovations. This rule will also apply to management as well when they send out employees to work on apartments when a tenant leaves and when pertaining to maintenance of any thing involving the need to hammer and use of power tools. Living in NYC is already noisy but the noise should not follow us into our homes as well. Some of these things are included in the lease already, however, I think the need for specificity is important. Since some people try to find loop holes within the agreement. I also want to address loud music or any volume that can be heard through the walls. Music and any other type of recreational noises shall only be allowed from 11 am to 11 pm. And rules should be made to evict those unruly neighbors who consistently violate the rules or imposed fines of some sort. No one should have to deal with disrespectful people who get in the way of those wanting to have a peaceful and considerate fair use of their apartments. And reminders of this rule should be sent out once a year to each apartment.

Dolores Ranghelli Wed, 03/20/19 - 21:21 I live in a Mitchell-Lama supervise rental building, and I strongly support the rule change to increase the vote to ⅔ from a simple majority of the residents, to approve the funding of a feasibility study for step one of the 3 step process toward privatization of Mutual Housing companies. In addition I support the use of election companies and proceedures for the vote Affordable housing in New York City is sadly disappearing at an alarming rate. The lotteries for affordable housing are rapidly growing because of this, and any regulation that will help stem the tide of privatization of affordable housing is a welcome change.

Jay Hauben Sat, 03/23/19 - 0:52 I oppose prohibition of lateral transfers: It is sometimes difficult to find a person on the waiting list willing to move into a less desirable apartment (e.g., on a low floor or just above the laundry room or in a poor "as is" condition). Allowing for lateral transfers can help fill those apartments by those who can have the hope in a short time of making a lateral transfer to a more desirable apartment (e.g., on a high floor). Lateral transfer should be a normal right of all shareholders. I support requiring that a board hold an informational meeting before an HPD carrying charge increase hearing. It is necessary that shareholders have adequate information and hear the board rational for a proposed increase before the HPD hearing so that comments at the hearing can reflect support or opposition to the board's rational. I support that election procedures be submitted in detail to the HDP for approval and at least 60 days in advance of an election. I support adding to the rule change that there be mandatory distribution of the procedures at the same time to the shareholders. And I request that HPD add to the proposed rule change specific guidelines for election procedures. I would support a rule change that requires all votes toward dissolution/reconstitution be funded by cooperator assessments. It is economically irresponsible to take such money out of operating funds. The HPD keeps the expenses balanced by the income. If funds toward privatization come from operating funds, the result will increase pressure toward the next carrying charge increase.

Ellen Sheehy Mon, 03/25/19 - 18:51 I favor HPD rule change to 2/3 of vote for Feasability study, Mitchell Lama was created for the middle class, we need affordable homes.

David Tambini Mon, 03/25/19 - 19:43 I oppose prohibition of lateral transfers. I support requiring that a board hold an informational meeting before an HPD carrying charge increase hearing. I support that election procedures be submitted in detail to the HDP for approval and at least 60 days in advance of an election. I support adding to the rule change that there be mandatory distribution of the procedures at the same time to the shareholders. I support a rule change that requires all votes toward dissolution/reconstitution be funded by cooperator assessments. Thank you.

Vlad Loptine Mon, 03/25/19 - 22:39 I and my family wants to stay with ML. Plus change rules

Mohammed Tohin Tue, 03/26/19 - 0:27 I strongly support the HPD proposed rule change regarding Feasibility Studies for Mitchell-Lama Coops -- which will require a 2/3 super-majority vote to authorize expenditure of coop funds on a feasibility study.

Mohammed Tohin Tue, 03/26/19 - 8:44 I support the HPD's proposed rule change regarding Feasibility Studies for Mitchell-Lama Coops which will require a 2/3 super-majority vote to authorize expenditure of coop funds on a feasibility study. There is no logic to allowing a M-L cooperative to begin the costly privatization process unless an overwhelming majority of shareholders have, at the outset, a preliminary interest in privatization. To allow anything less than a 2/3 shareholder approval to spend anywhere from $40,000 to $100,000 simply for speculative "information" about the pros & cons of privatization is a travesty of sound financial management

Sheila Greenberg Tue, 03/26/19 - 9:00 As a senior citizen living on a limited, fixed income maintaining my home at an affordable monthly cost is my top priority. I urge that the number of Yes votes required to authorize funds for a Feasilibity Study be increased from a simple majority to 2/3 of the dwelling units.

Sharon Torres Tue, 03/26/19 - 15:05 I am very much in favor of increasing the requirement from a majority to two-thirds of the units for approval of funds for a feasibility study. I live in a Mitchell Lama coop in Brooklyn and we spent hundreds of thousands of dollars, and 10 years in efforts to "go private." Funds that could have been better spent on much needed repairs, and energy and effort that could have gone into finding solutions to our problems rather than pitting shareholder against shareholder. So while this proposed rule change is coming too late to benefit some coops, it still is very much appreciated. I'd like to propose a change that would require funds for feasibility studies or proxy's be raised through assessments rather than the operating budget. I am opposed to prohibiting lateral transfer; I think it's unnecessarily harsh and can't understand why it's being proposed. Historically, you move into a Mitchell Lama coop, often into a less desirable apartment, put your name on a waiting list to transfer, and if you are inclined, you have the option of moving to a more desirable apartment. Additionally, there are at times unfortunate circumstances where you and a neighbor have issues and after exhausting every option, chose to transfer to a different floor.. As far as I know in my coop we've never had an issue with lateral transfers. I oppose the rule change setting aside the fourth apartment that comes available to an applicant on the external waiting list. Again, we have a system in place that works just fine and changing it is unfair to current shareholders. I also thinks it affords an opportunity for people involved in the process to potentially benefit a relative or friend on the outside waiting list. I'm grateful to live in a Mitchell Lama coop and again, thank you for the proposed rule change regarding 2/3 approval for feasibility studies.

Darryl Mitteldorf Tue, 03/26/19 - 16:02 HPD should not implement the proposed rule to "increase the requirement from a majority to two-thirds of the dwelling units to approve the proposed expenditure of funds for the preparation of a mutual housing company’s feasibility study." This rule represents the interests of the local real estate developers, who do not want an excess of apartment inventory to flood neighborhoods and thus reduce the overall availability of afordable cooperative housing. It's clear from previous comments that real estate developers from the East Village have activated people with fear and falsehoods in favor of implementing this proposed rule. This rule serves to divide our ML community by reducing the availablity of truthful information, in the form of a feasability study. I am confident that conducting feasibility studies will lead to the maintence of ML housing. Requiring a two thirds majority will reduce the likelyhood of a feasibility study and thus allow the wealthy real estate developers to sow fear and neighbor to neighbor hatred, as we saw occur three years ago at the Village View ML. I am a life long ML resident, the third generation of my family to live in ML. My six year old son is the fourth generation of my family to live in ML, and, G-d willing, his children will be the fifth. I am a social worker, as is my wife. We have spent our lives fighting for social justice. We take a back seat to no one regarding the preservation of affordable housing. I say to you and your committee that this increase from a majority to two thirds of the swelling units to approve a feasilibity study is wrongheaded, and runs counter to basic democracy by creating a situation where the simple gathering of facts in advance of a vote for privitization is truncated in a manner befitting those who would wish our neighborhood to be controlled by the weathly rather than we lower middle class.

Terry Weissman Tue, 03/26/19 - 16:18 I strongly support the proposed change for requiring a 2/3 vote to authorize funds for a feasibility study. This change is long overdue and we must take all measures to protect our Michell-Lama housing. It is ridiculous to allow such a costly and unnecessary expenditure to be allowed without an overwhelming majority of the residents in support of it.

Frank Brevins Tue, 03/26/19 - 17:10 I am TOTALLY against the proposed rule to increase a 50% majority to two thirds majority, Look at what you are doing....creating more reasons for all of us to get out of Mitchel Lama. I want to stay in Mitchel Lama, but I Don't want to be Told what to do. The pro increase comments are from people who want to force their opinion down our throats. This is America and this is NYC....we have earned the right to know more about the feasibility of converting and you should not create regulations to prevent that. With facts, we will all likely choose to stay in Mitchel Lama....with proposals that prevent aquiring facts, we will be angry against you and against our neighbors....why are you trying to destroy the cohesion of our community by creating a proposal that prevents us from making choices. This is Mitchel Lama, not a rental. We have the right to know! Please vote against this horrible idea of increasing the requirement for a simple feasabilty study from 50% to two thirds majority. Thank you for your attention.

Adele Niederman Tue, 03/26/19 - 17:17 March 26, 2019 Dear Ms. Walpert: As residents and shareholders of St. Martin’s Tower we endorse the revised amendments to the HPD Rules and Regulations: • Increase the voting requirements for authorizing funds for a Feasibility Study to two-thirds of the dwelling units. • Requirement of sixty days advance notice to HPD of election procedures and mandating use an independent election company to monitor and supervise the voting associated with Special Meetings. • Defining the role of Managing agents in advising HPD of violations committed by the Housing Company. • Rules for establishing primary residency. We want to emphasize our support of the 2/3 voting requirement as an excellent way to add protection of Mitchell-Lama cooperatives. Any change to the organization of a cooperative, or any form of government, should require a super majority in order to protect everyone from hasty judgments. We do not agree with the prohibition on lateral transfers. Our community at St. Martin’s has found this a useful method to accommodate changes in family needs and allows families a chance to move to an apartment they find more desirable. We feel this is an unnecessary reduction in flexibility for the housing company and its residents. Thank you for this opportunity to speak out on important issues for Mitchell-Lama cooperatives. We look forward to many more years as a limited equity cooperative providing affordable homes and gracious community to many New Yorkers. Sincerely, Residents of St. Martin’s Tower 65 West 90th Street New York, NY 10024 Florence Buist 11A John Barrett 26C Barry Cohen 23E Joan Cohen 23E Iris Cuevas 5B Bill Davis 7C Ellen Davidow 18D Melvina Ellis 13G Viola Ford 26E Angel Flecha 21B Regina Flecha 21B Viola Ford 26E Marian Goldberg 7D Walter Grutchfield 10F Frances O’Flynn 16D Elmyria Hull 20B Kevin Kennedy 19C Preston McCoy 20E Esther Moroze 7C Adele Niederman 26G Nick Niederman 26G Pat Pollock 22D Richard Rosenfeld 20A Varda Rosenfeld 20A Maria Sassian 17D Flo Schreibstein 5C Laura Sirota 23G Deborah Schroer 13A Harold Schroer 13A Doug Shepord 13A Elnora Smith 13E Peter Sprung 5D Maria White 11E

Jay Hauben Tue, 03/26/19 - 17:21 The following letter was sent today: Dear Ms. Walpert: We, concerned shareholders at the RNA House Mitchell-Lama co-op in Manhattan, support the proposed HPD M-L rule change to 3-14 (h) (2) that election procedures be submitted in detail to the HDP for approval and at least 60 days in advance of an election. Also, we support adding to the rule that there be mandatory distribution of the procedures at the same time to the shareholders. In the 2017 election at RNA House for new board members, because of an election irregularity, ballots with uncounted votes were taken off site by the corporation attorney with the promise of a new election. There was no new election. Instead, ten days later winners and losers were announced without any way to confirm them. Complaints to the RNA House Board and to the HPD about that election were not investigated. In 2018 and 2019, control of the election was by the same corporation attorney and the outcome of votes seemed to be the result of unusually large numbers of proxy votes. Many shareholders at RNA House have lost confidence in our election procedures. In order to restore some confidence, we request that the HPD add specific guidelines for election procedures to the proposed rule change. We suggest that the following, specific election procedures be added to the rules: a) All elections and votes shall be based on an HPD approved shareholder list. To update such a list there must be a resident audit/verification before each vote. b) Notices and ballots shall be sent only to the address of record. No sending of ballots to offsite residents. c) Proxy voting must be by directed proxies and carried out in a manner that ensures anonymity of the vote. So as to avoid intimidation and possible fraud, only third party collection of proxies shall be allowed (not by cooperators or the co-op's professionals). Signatures on proxy ballots must be verified before votes are counted. d) Voting in person must be with a paper trail. e) Cooperator oversight of voting and counting shall be allowed and mandatory appointment of an Election Inspector per the BCL Section 610 shall be required. f) The election procedures must include public and transparent vote counting on site, open to all shareholders as observers. No vote count before verification that the quorum requirement has been met and that the number of ballots is equal to the number of signatures. g) In the case of a close election, the results shall be subject to recount upon request. h) Election complaint and investigation procedures shall be included in the election procedures Thank you for considering our requests. . The names and apartments of 20 RNA House cooperators Concerned Shareholders at RNA House, 150-160 W 96 St., New York, NY 10025

Richard Hayden Tue, 03/26/19 - 17:27 I've just been shown a flyer by my neighbor at Village View Mitchel Lama Housing. The flyer says that if I don't make a comment in favor of a proposal to increase the voting threshold for a feasibility study, then I will either loose my apartment or be forced to pay ten times my current monthly fee. This is unacceptable. How dare anyone try to scare me or my neighbors into supporting any kind of regulation or proposed change in regulation. Shame on whoever is instigating this. Clearly supporting anything that requires an impossible to reach two-thirds majority for creating a study is wrong. I STRONGLY OPPOSE CHANGING THE VOTING REQUIREMENT FROM 50% TO 67% and ask that you keep the current simple majority requirement for a feasibility study. Further, I ask that you publicly chastise whoever organized this fear mongering in my building. It is toxic and illustrates how easy it is for bullies to force people to support something that clearly is against common sense and our interests.

Heidi Kohn Tue, 03/26/19 - 17:35 I support the proposal to require a 2/3 super majority to pass a Feasibility Study. I also urge HPD to NOT permit the money for a Feasibility Study to come from either general or reserve building funds. I further encourage HPD to require a waiting period of at least 10 years after the defeat of a Feasibility Study attempt before another Feasibility Study vote can be taken so as to discourage continued unrest in the building which interferes with competent long-term planning into the future. We all know that we need affordable housing in NYC more than ever. I believe these changes will support keeping more affordable housing units in NYC.

Kimberly Ellis-Rogers Tue, 03/26/19 - 19:59 Require Independent Election Companies to provide cooperators with anonymous Election voting ballots, in order to reduce voter intimidation. Ballots must only be mailed to the shareholder’s address at the Mitchell Lama building.We should only allow directed proxies to reduce impact of door to door intimidation.We need paper trails in case of close votes and outcomes.Open observation of vote counting. To avoid any impressions of unfairness, The Election process should also allow poll watcher { such as cooperators; elected official; or HPD representative} to observe the Election process and ballot count. Open Observation encourages participation by shareholders and brings transparency to the whole process. Requiring a two-thirds vote of the dwelling units for authorization of a Feasibility Study is an important change which I support.Please require a primary residence audit six months in advance of the vote to authorize money for Feasibility Study. Too many residents of Mitchell Lama cooperatives complain of non-residents voting. We have shareholders that do not live in their apartments waiting for the development to privatize so they can sell. We have pointed out these vacant apartments to our managing agents and Board officers to no avail. Further, after a vote is taken by the shareholders for a vote on whether to spend money for a Feasibility Study, another study must not be permitted for a specified number of years so that shareholders money is not wasted. Further, funding of a Feasibility Study must come as a Shareholder assessment, not from building general/operating/reserve funds. Article XI does not advance the goals of affordable housing especially since there are inequities with regard to the AMI (Area Median Income) for the true cost of living in NYC, so delete. Further, the provision which must be added would include some of the benefits of remaining in an HPD building such as SCRIE, DRIE, competitive financing/grants/loans available for remaining an HPD building. § 13. (16) There should be a specific time frame (not timely manner) to respond to shareholder, such as two weeks or what may be deemed appropriate for the situation. (§ 13. HPD must fully investigate the allegations of violations of rules made within a specified time frame, such as thirty days of being informed of the allegation. Further, HPD must promptly report any criminal allegations to the police and/or Attorney General of New York State and/or Comptroller or appropriate governing body. This is to ensure that violations are addressed and that if there is someone at fault, that this person or entity does not be allowed to commit the same violations to other buildings/tenants.

Kimberly Ellis-Rogers Tue, 03/26/19 - 20:06 “Applicants to the lottery must be provided with at least 45 days to respond to the lottery (i.e. at least 45 days from the 1st publication of the lottery in at least two daily newspapers of general circulation.”The rationale is that in the past some lotteries have had less than 2 weeks notice, in a daily newspaper of general circulation, which does not promote fairness and equity. § 4. The following section should not be added as people should have the right to make transfers to same size units. “However, no tenant/cooperator currently residing in a development shall be permitted to transfer to an apartment in such development that is the same size as the one such tenant/cooperator currently occupies.” § 10. (9) Must not be added as it is poor statutory construction. This provision fails to take into account whether someone has been rehabilitated, whether the crime was a felony or involved violence, how long ago the crime occurred and whether other felonies should be considered.

Hellen Washingtong Wed, 03/27/19 - 9:34 I am a twenty year resident of the Village View Mitchell Lama housing corporation. I and my husband are AGAINST increasing the requirement from a majority to two-thirds of the units for approval of funds for a feasibility study. I feel that you are preventing shareholders from receiving basic information. That is unfair. I believe you are trying to take over our Mitchell Lama development with rules that only benefit the financially well off. The question of privatization is irrelevant for this proposal. As shareholders, we have the RIGHT TO RECEIVE full, complete and accurate information. Without a feasibility study, we are vulnerable to falsehoods and Trump like scare tactics. Witness this: I received a flyer under my door which said several things that I believe are false, such as my monthly fee would rise ten fold if I did not post a comment in favor of increasing the requirement to two thirds. The flyer went further saying that "millennials" would force me and my family out of my apartment and other nonsense. But, it is nonsense that my neighbors seem to accept as truth. What is it that Trump says, Fake News? But, the most horrible part of this flyer, is that it says that if I did not post a pro-two/thirds comment, then "people from outside my neighborhood" would likely become new shareholders. As a woman of color, I know all too well what this flyer and it's - lets be truthful - racist dog whistles are about. Shame on this committee if it allows the voices of hate and propagators of ignorance to win over justice and fair play. In closing, I ask that you DO NOT pass the proposal that increases the requirement from a majority to two-thirds of the units for approval of funds for a feasibility study. I also ask that you as a committee make a clear statement against the horrible people who have been trying to scare us into supporting this change.

Fabio Miliano Wed, 03/27/19 - 10:27 “Internal Transfer” Shareholder should be allowed to transfer to the same unit if they qualify in all aspects. I’m on a transfer waiting list for my dream apartment for 7 years and this new proposal is a dream killer. I don’t see this proposal to benefit any old or new shareholder than HPD. It means one less paper work to review and to be approved. Solution: Please assign this duty to the Board or management agent to control internal transfer. They will provide an annual report to HPD with all the transfers and changes. There is one famous speech by Dr. Martin Luther King Jr. “I Have a Dream“. Please do not kill my dream. Fabio E. Miliano

Shelia Scurlock Wed, 03/27/19 - 10:29 I am a member of CU4ML. I would like to endorse the proposed amendment to Section 12 Paragraph 6 of HPD Rules, "2/3 vote of the dwelling units in the hosing company to authorize funds for a feasibility study." This ruling will help Mitchell-Lama Shareholders to maintain support for their communities.. Maintenance Increase- My development was facing a very high increase that did not reflect the economic level of our community. The Shareholders had to meet to fight the rate of the increase. I am happy to see the additional requirement for information meetings before the HPD hearing. I also agree that the Boards needs to specify changes in all aspect of overhead (like wages, benefits, supplies, fuel & taxes. Shareholders need this information to support or disagree with major increases.

Zezlie Blyden Wed, 03/27/19 - 13:23 I definitely agree with HPD's proposed rule change regarding feasibility studies for Mitchell-Lama Coops, requiring a 2/3 majority vote to authorize coop funds for a feasibility study. The current 50% majority of voters, is not sufficient to allow Mitchell-Lama coops to start the process of privatization, affecting their entire neighbors of cooperators with such a drastic decision. In addition, new HPD rules governing Mitchell-Lama coops should require funds for a feasibility study to come from a special assessment from shareholders and not from the general operating or reserve funds. Positive steps are necessary to keep Mitchell-Lama coops affordable.

Kevin Berry Wed, 03/27/19 - 13:29 I also strongly oppose the amendment to prohibit lateral transfers within Mitchell Lama buildings. There are many who have made the decision to move into a less desirable apartment knowing there's an option to be placed on a waiting list. This change would be unfair to future shareholders and especially to those who are, and have been on a waiting list for a while. Our dwelling choices should not be limited just to reduce administrative paperwork.

Alan Barnes Wed, 03/27/19 - 14:52 As a long-standing resident shareholder in an UWS M-L co-op, I fully support the proposal requiring a 2/3 vote to initiate the costly and potentially life-changing process of privatization. This change is long overdue. There is simply no good reason to allow the expenditure of a co-op's sorely-needed funds on such a speculative endeavor based solely on the interests of anything less than an overwhelming number -- a “supermajority" --of those affected.