Public comments for: Mitchell Lama Rule Amendments

Comments

Comment:
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
Agency: HPD
Comment:
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
Agency: HPD
Comment:
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.
Agency: HPD
Comment:
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.
Agency: HPD
Comment:
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.
Agency: HPD
Comment:
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.
Agency: HPD
Comment:
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.
Agency: HPD
Comment:
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
Agency: HPD
Comment:
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.
Agency: HPD
Comment:
I and my family wants to stay with ML. Plus change rules
Agency: HPD

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