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April 6, 2020
REASONABLE ACCOMODATION NOTICES ON HOLD

On March 19, 2021, we notified you of a new New York State law requiring all landlords, including cooperatives and owners of rental units in Condominiums, to provide a mandatory written notice to all tenants setting forth the tenants' right to a reasonable accommodation if they are disabled.
 
 
On March 25, 2021, those laws were repealed and replaced with a new law which requires the NYS Division of Human Rights to promulgate regulations requiring housing providers “to provide notice to all tenants and prospective tenants … of their rights to request reasonable modifications and accommodations."  The Human Rights Division web site reports that they have issued those proposed regulations which will be published in the State Register for a 60 day public comment period on April 14, 2021.  The regulation will therefore not be adopted before mid June, at the earliest.

If you have already mailed the reasonable accommodation notices to your tenants, nothing further need be done at this time.  You do not need to issue any form of revocation.  It is possible that a new notice may have to be sent once the regulations are adopted.  If you have added the notice to closing packages or to purchase/leasing applications, we suggest you remove them for now and wait for the State to issue new guidance and a new notice.

We will update you as to what is required once the regulations are enacted and provide you with an appropriate notice at that time.
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Tane Waterman & Wurtzel, P.C. · 120 Broadway Ste 948 · New York, NY 10271-0996 · USA

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