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23 February 2026

New Law Imposes Strict Timelines For Cooperative Transfer Approvals In NYC

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Starting this summer, cooperative corporation (coop) boards and their managers will need to work a little faster to avoid inadvertently approving purchase applications.
United States New York Real Estate and Construction
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Starting this summer, cooperative corporation (coop) boards and their managers will need to work a little faster to avoid inadvertently approving purchase applications.

On January 29, 2026, the New York City Council voted to override Mayor Adams' veto of Int. No. 1120-B, officially enacting significant new requirements governing how coops review and process transfer applications. The law amends the New York City Administrative Code to introduce strict timelines, standardized procedures, and new enforcement mechanisms intended to increase transparency and reduce delays in coop transactions.

The law applies to New York City coops with more than 10 units and only to applications that do not require governmental approvals. It covers purchase applications and other board-approved transfers — including trust transfers, gifts, family transfers, and estate transfers — and takes effect 180 days from passage (in late July 2026).

Standardized Application & Transfer Requirements

Coop boards must maintain:

  • A standardized written application package, and
  • A complete list of all transfer requirements, including:
    • Required forms and disclosures
    • All fees
    • Interview procedures
    • Instructions for submission
    • Any other documentation required for approval

These materials must be provided promptly upon request to purchasers, sellers, or their agents.

Importantly, the new law's broad definition of "sale" extends to any transfer requiring board approval. A "purchaser" includes any person acquiring shares or a membership interest for which board approval is required.

Acknowledgement of Application

Within 15 days after receiving an application (or any subsequent submission), a board must send a written acknowledgement via email and registered mail stating whether the application is complete, noting any missing items with citations to the application, and identifying any additional materials requested for clarification.

If the board fails to provide the acknowledgment within 15 days, the application is deemed complete as of the date the acknowledgment was due.

The law includes detailed procedural requirements governing how and when boards may request additional information and how those interact with the completeness determination.

Decision Deadline

Within 45 days after acknowledging a complete application (or when the application is deemed complete), boards must notify the purchaser (or the purchaser's agent) by email whether consent is granted unconditionally, granted subject to condition, or denied.

A board may extend this deadline once by 14 days without the purchaser's consent, provided notice is given before the original deadline. If the board requests additional information during its review, the law expressly permits an additional 14-day extension. Purchasers may consent in writing to additional extensions.

Summer Recess Tolling: Boards may toll statutory timelines only during July and August and only if the board has formally adopted a documented recess period and applicants are advised of the recess period.

Enforcement & Penalties

The Department of Housing Preservation and Development (HPD) will enforce compliance. Failure to comply may result in civil penalties as follows:

  • $1,000 for the first violation
  • $1,500 for the second violation
  • $2,000 for each subsequent violation

HPD will initiate enforcement proceedings by serving a summons returnable to the Office of Administrative Trials and Hearings (OATH).

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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