The Real Estate Board of New York to The Committee on General Welfare of the New York City Council Concerning Intro 2176-2020


December 14, 2020

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The Real Estate Board of New York (REBNY) is the City’s leading real estate trade association representing commercial, residential, and institutional property owners, builders, managers, investors, brokers, salespeople, and other organizations and individuals active in New York City real estate. REBNY thanks the Committee on General Welfare for the opportunity to provide feedback in support of Intro 2176-2020, legislation to create a supportive housing bill of rights. We are supportive of the City Council’s efforts and offer a number of recommendations to improve this legislation.

For a Supportive Housing Bill of Rights to be effective, it must be presented to the resident in plain language and should ensure that all owners have a resource to direct residents towards if they need further assistance. Principally, the bill should designate an appropriate city agency to promulgate and create a standard, plain language template so that the required information is provided in a manner that is intelligible to the resident, and makes clear that additional resources are available to tenants to help them in understanding the rights outlined. We believe a form that is written in dense legal terms is not in the best interest of residents. This would also ensure consistency across portfolios and ownership structures, and should be required in any supportive housing site, private and public.

Information regarding programs and supportive services administered should clarify what benefits a tenant can access. Again, language would need to be included in the standard form that also directed a tenant as to where they could seek out more information if desired. However, it is unclear what benefit is incurred by providing any and all information regarding financing or funding streams for the entire project, and could cause confusion and detract from the laudable goal of focusing attention to tenancy rights. Alternatively, it would be more wholly appropriate for the state and city to report on funding stream allocation if that is the goal of this bill clause. Lastly, as a drafting correction, please note that if a tenant is residing in a rent stabilized unit, the bill should be clarified to mention the requirement of a 1 year lease minimum pursuant to stabilization law.

Lastly, by definition, residents in supportive housing have access to supportive services through a service provider. Ideally, those supportive service providers should already be able to assist residents who are having difficulty understanding their rights. If there is a need to help persons in supportive housing understand their rights it is unclear whether a single piece of paper will truly be sufficient, and raises the question as to whether efforts would be better directed to ensuring outreach by the providers themselves on how to help the residents and advocate for them. There are also a number of existing non-profit and government resources available to help people, such as the HomeBase program.

Thank you for the opportunity to submit comments on this legislation.