Landlord Can't Substitute Annual Registration Form for Initial Registration Form
LVT Number: 9530
Landlord asked the DHCR if it could file initial registrations on the forms that were used for annual registrations in 1985 and 1986. The DHCR said ''no.'' The initial registration form (RR-1) tells tenants that they have a right to object to the information that landlord puts on the form. The annual registration forms for those years didn't have the same notification provision as the RR-1. Landlord can't substitute the 1985 or 1986 annual registration forms for the RR-1 because the forms aren't similar enough.
DHCR Opin. Ltr. by Nathaniel Geller (7/20/94) [2-page document]