The new law applies to transfer applications in co-ops with 10 or more units submitted on or after July 28, 2026. Additionally, the law applies to gifts of co-op shares, transfers to a trust, family transfers, and estate-related transfers. Article IX HDFC cooperatives and cooperatives that require a government housing agency’s approval for a transfer—including certain Mitchell-Lama developments—are excluded. Covered co-ops must maintain a standard application form and a complete list of transfer requirements, including required documents and fees. Under the statute, several deadlines run from the receipt of materials the co-op requires for its review.

The Clock is Running

Coopersmith explains that “Within 15 days of receiving an application from the purchaser or the purchaser’s agent, the co-op must acknowledge its receipt in writing, both by email and registered mail, and must state whether the submission is complete. If it is incomplete, the response must identify what is missing. If the co-op does not send that acknowledgement within 15 days, the application is treated as complete as of the date the acknowledgment was due.”

In addition, Coopersmith notes, there is a 45-day decision period. “Once an application is complete, or treated as complete, the board has 45 days to notify the purchaser or the purchaser’s agent by email whether consent is granted, granted with conditions, or denied. During that period, the co-op may request additional material to clarify items already submitted. The co-op may also extend the decision period once for up to 14 days if written notice is given before the original deadline expires.

See You in September

The law also acknowledges that many cooperative boards reduce their activity during the summer months. The statute permits a temporary pause or suspension of requirements during the 15-day acknowledgement period and 45-day decision period in July and August if the co-op has adopted a written summer recess period and has advised applicants in advance. However, Coopersmith says that “It is critical that co-op boards adopt a formal summer recess policy for this exemption to apply.”

There are provisions for enforcement and penalties. Violations may be pursued through the Department of Housing Preservation and Development (HPD), with adjudication at the Office of Administrative and Trial Hearings. Civil penalties are set at $1,000 for a first violation, $1,500 for a second violation, and $2,000 for a third or subsequent violation. Boards and managing agents can prepare by adopting clear internal procedures and policies for transfers, standardizing and organizing application materials, and establishing calendaring protocols to track application deadlines.