Briefing Book:
The Effectiveness of Rent Regulation in New York City

A Briefing Book


Chapter Three


The following analysis is organized to measure the effectiveness
of New York City's rent regulation system in meeting the three
purposes set forth in Chapter 2: the moderation of rents;
eviction controls; and the preservation of housing through
maintenance of services. Each section below defines the issue at
hand, provides relevant evidence, and identifies barriers to


Data on rent levels are needed in order to shape the discussion
of affordability for tenants and fair return for owners.

Median rents over the past 13 years may be compared using HVS
data [Table 8]. Rents in current dollars represent what the
tenant is paying in today's dollars, while constant dollars
measure rent increases above and beyond inflation. As figures
were unavailable for contract rent, median gross rents (contract
rents plus utilities) are used for purposes of this comparison.

As the data reveal, current-dollar rents have increased across
the board from year to year. Constant-dollar rents show more
variability -- with an actual decrease in gross rents for all
control groups of housing in the 1978-to-1981 period and steady
increases thereafter until 1987.

From 1987 to 1991, median gross rents for controlled and post-
1947 stabilized apartments decreased somewhat. However, gross
rents increased more rapidly than inflation during this period
[Table 9].

It is clear that rents have risen considerably in New York City.
Analyses of what these increases mean for tenants follow.

Tenant Affordability.

A commonly used measure of housing affordability is the rent-to-
income ratio. It is generally presumed that approximately 30
percent of household income is an affordable (or reasonable)
amount to devote toward rent.

While this measure does help to gauge affordability, its
effectiveness is limited. Rent-to-income ratios do not account
for household size -- i.e., how many people are being supported
by a given income. Nor do they take into account individual
circumstances such as high medical costs or the like. Also, 30
percent is too much for most low-income renters to pay. (In fact,
some poor people can't reasonably afford to pay any rent and have
anything left for their other needs.) The measure is used here
only because it is the generally recognized standard.

                             Table 8
                       Median Gross Rents
      Current and Constant Dollars New York City, 1978-1991

Control Status       1978      1981      1984      1987      1991

                         ----- Current Dollars -----
Total Renter
Occupied             $208      $263      $325      $395      $509

Controlled           $164      $212      $256      $300      $370

Decontrolled         $221      $270      $355      $445      N/A*

     pre 1947        $206      $260      $322      $390      $505
     post 1947       $287      $350      $400      $480      $573

CPI                 192.2     253.9     299.9     334.7     414.5

                         ----- Constant Dollars -----
Total Renter
Occupied             $108      $104      $108      $118      $123

Controlled           $ 85      $ 83      $ 85      $ 90      $ 89

Decontrolled         $115      $106      $118      $133      N/A*

     pre 1947        $107      $102      $107      $117      $122
     post 1947       $149      $138      $133      $143      $138

Sources:Stegman, Michael. Housing and Vacancy Report, New York
City, 1987, pg. 63, and 1991 NYC HVS Tabulation Package.

Consumer Price Index for All Urban Consumers for New York-
Northern New Jersey (1967=100), March of each year, Bureau of
Labor Statistics, U.S. Department of Labor

Rents use current dollars rounded to the nearest dollar before
calculating constant dollars. Rents in constant dollars
calculated by dividing rents in current dollars by the CPI for
the appropriate year.

* Decontrolled was dropped as a unit of analysis in 1991.


                             Table 9
       Percentage Increases in Median Monthly Gross Rents
                Compared to Increases in the CPI
                    New York City, 1978-1991

                        ----- Percentage Change -----
Unit         1978-1981     1981-1984     1984-1987     1987-1991

Dollars          +26.4         +23.6         +21.5        +28.8

CPI              +32.1         +18.1         +11.6        +23.8

Dollars           -3.1          +3.8          +9.3         +4.2

Sources: Stegman, Michael. Housing and Vacancy Report, New York
City, 1987, pg. 63, and 1991 NYC HVS Tabulation Package.

Consumer Price Index for All Urban Consumers for New York-
Northern New Jersey 1967=100), March of each year, Bureau of
Labor Statistics, U.S. Department of Labor

                            Table 10
           Renter Households Paying 30 Percent or More
                     of Income in Gross Rent
                     By Control Status, 1991

                             Units         Percent

Controlled                  66,359            54.7
Stabilized                 528,285            55.5
Public Housing             110,289            43.4
Mitchell Lama               40,692            47.5
Other*                     321,471            56.2

Source: 1991 NYC HVS

Note: This table was produced using computerized data.

* The unit of analysis "Other" refers to in-rem, HUD federally
subsidized, Article 4, Loft Board regulated and unregulated

A more telling way to measure the effects of regulation on
affordability is to compare changes in tenant incomes to changes
in rent levels for each control status of housing. Over the past
four years, both tenant incomes and rent levels increased.
However, rents increased much more than incomes, creating a gap
for all tenants.

                            Table 11
            Median Household Income by Control Status
                   New York City 1986 and 1990
Control Status                 1986        1990         Change

Controlled                  $10,817     $12,075         +11.6%
Stabilized                   18,547      21,000         +13.2%
Other*                       18,609      24,000         +29.0%

Sources: NYC HVS 1987, Series IA, Table 10; and NYC HVS 1991,
Series 1A, Table 9

Note: Data on incomes were collected in 1987 and 1991 but reflect
income earned the previous year.

* The unit of analysis "Other" refers to in-rem, HUD federally
subsidized, Article 4, Loft Board regulated and unregulated

Incomes grew significantly for all types of tenants during this
time period [Table 11]. But the incomes of tenants in unregulated
(included in "Other") housing grew twice as much as the incomes
of regulated households. Tenants with the greatest gap between
income and rents are those living in stabilized apartments.

                            Table 12
  Median Monthly Contract Rents per Apartment by Control Status
                  New York City, 1987 and 1991
Control Status                 1987        1991         Change

Controlled                     $260        $320          23.1%
Stabilized                      377         480          27.3%
Other*                          418         550          31.6%

Sources: NYC HVS 1987 Series IA, Tables 32 and 37; and NYC HVS
1991 Series IA, Tables 30 and 35

* The unit of analysis "Other" refers to in-rem, HUD federally
subsidized, Article 4, Loft Board regulated and unregulated

Rents also increased significantly over this four-year period
[Table 12]. Again, rents increased the most in unregulated
housing. When increases in income are compared to those in rents,
the gap referred to above is identified [Table 13].

                            Table 13
              Increases in Median Household Income
                Compared with Increases in Median
                      Monthly Contract Rent
                    New York City, 1987-1991

                                  -- Percentage Increase --
Control Status              Incomes       Rents            Gap

Controlled                   +11.6%      +23.1%         -11.5%
Stabilized                   +13.2%      +27.3%         -14.1%
Other*                       +29.0%      +31.6%          -2.6%

* The unit of analysis "Other" refers to in rem, HUD federally
subsidized, Article 4, Loft Board regulated and unregulated

The implications of this comparison are serious. Few incomes are
keeping pace with rising rents in New York City. And tenants in
regulated apartments are bearing the burden of rent increases far
greater than the growth of their incomes.

Using different measures, we have seen that housing, by and
large, is becoming less affordable for tenants. It is then
reasonable to ask how landlords are faring.

Landlord Profitability.

In a housing market experiencing a shortage, the goal of rent
regulation is to stabilize rent levels while guaranteeing a fair
level of return for owners. A fair or reasonable rate of return
is, however, interpretative and shaped by politics. "One of the
most difficult and persistent problems of rent control has been
defining 'fair return' and developing satisfactory individual
adjustment fair return standards."(1) This is particularly
difficult given the lack of reliable information regarding the
incomes and expenses of landlords. Hence, the following analysis
is more qualitative than it would be if firm data were available.
While no one indicator is adequate, those discussed below show
that real estate is providing a fair return.

Peter Marcuse makes an important point that clarifies the issues
at hand. By design, landlords are worse off under rent regulation
because regulations hold rents below what they would be
otherwise. "The crucial question, however, is not whether
landlords would be better off without rent regulation, but are
they badly off with it?"(2)

Since rent regulation is designed to pass increases in operating
costs on to tenants, operating costs are at the heart of this
discussion. Whatever the profitability of a given property, rent
regulations in New York City essentially maintain that level of
profitability (rate of return) over time by granting rent
increases for changes in operating costs. Thus, discussion of
fair return will focus on the degree to which rent increases
granted by the regulatory system adequately compensate owners for
changes in operating costs. In this situation, rent increases
larger than changes in operating costs result in an increased
rate of return for owners.

As a starting point, analysts have compared changes in operating
costs to changes in the Consumer Price Index (CPI). Several
experts who have examined the operating costs of rental buildings
have found that these costs consistently increase at a slower
rate than inflation. John Gilderbloom and Richard Appelbaum
found: "On average, one-third to one-half of landlords' costs are
unaffected by inflation."(3) While New York City's rent
regulations are not tied to increases in the CPI (as regulations
in some jurisdictions are), we may note from an earlier
illustration that rents have increased at a faster pace than
inflation over the past 14 years [see Table 9]. "Moderate rent
control, by pegging increases to the full CPI [or above it], can
therefore result in increased income over time..."(4)

In sum, researchers have found that operating costs rise at a
rate slower than the CPI. As rents have risen faster than the CPI
in New York City, it is safe to assume that, at a minimum, rental
income has grown over time as a result of these substantial rent

This assumption is supported by the findings of the New York City
Rent Guidelines Board (RGB), the local body charged with
determining annual rent increases. To do so, the RGB staff
conducts various types of research, including studies of changes
in operation and maintenance (O&M) costs.

For the past few years, the RGB has conducted an Income and
Expense study to determine the O&M-to-rent ratio for rent
stabilized buildings. From a sample of unaudited Income and
Expense reports filed with the Department of Finance by landlords
of 500 rent stabilized buildings, an O&M-to-rent ratio of .75 was
determined using 1991 data.(5) This indicates that, on average,
75 cents of every rental dollar go toward operation and
maintenance expenses -- which include taxes, labor, fuel,
utilities, maintenance, administration, insurance, and other
miscellaneous costs -- leaving 25 cents of every rental dollar to
go toward debt service and profit.

In order to obtain information regarding owners' income and
expenses (for which data have been largely unavailable) and to
verify the reliability of the available data, the Department of
Finance, at the request of the RGB, recently completed an audit
of some annual Income and Expense reports of landlords filed with
the Department of Finance.

Based on a weighted sample to reflect the stabilized stock in
general, information on 46 buildings was analyzed from the 1990
Income and Expense reports. Many owners of larger buildings
refused to participate in the voluntary study, making the
reliability of the findings for large buildings questionable.
Despite these shortcomings, the study is not only current but is
the first, in-depth examination of actual audited income and
expense information. It yielded some important findings on the
finances of landlords.

First, the audit determined that owners significantly overstated
expenses. "Overall (weighted) O&M expenses were reduced by about
8 percent."(6) There are factors that may explain the
overstatement of expenses, such as making an error, "expensing"
an item that should be capitalized, or not providing
documentation of expenses -- in addition to deliberate

Second, the audit indicated that previous Income and Expense
studies yielded O&M-to-rent income ratios that were too high.

     This year's estimate of the O&M to rent ratio was
     .75 based on 1991 submissions. If we assume that
     an audit of the 1991 I and E filings would have
     resulted in the same findings as in this study
     (all other things being equal), we can revise the
     O&M to rent ratio based on the adjustments made by
     the auditors. Doing so would result in an O&M rent
     ratio of .69 (.71 if salaries to stockholders and
     partners are considered a legitimate expense).
     While we do not suggest that this is necessarily a
     precise estimate of the O&M to rent ratio, the
     audited data strongly suggest that the .75 figure
     from this year's I&E study is too high.(7)

The RGB bases annual rent increases on these figures. Thus, the
RGB itself has concluded that due to a dearth of available
information -- and also due to the overstatement of expenses in
the information that is available -- its own estimates have
favored landlords by overestimating O&M costs. Overcompensation
for changes in these costs result in higher-than-necessary rent
increases and increased return for owners. This suggests that
routine audits of landlords' books should be conducted before
tenants bear the brunt of rent increases.

A final, though imperfect, indication of how landlords are faring
is the number of rent-increase hardship applications filed with
the state Division of Housing and Community Renewal (DHCR).
Hardship applications are requests by landlords for additional
rent increases to relieve the financial strain of operating their

     The intent and purpose of the hardship provisions
     are to act as a safety valve relieving economic
     pressure on owners confronted with financial
     difficulties because of administratively set rent
     levels. While the proportion of buildings that are
     operating with adequate cash flow compared to the
     proportion of those operating at marginal or
     negative profitability is not known, the hardship
     study found an extremely low level of owner
     applications for hardship increases. Approximately
     200 applications were filed from 1984 to 1988 and
     there has been an almost negligible approval rate.
     Of the 167 applications reviewed only eight
     resulted in hardship increases.(8)

This small number of applications may indicate two things. First,
rent regulations may have maintained a reasonable rate of return
for landlords. However, it is also important to note that the
current hardship application process is unworkable, and hardship
applications thus should not be viewed as a single financial

Given that rents have increased more than the CPI over the past
14 years, that the RGB has found its own estimates of operating
costs upon which rent increases are based to be too high, and
that relatively few hardship applications are filed with DHCR, we
may conclude that, by and large, operating rental property in New
York City remains a business that provides a fair return for


A commonly held myth about rent regulation is that it is
impossible to evict tenants from rent regulated apartments. Quite
the contrary is true. From 1983 to 1990, the Bureau of City
Marshals evicted an average of 24,025 households per year. The
number of evictions has varied little during the time period,
from a high of 26,700 in 1983 to a low of 20,300 in 1985.
Evictions in 1990 and 1991 were close to the eight-year

Of course, not all of these were evictions from rent controlled
or rent stabilized housing -- but a substantial portion no doubt
were. Unfortunately, very limited eviction records are kept in
New York City, so there is no way of knowing the exact proportion
of rent regulated evictions.

Grounds for eviction under rent regulation fall into three key
categories: nuisance, breach of lease, and personal use. Nuisance
evictions provide owners an ability to evict tenants for causing
disruption, disturbing other tenants, allowing the apartment to
be used for an illegal purpose, and similar grounds. Breach of
lease grounds for eviction include keeping a pet not allowed by
lease, illegal sublets, etc. Personal use grounds allow landlords
to evict in order to enable use of the apartment for themselves
or their relatives. (Of course, rent regulated tenants can also
be evicted for non-payment of rent.) The multitude of provisions
for eviction provide reasonable recourse for landlords struggling
with "bad tenants" while protecting tenants at large from
speculation, conversion, and unfair conditions.(10)

Some critics have argued that rent regulation is so restrictive
and so pro-tenant that it drives landlords to harass tenants
illegally. However, as illustrated above, rent regulation laws
leave ample room for legal recourse for owners faced with
problems. The reasons landlords harass tenants vary, but they are
generally driven by a desire for profit. Owners may try to force
tenants out because they are looking for much higher rents -- or
for the profits made through coop conversion, renovation, or even
demolition. Often, landlords harass their tenants after tenants
have asserted their rights by complaining about a lack of
services or repairs in the building.(11)

Rent regulation protects tenants from harassment. Tenants may
file complaints with the DHCR Harassment Unit. The DHCR
Enforcement Bureau considers the following acts to constitute
legitimate claims of harassment: physical abuse, verbal abuse,
arson, a denial of services (when it is purposeful and continuous
as opposed to an isolated, unintended interruption), and multiple
instances of unwarranted litigation.(12)

The tenant protections detailed above are useful only under two
conditions. First, tenants must be informed of the protections
provided them. Second, protections must be meaningfully enforced
by DHCR without an unfair burden placed on tenants through the
process of obtaining their rights.

Informed Tenants?

Tenant knowledge of protections is difficult to gauge. However,
the HVS asks tenants whether or not they know the control status
of their apartments. This is a rough indicator of tenant
knowledge not only about protections but also about their rights
regarding rent levels and eviction. The results indicate, in
terms economists would use, that such knowledge is not perfect
[Table 14].

Rent controlled tenants are the most highly aware of the status
of their apartments and, one may assume to some degree, the
attached rights and protections. Stabilized tenants are less
informed, with under half reporting their true control status-
indicating a relative lack of knowledge regarding protections.
Simply put, many rent regulated tenants do not know their rights.

                            Table 14
               Tenant Knowledge of Control Status
                       New York City, 1991

Reported                  % Actual       % Actual
Control Status           Controlled     Stabilized      % Other*

Rent Controlled            63.38%         13.43%         3.33%
Rent Stabilized            10.84%         43.88%         6.35%
Neither of the Above       13.21%         18.44%        66.54%
Do Not Know                 9.46%         20.72%        18.62%
No Cash Rent                3.04%          1.56%         3.52%
Not Reported                1.07%          1.97%         1.60%

Source: 1991 NYC HVS

Note: This table was produced using computerized data.

* The unit of analysis "Other" refers to in-rem, HUD federally
subsidized, Article 4, Loft Board regulated, and unregulated

Tenant protections lose further meaning when the burdens placed
on tenants are examined. Virtually no investigations regarding
any aspect of the rent regulation system are instigated without a
tenant's filing a complaint. Thus, there is no proactive
enforcement and the burden to be protected falls upon tenants,
which heightens the importance of tenants knowing their rights.


Finally, enforcement on the part of DHCR is inadequate and even
deviates from what is required by the law. Partly because the
DHCR Office of Rent Administration is underfunded by the State
Legislature and the Governor, poor administration and enforcement
seriously undercut the effectiveness of rent regulation. The
problems became so serious a few years ago that the New York
State Assembly held public hearings on DHCR's administration of
rent laws in 1986 and 1987, publishing a report, Bleak House,(13)
that was extraordinarily critical of the agency. While some
improvements have been made since that time, enforcement is still

Despite the shortcomings mentioned above, rent regulated tenants
have much greater security than other tenants. This is indicated
by how long regulated tenants have remained in their apartments
[Table 15].

As illustrated by the data, rent controlled tenants have been in
their apartments the longest -- the result of vacancy decontrol
of rent controlled apartments, which has been in effect since
1971. However, the significant difference between stabilized
units and other housing also illustrates a promoted length of
tenure through regulation.

The flip side of prolonged tenure, some argue, is reduced
mobility for tenants and the "overconsumption" of housing. Length
of tenure is often presented as evidence of "housing gridlock."
However, vacancy decontrol -- the setting of rents at market
rates upon vacancy -- not rent regulation, is the true culprit in
this scenario. If all housing units were granted increases based
on costs and improvements, and rents were not allowed to be
increased upon vacancy, mobility would be enhanced for all
tenants. Those people wanting or needing to move could more
readily afford the rents of vacant apartments.


The quality of the housing in which people live is as important
as how much it costs them. A leading determinant of housing
quality, which is directly related to affordability, is
overcrowding. Housing quality also can be measured by building
deficiencies, maintenance deficiencies, and neighborhood


A key measure of habitability is how many people are living in
each room of a given apartment. Crowding may be seen as a
function of affordability, in that the more space a household can
afford, the less crowded a given living situation may be. For
analytical and practical purposes, it is generally held that any
apartment that houses more than one person per room is crowded.
Rooms counted include bedrooms, living rooms, dining rooms,
kitchens, and dens. Not counted are bathrooms or vestibules.

According to HVS findings, rates of crowding have been on the
rise in New York for the past four years. In 1991, 10.4 percent
of New York City households lived in crowded conditions, up from
7.1 percent in 1987. The level of crowding for renters varies
greatly depending on the control status of the housing [Table

                            Table 16
      Percentage of Households Living in Crowded Conditions
             By Control Status, New York City, 1991

          Status                           Percent

          Controlled                          3.0%
          Stabilized                         12.3%
          Other*                              9.9%

Source: NYC HVS 1991, Series IA, Table 28

* The unit of analysis "Other" refers to in-rem, HUD federally
subsidized, Article 4, Loft Board regulated, and unregulated

Because of the concentration of elderly tenants, rent controlled
households are more likely to be composed of single persons than
the other two control status categories are; thus the person-per-
room levels are much lower. No real connection between regulation
and crowding is illustrated by the data.

Building Conditions.

Building conditions are another key indicator of housing quality.
The data show that there is not a strong relationship between
building deficiencies and rent regulation [Table 17].

Rent controlled units have slightly fewer deficiencies overall.
Stabilized apartments have a greater number of deficiencies than
both controlled and other housing, though the difference is
rather small. Consistent with the findings of other research,(14)
the relationship here appears to be weak, if not insignificant.

                            Table 17
    Percentage of Households Reporting Building Deficiencies
             By Control Status, New York City, 1991

                       -- Number of Deficiencies --
Status          None       One       Two     Three      Four

Controlled     87.3%      5.8%      5.3%       .9%       .7%
Stabilized     83.4%      8.3%      5.0%      2.2%      1.1%
Other*         86.9%      6.3%      3.1%      2.3%      1.5%

Source: NYC HVS 1991, Series IA, Table 26

* The unit of analysis "Other" refers to in-rem, HUD federally
subsidized, Article 4, Loft Board regulated, and unregulated

Maintenance Deficiencies.

A contentious debate surrounding rent regulation is the effect it
has on housing maintenance and services [Table 18].

While the data indicate a higher number of deficiencies in
regulated housing, research has found greater determinants than
rent regulation in housing maintenance issues. According
Gilderbloom and Appelbaum: "Numerous studies have shown that
maintenance expenditures are unaffected by rent control."(15) In
fact, they assert that moderate rent controls, such as those in
New York City, may even encourage maintenance due to the ability
of owners to pass along maintenance and capital improvements
costs to tenants. Additionally, according to Peter Marcuse,

     Rent regulations permit rents sufficient for
     adequate maintenance and repairs, and major
     capital improvement provisions permit major
     repairs and improvements. But landlords, in a very
     tight housing market, do not have the economic
     incentive to make repairs: they can rent their
     units whether they are well maintained or not.
     Ending rent regulation will not automatically lead
     to improved maintenance.(16)

                            Table 18
                    Percentage of Households
               Reporting Maintenance Deficiencies
                        By Control Status

Number of Deficiencies     Controlled   Stabilized    Other*

None                            35.0%        32.2%     50.2%
One                             22.5%        21.5%     20.3%
Two                             18.0%        15.1%     11.3%
Three                           11.2%        11.8%      7.7%
Four                             8.3%         9.1%      5.3%
Five                             2.8%         5.8%      2.7%
Six                              1.8%         3.2%      2.0%
Seven                             .5%         1.4%       .6%

Source: NYC HVS 1991, Series IA, Table 53

Note: Maintenance deficiencies include a breakdown in heating,
additional heating required, rodent infestation, open
cracks/holes in interior walls and/or floors, broken
plaster/peeling paint and/or floors, toilet breakdown, and water

* The unit of analysis "Other" refers to in-rem, HUD federally
subsidized, Article 4, Loft Board regulated, and unregulated

Additionally, it is important to note that the rent regulated
housing in New York City tends to be older than unregulated
housing, which can create greater maintenance and service
problems. Moreover, due to a high level of conversion activity
throughout the 1980's, many of the highest-quality buildings were
removed from the rent regulated stock through condominium or
cooperative conversion. Thus, the data reflect the remaining
rental buildings, which were generally less well maintained in
the first place.

Neighborhood Conditions.

Housing is a good that is tied to place, so examining the
conditions in a neighborhood is useful [Table 19]. The indicators
used -- boarded-up buildings and buildings with broken windows --
are somewhat limited, however, since they are based on reporting
and observation.

                            Table 19
            Neighborhood Conditions By Control Status
                       New York City, 1991

                      Boarded-up        Buildings with
Status               Buildings**      Broken Windows***

Controlled               19.2%               14.7%
Stabilized               19.8%               15.2%
Other*                   21.3%               17.2%

Source: NYC HVS 1991, Series IA, Tables 55 and 56

* The unit of analysis "Other" refers to in-rem, HUD federally
subsidized, Article 4, Loft Board regulated, and unregulated

** Information on boarded-up buildings was reported by survey
respondents and refers to the neighborhood.

*** Information on buildings with broken windows is based on
enumerator observations and refers to the block.

Still, these two simple measures indicate that rent regulated
apartments are in neighborhoods that are no worse, if no better,
than neighborhoods with unregulated (included in "Other")

Within the context of neighborhood conditions, it is worthwhile
to raise some of the little-discussed benefits of rent
regulation. First, by moderating rent levels, rent regulation
aids in providing some degree of housing choice for tenants.
Second, by providing protection from eviction, rent regulation
promotes neighborhood stability. Thus, the neighborhoods of New
York City are more stable than they would be in the absence of
rent regulation.

Notes to Chapter 3

1.   Baar, Kenneth K., "Guidelines for Drafting Rent Control
     Laws: Lessons of a Decade," Rutgers Law Review, Vol. 35, No.
     4, Summer 1983, pg. 781.

2.   Marcuse, Peter, 1986, The Uses and Limits of Rent
     Regulation, pg. 50, New York City, Community Training and
     Resource Center.

3.   Gilderbloom, John and Richard P. Appelbaum, Rethinking
     Rental Housing, Philadelphia, Temple University Press, 1988,
     pg. 132.

4.   Ibid, pg. 132.

5.   Per compliance with Local Law 63 of 1986, which requires
     reporting of income and expenses of rental properties to the
     Department of Finance for tax purposes.

6.   Rent Stabilized Housing in New York City: A Summary of Rent
     Guidelines Board Research, 1992, New York City Rent
     Guidelines Board, October 1992, pp. 41-42.

7.   Ibid, pg. 44.

8.   DHCR Hardship Study, pg. 1. Presented to the Rent Guidelines
     Board of New York City, 1990.

9.   From Housing Court, Evictions and Homelessness: The Costs
     and Benefits of Establishing a Right to Counsel, 1993, by
     the City-wide Task Force on Housing Court and Community
     Training and Resource Center.

10.  It is important to note that unregulated tenants have only
     one basic right with regard to eviction: a requirement of
     warning, without need to examine or substantiate grounds
     above those specified in a given lease, if any.

11.  Community Training and Resource Center Fact Sheet, "Fighting
     Landlord Discrimination and Harassment," 1990.

12.  Ibid.

13.  New York State Assembly, June 1987, Bleak House: DHCR at the
     Crossroads. Findings and recommendations of the Joint
     Assembly Committees' Investigation of Rent Administration in
     New York State.

14.  Marcuse, Peter, 1981. Housing Abandonment: Does Rent Control
     Make a Difference? Washington, DC, Conference on Alternative
     State and Local Policies, Policy Report Number 4.

15.  Gilderbloom, John I. and Richard P. Appelbaum, Rethinhng
     Rental Housing, Philadelphia, Temple University Press, 1988,
     pg. 136.

16.  Marcuse, Peter, 1986, The Uses and Limits of Rent
     Regulation, pg. 73, New York City, Community Training and
     Resource Center.