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Initial Building Services Registration- Front Desk Question

NYC Rent Regulation: Rent Control/Rent Stabilized, DHCR Practice/Procedures

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Initial Building Services Registration- Front Desk Question

Postby slumlords » Tue Jun 26, 2018 3:39 pm

Hello,

Our LL has decreased the front desk presence dramatically over the years and last weekend a severe physical assault happened in our lobby with no attendant present to help. Still, the LL refuses to add more hours to the front desk position.

Notably, LL checked off "Front Desk/Secretarial" option on our building's Initial Building Services Registration Form, however I have not been able to find any legal requirements or definitions for what a "Front Desk/Secretarial" role entail. It seems to only be mentioned once in the RS laws in regards to housing accommodations in hotels (we are not a hotel).

Is "Front Desk/Secretarial" assumed to be 24 hour role based on the missing "hours provided" option for it on the form? If so, we could file a building-wide service decrease.

Any insight would appreciated.
slumlords
 
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Re: Initial Building Services Registration- Front Desk Quest

Postby TenantNet » Tue Jun 26, 2018 4:18 pm

You have a problem as DHCR some times takes the position that the hours/duties of the front desk employee can be changed if they can be persuaded (not too hard to do that) that a reduction in the hours/coverage will not impact the tenants.

Still you should probably file a reduction in services complaint with DHCR. There are no requirements for such staffing. However, if such services were provided, the LL can't just decrease it without permission of DHCR.

But before you do that...

a) if you don't already have a tenant association, organize one. Your chances go up with more people
b) consult with a tenant attorney on the trade-offs of filing with DHCR or going to court.

c) do a lot of research as to the hours/duties of the personnel before the reduction occurred. The old staffing might have been 24 hours a day, but the LL might claim it's only needed 8 hours a day. The check on the RR1 form (initial services from 1984) is good, but it doesn't say how things were done.

Has anyone else complained on this since 1984? Do others have photos, letters of complaint to the LL or other things that can show the nature and degree of coverage?

d) look into DHCR decisions regarding building staff, including elevator operators.
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Re: Initial Building Services Registration- Front Desk Quest

Postby slumlords » Tue Jun 26, 2018 5:18 pm

It's a 421-a building that opened in 2009. I have digital complaints from people about the lax security (including several incidents of burglaries, assaults and trespassing) spanning 8 years. Early on we had someone at the desk about 18 hours a day starting around 10/11am - 6/7am the next day with a 3 hour break in the late afternoon. For at least 7 years now we've only had about 6 hours of coverage from 8/9pm -3/4am (though non-residents getting in to the building has been a steady problem since opening, regardless of front desk presence.)

We're having a tenant meeting tonight and I had planned to include the dhcr as an option, so I'll keep to it. Thanks for the response!
slumlords
 
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Joined: Tue Nov 15, 2011 12:45 am

Re: Initial Building Services Registration- Front Desk Quest

Postby TenantNet » Tue Jun 26, 2018 5:45 pm

Yes document everything. The loss of security also impacts the market rate tenants, so get them involved. They don't have DHCR, but they have their leases. Scrutinize the fine print of those leases. And with 421-a, either DHCR or HPD (or maybe both) will have copies of the regulatory agreement. You should FOIL copies of that.

DHCR is certainly an option, but so is court. I'd consult with a tenant attorney on this.
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Re: Initial Building Services Registration- Front Desk Quest

Postby slumlords » Tue Jun 26, 2018 6:18 pm

Alright, thanks very much!
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