Overcharge on Security...warrents treble, right!?

[NeGeMo]

Hi...I have a question. According to FS#26...LL can only collect one month's rent for a new tenant's security dep.

If the LL collected more than one month, wouldn't that be an overcharge amount. For instance, if the rent was $1,000 and LL collected $2,000 in security. Shouldn't the LL be found guilty of overcharging the tenant for $1,000!!

Why doesn't DHCR consider this part of the "overcharge" amount? They consider it to be just "excess security amount". The security should be trebled, right! It was an overcharge to begin with!

Any thoughts or opinions....

Regards

:p