We previously wrote about Local Law 110 – the new requirement to post violation copies in the lobby, and provide them to tenants if the violation occurred in their unit. While it looks like this requirement is being enforced by the DOB (not HPD), there are still some open questions on how this will be enforced. 

Here’s What’s Been Released

Local Law 110 mandated that owners would have to provide and post copies of open violations to dwelling units/in the lobby, as appropriate. For example, if a violation is for an area affecting all residents, it would be posted in the lobby. If a violation was issued for a specific unit, a copy would have to be provided to that unit, along with a department-created flyer. The copy and flyer must also be provided to adjacent units.

The DOB also released a Service Notice briefly outlining the requirements of the law.

The law was passed earlier this year, so the 180 day “in effect” date is 12/5.

Here’s What Hasn’t Been Released

Despite the fact that the law is currently in effect, no clarifying rules have been published by the DOB. This means that there are no guidelines for enforcement, no clarity on the type of violations included, and much confusion on how this will actually play out.

Here are the questions we’ve asked the DOB, and here’s what we’re hoping to find out:

• Do only DOB-ECB (OATH) violations need to be posted (as outlined in the DOB’s materials), or will this extend to other violation types/agencies?
• Are there any requirements for posting (more specifically than conspicuously in the lobby)?
• Does this apply to all buildings (commercial, residential, and otherwise), or are there exceptions?
• When can the violation copy be removed from the lobby?
• What violations or associated penalties will be issued for noncompliance?

We’ll let you know the answers to these as soon as they’re available.

Here’s How SiteCompli Can Help

SiteCompli users can access DOB-ECB (OATH) violation copies directly from their accounts, as they’re made available by the city. You can print available copies from SiteCompli and post them within the 5-day mandate period.

If you’re an InCheck user, we’ve also added a task to comply with LL 110 to each DOB-ECB violation workflow. This way, your team will never forget this critical step in the process. We’ve included a link to the city’s required flyer  directly in the Workflow, so it’s even easier for your team to click and print everything – the violation copy, and the flyer – and comply with the law.

If you’ve already activated a DOB-ECB workflow for your team, no worries – you can view our updated version from your Standard Operating Procedures page and edit your existing template.

Stay tuned for critical updates here – we’ll update your team as soon as the DOB provides more details.