![]() ![]() I also welcome the amendments supporting more democracy at M-L co-ops to the Private Housing Finance Law which became law one year ago in March of 2022. I welcome this opportunity to comment on the HPD’s proposed rule changes. I agree with HPD’s having rate of pay and staffing information. I agree with the insertion to the website of the redacted Board contracts and essential information. I agree with all Directors go through essential training with HPD In favor without objection to this ruling. Where it reads: In the event that any Director /Officer, Shareholder, employee, or agent of any housing company shall be directly or indirectly connected with any person, firm, or corporation which may submit any bid or to whom any contract is proposed or awarded shall be part of the minutes and submitted to HPD. I object to having the housing company’s attorney or accountant monitor the election instead have an independent company handle the election process in its entirety. ![]() ![]() Where it reads: Prohibit the housing company attorney or account from serving as the election monitor. Board Directors and the Managing agent need to be accountable for every expense authorized by them. ” I totally agree with this change and should be enacted without objection. Page# 3 paragraph # 10 Require the Managing agent to notify HPD if the housing company makes payments to and /or incurs charges from any vendor or service provider that in the aggregate equal or exceeds $100.000 in any twelve-month thereafter prohibits further charges to be incurred without the prior written approval of HPD. I object to this unless adequate training or information is given to all employees prior to enacting it. Page # 3 paragraph # 7 – Require the Housing company to remove any of its onsite employees where any such employee has violated the Private Housing Finance Law and/or applicable rules and directives, consistent with any internal grievance procedures -I questioned whether this includes “Union Employees like 32bj ? ” Many are not familiar or knowledgeable in Private Finance Laws and Procedures including Management. ![]()
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