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Building Owners Must Begin Filing RPIE Statements

Property owners are once again required to submit income and expense information to the City Department of Finance (DOF) so that the value of your property is accurately assessed.

Owners must fill out Real Property Income and Expense (RPIE) Statements that will be used to determine property values for the 2022-23 tax year tentatively slated to begin on July 1, 2021. Despite ongoing concerns with the COVID-19 pandemic, you are once again required to file RPIE statements by June 1st.
As a residential property owner, you are required to file the RPIE-2020, or a Claim of Exclusion, if your property has an Actual Assessed Value of more than $40,000 on the 2021-2022 Tentative Assessment Roll. Some properties are exempt and are not required to file either document, such as properties that have an assessed value under $40,000, contain 10 or less apartments, or are Class 1 or Class 2 properties with six or less units and at least one commercial space.

The RPIE-2020 statement must be filed online. Building owners who are senior citizens or disabled may apply for a waiver from the electronic filing by completing the RPIE electronic filing waiver application that can be found on the DOF website, or by calling 311. If the waiver is approved by DOF, the owner will be sent the RPIE-2020 form in the mail to complete and submit. The application for a waiver from the electronic filing can be found on the DOF website listed below.
If you are not required to file an RPIE statement, you may voluntarily file the RPIE-B form, which is a simpler form that the City uses to accurately value your property. Unlike the RPIE-2020 form, the RPIE-B can be filled out either electronically or manually and mailed directly to DOF at 66 John Street, 12th Floor, New York, NY 10038. To download samples of the RPIE-2020 forms, or for instructions on how to file your RPIE forms online, click here.

If you would like to file a Claim of Exclusion, you must complete Section D of the RPIE-2020 form. Owners who may file a Claim of Exclusion, for example, have property that is vacant or inhabitable and has no existing leases. If there are any existing leases, the owner must file the RPIE. Owners who wish to file a Claim of Exclusion, but have still not submitted the claim by the June 1st deadline, could be subject to a $100 fine and subsequent penalties for continued non-compliance.
DOF also offers a Short Form Option. If, on the 2021-2022 Tentative Assessment Roll, your property has an Actual Assessed Value of $250,000 or less and is not a hotel, you are permitted complete a new, shorter version of the RPIE application instead of the standard RPIE. If your property is eligible for the short form, you will be given the option when you begin the RPIE-2020 filing process online.

Furthermore, there are two additional filing requirements that went into effect last year that many owners must comply with. The Storefront Registry requires property owners who have ground-floor or second-floor storefronts to register these spaces on the RPIE statement. Owners can find these requirements in Section S of the RPIE statement. Additionally, beginning at some point over the summer, Class 2 and Class 4 building owners who have filed storefront information as part of their 2020 RPIE filing must also file a Supplemental Storefront Registration form to report any property ownership changes or storefront vacancies that occurred between January 1, 2021 and June 30, 2021 (or the date you sold the property, whichever is earlier).

The major filing requirement that owners must comply with is the RPIE Rent Roll Addendum, which requires RPIE filers whose properties have an actual assessed value of $750,000 or greater to file an addendum containing rent roll information. As you may recall, RSA led the charge last year against this latest filing requirement, which created much controversy after a compliance deadline appeared without warning on the DOF website. Even more alarming was that by the end of June 2020, DOF still had not provided any filing instructions, explanatory information, FAQS, or any other information that alerted property owners to this new requirement and how they must comply with it.

Despite DOF initially rejecting RSA’s concerns about the new requirement, our staff’s persistence ultimately led to a series of virtual meetings with DOF representatives over the summer that resulted in a much more simplified addendum. In addition to extending the filing deadline last year, DOF simplified the addendum to include only 10 filing requirements instead of the original 20 filing requirements. DOF also addressed another concern of RSA by eliminating the need for building owners to report rent roll information for both the former and current tenants if a tenancy changed during the current reporting period. Owners are now required to only report on the new tenant only.

DOF has since adjusted their FAQs on their website to reflect these changes. All FAQs and additional information about the RPIE and Rent Roll Addendum filing requirements can be found by clicking here. Please be advised that although the deadline to file the Rent Roll Addendum was extended through October last year, building owners are now required to submit the rent roll information, along with the RPIE-2020, by June 1st.

If you are required to file the RPIE-2020 and do not do so by the June deadline, you might be subject penalties based on the 2021-2022 Assessed Value of your property. Please visit http://on.nyc.gov/1ECCv19 for more information on all matters related to the RPIE. 

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