Co-op boards have 21 days to protect their summer calendar.

On July 28, 2026, Local Law 2026/058 takes effect for every cooperative building in New York City with 10 or more residential units. From that date forward, a 15-day acknowledgment clock and a 45-day decision clock apply to every purchase application the board receives, with HPD enforcement and fines starting at $1,000 per violation. The law contains one formal mechanism to pause those clocks through the summer months: a written summer recess notice adopted by the board before the effective date. Today is July 7. There are 21 days left.

What the summer recess provision does.

Local Law 2026/058 permits a co-op board to toll both the 15-day acknowledgment deadline and the 45-day decision deadline during July and August. The mechanism is a formal "summer recess notice": a written board policy stating that the board does not ordinarily hold meetings during a specified period in the summer months.

If the board adopts this notice before July 28 and provides it to applicants as part of the standard transfer package, any statutory deadline that falls within the documented recess period is automatically paused until the recess ends. An application received on July 30, for example, would have its 15-day acknowledgment clock start the day after the recess period ends, not the day after submission. The 45-day decision clock follows the same rule.

The legislative record of Intro 1120-B acknowledged that most co-op boards in New York City do not hold formal meetings in July and August. The summer recess provision was drafted into the statute to accommodate that reality. It is not a workaround. But it functions only for boards that formalize it before July 28.

What the written notice must contain.

HPD has not issued a standard form for the summer recess notice as of this writing. Based on the statute's requirements as analyzed by multiple real estate law firms following Intro 1120-B's enactment, the notice must meet four conditions:

1. Specific dates. The notice must state the exact start and end dates of the recess period. The statute limits recess periods to July and August only. A board cannot invoke a December or March recess under this provision. Language like "we are unavailable in summer" does not satisfy the specificity requirement. Language like "the board does not hold regular meetings from August 1 through August 31, 2026" does.
2. Formal board adoption. The summer recess notice is not a managing agent's email to a buyer's attorney. It is a written policy adopted by the board and recorded in the cooperative's official minutes. A board resolution passed at a board meeting — or by written consent if the cooperative's bylaws authorize that mechanism — is the standard form for this kind of policy adoption.
3. Maintained in the cooperative's records and available upon request. If an HPD inspector or an aggrieved applicant asks whether a recess policy is in effect, the managing agent must be able to produce the written record. A policy that exists only in a board member's recollection or in an informal email chain does not satisfy this requirement.
4. Disclosed to applicants at the start of the transfer process. The notice is not something the board can present to an applicant after the fact to justify a missed deadline. The statute requires that applicants be told about any recess policy before they submit their documents. It must be part of the application package distributed to prospective buyers from the outset.

What happens if the board does not act before July 28.

A board that does not adopt a written summer recess notice before Local Law 2026/058 takes effect loses the tolling protection for the 2026 summer season. The statutory clocks do not pause for undocumented vacations.

Consider a purchase application received on July 28 — the first day the law applies. If the board has no recess policy on file, the 15-day acknowledgment deadline falls on August 12. If the board's members are traveling and no one sends the required email and registered mail acknowledgment by that date, the applicant may file an HPD complaint. The first-violation penalty is $1,000. The violation falls on the cooperative corporation and the managing agent jointly under the statute's liability structure.

A board that misses the July 28 adoption window has no recourse for the 2026 summer. The statute contains no provision for retroactive adoption. The board would need to adopt a formal recess notice before July 1, 2027, to have the protection in place for the following summer season.

The managing agent's role — and what they owe.

Under Local Law 2026/058, "cooperative corporation" is defined to include the managing agent. This is not a minor definitional note. Managing agents carry direct liability alongside the board for HPD violations, including missed acknowledgment and decision deadlines. A managing agent that receives a purchase application, logs it, fails to send an acknowledgment within 15 days, and does not flag the lapse to the board can be named in an OATH proceeding independently of whatever the board did or did not know.

The managing agent is also the person with the clearest day-to-day view of how purchase applications arrive, how the board schedules meetings, and what administrative steps are required before July 28. A board that has no in-house administrator is relying on the managing agent to track these obligations and raise them with the board in time to act.

In New York State, that managing agent is required to hold no license, no registration, and no demonstrated competency in the laws governing the buildings they manage. S.71, Senator Kavanagh's managing agent certification and registration bill, was referred to the Senate Committee on Judiciary on January 8, 2025. Albany adjourned in June 2026 without bringing the bill to a floor vote. That is the tenth consecutive session in which a managing agent licensure bill did not advance. The specific pattern in this case: a statute now holds managing agents directly accountable for missing an application deadline, and separately, for failing to set up the summer recess policy that would have prevented that violation. New York State holds no managing agent accountable for lacking the competency to know either thing. Companion: When Albany adjourned in June, four co-op reform bills had no vote.

The five steps before July 28.

The procedural steps required before July 28 are not complicated. A board that wants to preserve its summer calendar needs to:

1. Decide which dates in July and/or August constitute the recess period for 2026 (and whether to set the same dates for future years).
2. Draft a board resolution adopting the summer recess notice with those exact start and end dates.
3. Pass the resolution by board vote or written consent before July 28 and record it in the board minutes.
4. File the adopted resolution in the cooperative's official records in a location the managing agent can retrieve on request.
5. Instruct the managing agent to include the recess notice in every application package delivered to prospective buyers on or after July 28, 2026.

A one-page resolution is sufficient. Most co-op boards can accomplish this by written consent without scheduling a special meeting, if their bylaws allow that mechanism. If a board's next regularly scheduled meeting falls before July 28, the resolution can be passed there. If not, a written consent signed by the required quorum of board members is the practical path.

Bottom line.

Local Law 2026/058 gives co-op boards one formal mechanism for preserving their summer calendar after July 28: a written recess notice, formally adopted before the law takes effect, with specific dates, maintained in the building's records, and distributed to applicants from the first day of the application process. Without that document in place, the 15-day and 45-day clocks run without interruption from the moment an application arrives, even if every board member is out of the state. The adoption window closes July 28 and does not reopen for the 2026 season.

The person best positioned to draft that resolution and get it adopted in the next 21 days is the managing agent. That person is also the one named in HPD enforcement proceedings alongside the board when a deadline is missed. New York State does not require that person to hold a license. The managing agent licensure gap that this site has documented since its first post runs through every new compliance layer the city adds to co-op governance. Local Law 2026/058 is another layer. S.71 is another session without a vote.

Primary sources: NYC Local Law 2026/058 (Int 1120-B), enacted January 29, 2026, NYC City Council · NY Senate Bill S.71 (Kavanagh, 2025-2026 session), NYSenate.gov

Companion resources: NYC just made managing agents liable. They still need no license. · Co-op buyers now have a 45-day application clock. Condo buyers don't. · NYC co-op boards can reject you without a reason. Westchester County disagrees. · When Albany adjourned in June, four co-op reform bills had no vote. · Managing agent licensure gap → · Write to your representative about S.71 →