A managing agent illegally evicted four tenants. New York has no license to revoke.

The settlement the Office of the Attorney General reached with Spigro Management, LLC in 2026 is a case study in what "no license required" means in practice. Spigro manages more than 40 buildings, including co-op and condo structures, across New York City. Its lead property manager, Saul Friedman, supervised a pattern of illegal lock changes that displaced four tenants between 2020 and 2025. The AG investigated for more than a year under the only statute available for the job: Executive Law §63(12), the general fraud authority. The total remedy was $23,500 in civil penalties and roughly $4,800 in restitution. No certification was suspended. No professional record was flagged. New York has neither.

What Spigro Management did, and how long it continued.

Spigro Management, LLC is based in Brooklyn. It holds management contracts across more than 40 residential buildings totaling more than 3,000 units in New York City. A number of those buildings are co-op and condo structures that retain pre-conversion tenants, residents who lived in the building before an ownership change and who remain under rent-stabilization protection after conversion. The managing agent serves both the board and the building's remaining stabilized residents simultaneously, under separate legal obligations to each.

Between 2020 and 2025, occupants in at least four Spigro-managed properties in Brooklyn and the Bronx were locked out of their apartments without a court order. A court order is required under New York law before any residential occupant can be involuntarily removed. Changing the locks without one violates both Real Property Actions and Proceedings Law §853 (unlawful eviction) and NYC Administrative Code provisions prohibiting self-help eviction. The conduct is not ambiguous. It continued, across four separate incidents, across five years. No state agency was monitoring for it. There was no licensing body to receive a complaint and no professional credential on which a complaint could be filed.

The only statute available: Executive Law §63(12).

The OAG opened an investigation in May 2025 after receiving complaints from affected residents. The bureau that handled the matter was the Housing Protection Bureau, the same bureau that brought the AG's first rent-stabilization enforcement actions in June 2026 under the same authority. That statute is Executive Law §63(12), which authorizes the AG to investigate and seek relief against "repeated fraudulent or illegal acts." The provision is the AG's broadest general enforcement tool for consumer and housing protection. It does not require that the underlying conduct arise from a licensed profession. It requires only a pattern: a single incident is typically not enough to trigger action.

Four incidents across five years satisfied the pattern requirement. The AG's investigation ran from May 2025 to the announcement in 2026, roughly fourteen months. The product was an Assurance of Discontinuance (AOD), a consent agreement under which Spigro and Saul Friedman agreed to stop the conduct in exchange for the AG's agreement not to file suit. An AOD is the workhorse of §63(12) enforcement. It can impose penalties and behavioral requirements. What it cannot do is limited by the underlying legal landscape.

What the settlement can and cannot accomplish.

Under the terms of the AOD, Spigro and Saul Friedman are required to:

• Pay $23,500 in civil penalties to the OAG
• Pay between $1,000 and $1,200 in statutory and compensatory damages to each of the four affected tenants (total: approximately $4,800)
• Adopt a written internal lockout policy specifying the legal authority required before any lock change
• Document every lock change, including the legal basis, and retain those records
• Post written notice of tenant rights in each managed building
• Report any future illegal-eviction complaints to the OAG within a defined period
• Submit to three years of OAG monitoring and compliance review

The structural limit of an AOD is what it cannot produce. Spigro and Saul Friedman may continue operating as managing agents in New York state. There is no professional record flagged in any searchable registry. No building board searching for a new management firm in 2027 will find this settlement in a licensing database, because no licensing database exists. The remedy is behavioral compliance overseen by the AG, which is a substitute for the oversight a professional licensing regime would provide structurally.

What a licensing regime would make possible.

Senate Bill S.71, sponsored by Senator Brian Kavanagh, would require property managers of cooperatives and condominiums to register with the Department of State and hold a certification from an approved certifying organization. A certifying body would be authorized to revoke or suspend certifications. The bill's sponsoring memo states the purpose: to assure that property managers "have the training, competency and integrity to adequately perform their duties."

If S.71 were in effect when Spigro's pattern emerged, the Assurance of Discontinuance could have formed the basis for a certification proceeding. Any building board considering a contract with Spigro could have searched a public registry and found the record. Future residents in Spigro-managed buildings would know, before a lock was changed, that their building's manager operated under a standard of conduct that could be revoked.

None of that is available under current law. A managing agent in New York holds no credential that accountability can attach to. The AG can sanction illegal conduct under §63(12). But once the AOD is signed and the penalties paid, the enforceability clock resets. A second pattern would require a second investigation.

S.71 and ten sessions without a committee hearing.

S.71 has been introduced in ten consecutive legislative sessions at the NY Senate. The bill covers the same ground in each session: registration with the Department of State, certification from an approved organization, and a recertification requirement. In the 2025-2026 session, the bill was referred to the Judiciary Committee in January 2025. Albany adjourned on June 5, 2026 without scheduling a committee hearing. The bill did not reach the floor. No recorded vote was taken.

The industry position, advanced in prior testimony by trade groups representing managing agents and commercial real estate firms, is that voluntary professional credentials (CAM, CPM, ARM) already serve the function a licensing regime would provide. The Spigro case illustrates the gap in that argument directly: voluntary credentials can be awarded and withdrawn only by the organizations that grant them. They are not tied to any state enforcement action. Spigro and Saul Friedman could hold voluntary credentials and continue holding them after the AOD was signed. A state license is the only credential whose revocation can be triggered by a regulatory finding.

The 2025-2026 session closed with four co-op reform bills still in committee, S.71 among them. As a legislative matter, the question is not whether the managing-agent registration gap exists. The AG's own enforcement action confirms it exists. The question is whether the legislature will schedule a hearing.

Bottom line.

Spigro Management's misconduct was real, documented by the state's top law enforcement office, and resolved through the only enforcement path New York law makes available. The AG can reach illegal acts through §63(12). What §63(12) cannot produce is a professional consequence that follows the managing agent beyond one settlement. The firm may file new management contracts tomorrow without disclosing the AOD, without submitting to any licensing body, without demonstrating that practices changed beyond what the OAG is monitoring for the next three years. A barber who altered someone's property without consent would risk losing a state license. The person managing your co-op or condo building has no license to risk.

Primary sources: AG press release, Spigro Management settlement (2026) · Assurance of Discontinuance (PDF) · Executive Law §63(12) · RPAPL §853 · NY Senate S.71 (2025-2026)

Companion resources: Managing agent licensure gap (issues page) · No public managing agent registry · S.71: the managing-agent licensure bill nobody's talking about · NYC just made managing agents liable. They still need no license. · Why the NY AG can't help with most condo governance disputes · What the AG's rent-stabilization lawsuits reveal about the condo governance gap · Managing agent registry · Write to your representative about S.71