RSL §26-517(e) states that the “failure to file a proper and timely initial or annual registration statement shall, until such time as a proper registrations filed,” freeze the stabilized rent. In overcharge cases, tenants will frequently point to any error in a registration as rendering it improper, such that the rent should be frozen.

The courts have established a general rule as to when a registration is deemed proper, and have also established an exception to that rule. The rule and its exception are examined below.

‘Enriquez v. DHCR’