The City
of New York
Rent Guidelines Board
51 Chambers Street, Room 202
New York, NY 10007
212-349-2262
Chairman:
Aston L. Glaves
Public Members: Hilda Blanco, Barbara Gordon-Espejo.
Agustin Rivera, Jane Stanicki
Owner Members: Joseph L. Forstadt, Harold A. Lubell
Tenant Members: Leslie Holmes, Kenneth Rosenfeld
Executive Director: Timothy Collins
Director of Research: Douglas Hillstrom
April
27, 1993 To:
Members of the Board
From: D. Hillstrom
Subject: Commensurate Rent Increase The
commensurate rent increase is a formula which the RGB has used throughout
its history. The commensurate rent increase has been explained as the percentage
rent increase needed to maintain landlords' current dollar net operating
income (NOI) at a constant level. The commensurate rent increase for this
year is1:
One
Year LeaseTwo
year Lease
3.3% 4.0%
As a means
of compensating landlords for cost increases, the commensurate rent increase
formula has two major drawbacks. First. although the formula is supposed
to keep landlords' current dollar income at a fixed level, the formula
doesn't consider the mix of one and two year lease renewals. Since only
two-thirds of leases are renewed in any given year, and a preponderance
of leases are for two years, the formula does not necessarily accurately
estimate the amount of income needed to compensate landlords for past
O&M increases.
A second
possible flaw of the commensurate formula is that it does not consider
the erosion of landlords' income by inflation. By maintaining current
dollar net operating income at a constant level, adherence to the formula
may cause profitability to decline over time, although this is not an
inevitable consequence of using the commensurate.2 Of
course other factors (e.g. individual apartment improvement and MCI increases)
may mitigate these impacts.
An
alternative to the commensurate rent increase would consider the mix of
lease terms and sources of landlord revenue allowed by the RGB other than
lease renewals (e.g. vacancy renewals). We will call this the "Net Revenue" rent
increase. This formula takes into consideration the mix of leases actually
signed by tenants but does NOT adjust NOI for inflation. Depending on whether
revenue from a 5% vacancy allowance is included in these calculations,
the "Net Revenue" increase is3:
One
Year LeaseTwo
year Lease
3% 5.5%
(Vacancy allowance income included)
4% 6%
(Vacancy allowance income NOT included)
An
alternative to this "Net Revenue" formula would be to consider lease terms
and to adust NOI upward to reflect inflation so that BOTH O&M and NOI remain
constant. We will call this the "Adjusted NOI" increase, which would result
in the following figures4:
One
Year LeaseTwo
year Lease
4% 7.5%
(Vacancy allowance income included)
5.5% 8%
(Vacancy allowance income NOT included)
These "Adjusted
NOI" figures have a major drawback - we are adjusting the debt service
portion of NOI UPWARD by the inflation rate when in fact, interest rates
have been falling in recent years.5
All of these
methods have their limitations. The commensurate increase is artificial
and doesn't consider the impact of lease terms or inflation on landlords'
income. The "Net Revenue" formula does not attempt to adjust NOI based
on changes in interest rates or deflation of landlord profits. The "Adjusted
NOI" formula inflates the debt service portion of NOI, even though interest
rates have been falling, rather than rising. Finally, none of the formulas
consider the impact of the MCI program or individual apartment improvement
increases on landlord profitability.
Each
of these formulas may be best thought of as a starting point for deliberations.
The staff's other research (e.g. the mortgage survey or the I&E study)
and testimony to the board can be used to modify the various estimates
depending on these other considerations.
1 The
accuracy of the PIOC is assumed as is the collectability of legally authorized
increases. Calculating the Commensurate Rent Increase requires an assumption
about next year's PIOC. In this case we use 1.8%, staff's PIOC projection
for 1994.
2 Whether
profits will actually decline depends on the level of inflation, the
composition of net operating income (i.e. how much is debt service and
how much is profit), changes in tax laws, and interest rates.
3 The
following assumptions were used in the computations: (1) The required
increase in landlord revenue is 3.3%, or 70% of the 1993 PIOC increase
of 4.72%; (2) These lease terms are only illustrative. Other combinations
of one and two year lease increases could also result in a 3.3% revenue
increase. (3) Lease terms were derived from the 1991 NYC Housing and
Vacancy Survey. According to the HVS, 24.9% of all tenants have a one-year
lease and the remainder have two-year leases. As a result, 62.5% of tenants
renew their leases in a given year. The increase in landlords' revenue
reflects this lease distribution. (4) The 1991 HVS showed a turnover
rate of 9.7%. As a result of turnover, landlords can expect an increase
in revenue of about one-half percent, given the 5% vacancy allowance.
This assumes that the vacancy allowance is collectible in all cases.
4 NOI
was adjusted upward by the most recent yearly increase in the Consumer
Price Index, March 1992 to March 1993. This figure was 3.4%.
5 An
alternative would be to adjust only the portion of NOI which is "profit" upwards.
In fact, we do not know what average "profits" are, but if we assume a
figure of 10% of rent, the respective lease adjustments would be 4% for
a one year lease and 5.75% for a two year lease if vacancy allowance income
is included.