The tenant path: the lease, and the tenant's records

The rule asks for the lease plus the tenant's own residency documents. The second half is where responses stall, because those documents are somebody else's to produce.

The tenant has to be a person

Under the final rule the lessee or sublessee must be a natural person. An LLC on the lease cannot establish primary residency, whatever the individual behind it does with the unit. Where a company holds the lease and a person lives there, a different criterion is in play, not this one?

Arm's length

There is no one-year lease requirement

Nothing in the rule requires a lease of any particular term. The final rule went the other way and added documentation pathways for renters under month-to-month lease or sublease agreements, the additional rental documents defined at 19 RCNY 62-01. A shorter or informal arrangement changes what you file, not whether you can file.

The tenant's half of the file

• The signed lease or sublease covering the period.
• For month-to-month leases and subleases, the additional rental documents the final rule provides for.
• The tenant's most recent federal or state income tax return showing the address, or their driver's license or other DMV-issued identification on its own; if neither exists, a voter identification card plus one other proof.

Practical order of operations: ask the tenant before anything else, because their half of the file sets the pace of the whole response. Then work the checklist in order. The criterion itself, and what happens when a tenant moves out mid-year, are set out on the tenant path.