DHCR's determination, made in 1998, properly applied the four-year rule mandated by Rent Stabilization Law of 1969 (Administrative Code of City of NY) § 26-516 (a) (2), effective June 19, 1997 and applicable to pending administrative proceedings (L 1996, ch 116, § 46), to petitioner's overcharge complaint filed in 1990. "Administrative delay will not defeat the agency, absent a showing that the delay was willful or a result of negligence" (Matter of Goldman v...
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