Zoning and land use

Zoning due diligence before you sign

Six records answer almost every zoning question on a New York City property, and all six can be pulled before the contract rather than after the deposit.

What zoning due diligence should a buyer do before signing a contract?

Quick Answer

Pull six records: the zoning district from the City Planning map, the certificate of occupancy history, the Department of Buildings property profile with permits and violations, the ACRIS chain for declarations and easements, a current survey, and the landmark and flood status. Read them together, because each one alone misleads.

Effect on a transaction

Who does this land on?

Every buyer of a New York City building or lot, and every buyer’s attorney negotiating the contingencies and the representations.

What governs it?

  • The Zoning Resolution and the zoning maps, which set what the lot may become
  • The Administrative Code certificate of occupancy provisions, which record what the building lawfully is
  • The Department of Buildings records, which show permits, objections, violations and prior filings
  • The recording statutes, because declarations, easements and zoning lot agreements bind only through the record
  • The Landmarks Law and the flood hazard rules, which each can foreclose plans the zoning would allow

How does the process run?

  1. Confirm the zoning district, any commercial overlay and any special purpose district for the specific block and lot
  2. Pull every certificate of occupancy in the record, including superseded ones, and read them floor by floor
  3. Pull the property profile: open permits, expired permits, objections, violations, complaints and any stop work order
  4. Search ACRIS for declarations of zoning lot restrictions, zoning lot development agreements, easements and covenants
  5. Order a current survey and reconcile the lot area against the zoning lot rather than against the tax map
  6. Check landmark status, historic district boundaries and the flood map, because either can override an otherwise good plan
  7. Turn the gaps into contract terms: representations, a zoning contingency with a real outside date, and seller obligations with deadlines

Where does it bite in a transaction?

  • A deposit goes hard before the certificate of occupancy history has been read
  • A development site is priced on floor area a recorded declaration already moved
  • A rental building is underwritten on units the certificate does not authorize
  • A landmark or flood constraint surfaces after the contingency period has expired

Which record answers the most questions?

The certificate of occupancy history, because it records what the City has approved floor by floor and how that changed over time. It is also the record most often skipped, since buyers read the current certificate and stop. The superseded ones are where the building’s actual history lives.

Is the tax map enough to establish lot area?

No. The tax lot and the zoning lot are different constructs, and floor area is measured across the zoning lot. A current survey plus an ACRIS search for declarations and zoning lot development agreements is what establishes the number a zoning analysis can rely on.

What belongs in the contract once diligence is done?

The gaps. Representations about the lawful number of units and the absence of undisclosed violations, a seller obligation to deliver specific documents by a date, a contingency tied to a defined outcome rather than to satisfaction, and an outside date. Diligence that does not change the contract has not been used.

What else should you read before you file or sign?

In the glossary

Zoning and land use

Have a closing coming up?

Tell us about the transaction. An attorney reads every intake form and responds the same business day.

Legal Disclaimer: This page is general information about New York practice. It is not legal advice, it does not account for the terms of any particular contract, building or transaction, and reading it does not create an attorney-client relationship. This is attorney advertising. Prior results do not guarantee similar outcomes.