N.Y. Real Property Law § 339-w

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N.Y. Real Property Law § 339-w requires condo boards to keep financial records open to unit owners on weekdays and render a report at least once annually.

Official text N.Y. Real Property Law § 339-w — New York

§ 339-w. Books of receipts and expenditures; availability for examination. The manager or board of managers, as the case may be, shall keep detailed, accurate records, in chronological order, of the receipts and expenditures arising from the operation of the property. Such records and the vouchers authorizing the payments shall be available for examination by the unit owners at convenient hours of weekdays. A written report summarizing such receipts and expenditures shall be rendered by the board of managers to all unit owners at least once annually.

Text as published in the 2026 snapshot of the code.

Source: Vaquill Open US Law, compiled from official state publishers (huggingface.co), reproduced under license CC BY 4.0.

Read this provision at the official source →

What it actually says

Three obligations in four lines. The manager or board of managers shall keep detailed, accurate records, in chronological order, of the receipts and expenditures arising from the operation of the property. Those records - and the vouchers authorizing the payments - shall be available for examination by the unit owners at convenient hours of weekdays. And a written report summarizing the receipts and expenditures shall be rendered by the board to all unit owners at least once annually.

The inclusion of vouchers is what gives the right substance. A summary of expenditure invites the answer that the board has already provided it; the statute goes past the summary to the documents authorizing each payment. "Detailed, accurate" and "in chronological order" are standards for how the records are kept, not merely that they exist.

The section says nothing about a purpose requirement, a written demand, a fee, or a deadline for producing the records - it fixes availability at convenient weekday hours and stops. It also says nothing about minutes, contracts, correspondence, legal advice or the owners' register, which are outside its subject matter of receipts and expenditures. Where a board simply refuses, the enforcement route is not in this section; § 339-dd governs actions relating to the common elements and the by-laws set out the governance machinery.

When it applies

  • A board refuses to let an owner see the accounts before a vote on a special assessment.
  • An owner asks for the invoices behind a large maintenance expenditure and is given only a summary.
  • No annual written report of receipts and expenditures has been circulated for years.
  • An owner suspects payments to a contractor connected with a board member.
  • A managing agent says records may be inspected only by appointment months ahead.

What this section does not say

  • It is not a right to all documents. The subject is receipts and expenditures and the vouchers authorizing payments - not minutes, contracts, correspondence or legal files.
  • It sets no deadline. "Convenient hours of weekdays" is the only timing the section gives.
  • It does not entitle an owner to copies, or set what may be charged for them.
  • It creates no penalty for refusal and no damages. Enforcement comes from elsewhere.
  • It does not require an audit. An annual summary report is what the section requires.

Worked examples

Invented situations, written to show how the wording bites. They are not real cases, not judgments and not precedent, and nothing here predicts what would happen in yours.

Illustrative example

A board asks owners to approve a large special assessment but will not let anyone see the invoices behind the figures, offering a one-page summary instead.

How the wording applies

The board must keep detailed, accurate records in chronological order of receipts and expenditures, and those records and the vouchers authorizing the payments shall be available for examination by unit owners at convenient hours of weekdays. The vouchers are what give the right substance - a summary invites the answer that it has already been provided. So it turns on the vouchers rather than on the summary.

How the parties settled it

The managing agent sets three inspection sessions on ordinary weekdays with the vouchers laid out, and the vote is deferred until after the last of them.

Illustrative example

An owner asking to inspect the accounts is told the only appointment available is four months away, at the agent's office an hour outside town.

How the wording applies

The section fixes availability at convenient hours of weekdays and stops there: it sets no deadline, requires no stated purpose or written demand, and says nothing about copies or what may be charged for them. So the only thing in dispute is whether what is being offered is convenient, which is the sole standard the text supplies.

How the parties settled it

They agree two dates within the month at the building itself, with the owner free to photograph documents rather than asking for copies.

Illustrative example

An owner suspicious about payments to a contractor connected with a board member asks for the minutes, the correspondence and the contract itself.

How the wording applies

The subject of the section is receipts and expenditures and the vouchers authorizing payments - not minutes, contracts, correspondence or legal files, which fall outside it. And the section creates no penalty for refusal and no damages: where a board simply refuses, the enforcement machinery is elsewhere, in § 339-dd and the by-laws.

How the parties settled it

The board produces the vouchers as the section requires and volunteers the contract as well, in exchange for further questions being raised at the annual meeting rather than by weekly email.

How courts have read it

Decisions construing this provision. The question and the summary are ours; the quoted sentence is the court's own words, taken from the published opinion. These are the decisions in our corpus, not every decision there is, and nothing here predicts any other case. Reported 2003 to 2017.

Pomerance v. McGrath, 143 A.D.3d 443 (2016)

Appellate Division

What the court had to decide

What is the scope of a condominium unit owner's right to inspect and receive copies of the association's records under Real Property Law § 339-w and the common law?

What it held

The court held that Real Property Law § 339-w grants unit owners the right to examine records of receipts and expenditures and vouchers during convenient weekday hours, and the board must deliver an annual report, but the statute does not require the board to deliver copies; however, the unit owner has the right to make paper or electronic copies at her own expense during inspection, and any confidentiality concerns can be addressed by a confidentiality agreement.

In the court's words
Real Property Law § 339-w requires the board to deliver an annual report summarizing receipts and expenditures, while merely conferring on a unit owner the right to examine records and vouchers of receipts and expenditures during convenient hours of the weekday.

Board of Managers v. Park Regent Unit Owners Associates, 58 A.D.3d 589 (2009)

Appellate Division

What the court had to decide

Whether the defendants could obtain relief under Real Property Law § 339-w to inspect the books and records of the condominium in the absence of a counterclaim based on that statute.

What it held

The court held that because the defendants did not assert any counterclaim based on Real Property Law § 339-w, there was no jurisdictional predicate for granting relief under that statute in the action, and thus the motion to inspect was properly denied.

In the court's words
Inasmuch as the defendants did not assert any counterclaim based on Real Property Law § 339-w, there is no jurisdictional predicate for granting relief pursuant to that statute in this action (see Seebaugh v Borruso, 220 AD2d 573 [1995]).

Source: Caselaw Access Project, CC0 1.0 Universal (public domain dedication).

Related sections

N.Y. Real Property Law § 339-m RPL § 339-m: how condominium common charges are apportioned N.Y. Real Property Law § 339-x RPL § 339-x: you cannot escape common charges by not using the building N.Y. Real Property Law § 339-z First Mortgage Superior: N.Y. Real Property Law § 339-z N.Y. Real Property Law § 339-i Condo Board Access Rights | N.Y. Real Property Law § 339-i

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We copy this text from the official publisher and re-check it against that source on every page load, but we cannot guarantee it is complete, current or free of error, and we accept no liability for any reliance on it. An amendment can take effect before a consolidation catches up. The publisher's own copy is linked below; where the two differ, it is the official one that counts.

This page reproduces the text of N.Y. Real Property Law § 339-w in force at the date shown and explains it in general terms. It is not legal advice and takes no account of the circumstances of your case, which can change the answer completely. For a live dispute, for limitation periods, and before taking any step in court, consult a qualified lawyer in New York.

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