 In November 2007, the State's Division of Housing and Community Renewal (DHCR) - now NYS HCR - adopted regulations stating that just removing a pre-1974 Mitchell-Lama from the program is not a "unique or peculiar circumstance" justifying a substantial rent increase.Several landlords challenged that policy in court, asserting that it contradicts a court decision, "KSLM-Columbus Apts.v.