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Following a 2018 court ruling that Rent Stabilization Code (RSC) §2526.1(a)(3)(iii), as amended in 2014, does not have retroactive effect, the DHCR has reversed its prior position that the amended RSC provision applied retroactively to determine legal rents after owners had followed the prior RSC provision to set negotiated first rents after an extended vacancy or temporary exemption from rent regulation.