The rights of shareholders to transfer their shares vary from building to building. The answer lies in the co-op’s governing documents.

By Jill Terreri Ramos The New York Times Real Estate

Q: I live in a Housing Development Fund Corporation, or HDFC, co-op in New York City. Recently, an original shareholder added her adult daughter as a shareholder, and the daughter is a chronic nonpayer. The board doesn’t think she can afford the apartment, and would like the chance to financially vet her. After the daughter moved in, the original shareholder moved to a different HDFC co-op, but the shares were never transferred. Can we require that the shareholder certificate be revised to reflect the daughter’s sole ownership? And can the board financially vet her as a sole shareholder?

A: If the daughter has already been added to the lease, then the board cannot go back and vet her after the fact, unless there was some conditional agreement when she was added. What’s done is done.

Peter Massa, a partner at Fox Rothschild in New York who works with condominium and co-op boards, suggested checking the co-op’s governing documents, regulatory agreements and records for this unit. Was the daughter actually added to the lease? Look to see if there are transfer fees, and read the assignment provisions to see what the board’s review rights are.

If the daughter was never added to the lease, then she may be there illegally. It’s possible that shareholders in your building have a right to transfer their shares to a family member without board consent, but the board can likely prevent any transfer until the maintenance is paid.

Like other co-ops, the board in a Housing Development Fund Corporation co-op has a duty to manage the co-op’s finances in the interest of all shareholders. (There are more than 1,100 HDFC co-ops in New York City, and they have income and resale restrictions.) Almost all HDFC co-ops require owner occupancy, so the original shareholder could be in violation of this rule. But, generally, it’s not in the co-op’s interest to enforce this, since the daughter is a shareholder.

“You want to be able to have her on the hook,” said Darryl M. Vernon, a partner at Vernon & Ginsburg in New York. “She might be able to get her daughter to pay.”

If the daughter isn’t paying the maintenance, you can take action against her — either a nonpayment case or a chronic nonpayment case, depending on how many times she’s failed to pay. In a nonpayment case, the daughter can pay and stay in the apartment, but a chronic nonpayment case could lead to an eviction.

“It’s rare, but it can happen if it’s extreme,” Mr. Vernon said.

Chatsworth Consulting Group by Robyn McLeod |

On a recent coaching call, my client talked about one of his direct reports needing to be more strategic. He was frustrated and felt that this person just didn’t have what it takes to be successful in their role long term. I asked him how he defined “strategic” and whether he had ever discussed this in more depth with his direct report.

I already knew the answer to those questions because my client tends to operate at a very fast pace and assumes that “everyone knows what strategic means.” But everyone doesn’t know what strategic means to him and what that looks like in terms of work performance. Could it be that if he took the time to share what he wants in a “strategic leader” at his organization that he just might find that he already has it?

These types of misunderstandings and miscommunications happen often. We leave a meeting feeling assured that everyone is in agreement and has their next steps and assignments well in hand, only to revisit the very same discussion at the next meeting and realize that much remains unresolved after all. This happens in delegation too. You think you have delegated a project and have that off of your plate, only to find that what you were expecting was not what you received and now it’s back on your plate.

The key to successfully navigating these interactions is to get to shared understanding – to move from “my view and your view” to “our view.” Here are some ways to do that:

• Share perspectives – Solicit others’ perspectives and share your own. Look for where your perspectives align and where they may conflict. The more information we have, the more likely we can gain understanding and avoid misunderstanding.
• Uncover what is not being said – Body language is just as important as spoken words when it comes to eliminating misunderstanding. Tuning in to those signals and clues, like facial expressions and body positioning, can provide an opening to inquire about what the person may be feeling but not expressing.
• Devote needed time – As I suspected with my client, not taking the time to have a complete two-way conversation will inevitably lead to misunderstandings. When it is important and agreement is needed, carve out the necessary time.
• Ask open-ended questions – Getting to shared understanding requires depth of understanding. Yes or No answers are never enough. Draw out information from others by asking great open-ended questions. For delegation, try “What are the commitments and next steps coming out of this conversation?” For getting buy-in on an idea, ask “What have I missed?” For confirming that you are on the same page, say, “I’d like to know what you see as the agreements we’ve just made.”
• Get specific on definitions and terms – Words can be meaningless if there is not a common definition among those in conversation. My client believed that “strategic” is a term that is universally understood and yet his direct report was not exhibiting the strategic behaviors he was looking for. Defining “strategic” and what it looks like will reduce misunderstandings in evaluating the employee’s performance.
• Don’t avoid the uncomfortable things – Often misunderstanding comes from avoidance – avoiding conflict, avoiding critical feedback, avoiding having the tough conversation. We may hope that the situation takes care of itself or that it really doesn’t matter in the grand scheme of things, but that is usually not true. Stepping out of your comfort zone and into a space of uncertainty and discomfort makes it possible to learn more about yourself and others and get to a place of shared understanding.

Misunderstandings happen all the time. There may be times when it’s OK and nothing suffers but, more than likely, unresolved misunderstandings will create tension, build up silos, and lead to lower team and organizational performance. Taking steps to address this issue is part of being a Thoughtful Leader.

By Kelly G. Richardson, Esq., HOA Homefront Column

Dear Mr. Richardson: Our HOA board recently changed the rules without notifying owners. Does this invalidate the changes? Thanks! J.G., San Diego

Dear Kelly: In our HOA there is limited parking available. The HOA is now requiring everyone to clean out their garage and park at least one car in it. There is no rule in the rules and regulations stating this. Are they allowed to even make this new rule? L.C., Huntington Beach

Dear J.G. and L.C.: Per Civil Code Section 4350(a), an enforceable “operating rule” must be in writing. Rules cannot conflict with the HOA’s articles of incorporation, CC&Rs or bylaws, per Section 4350(c). Also, the rule change process must substantially comply with the procedural requirements of Civil Code 4360. Some HOAs have “rules” which are simply board pronouncements – those are not enforceable but at most policy statements.

The verbatim content of a proposed rule or rule change must be first announced to the membership in verbatim form, along with an explanation of its purpose, at least 28 calendar days before the board considers it. Then, at the open board meeting to vote on the change attending members must have the chance to comment. I don’t think failing to announce and then vote upon a proposed change in an open board meeting substantially complies with the required procedure.

Civil Code Section 4355(b) lists some exceptions to the process requirement, most notably that the 2-step 28-day process is not required for rule changes required to comply with law or which repeat something already elsewhere in the CC&Rs or bylaws.

Best regards to you and your HOAs, Kelly.

Dear Mr. Richardson: Does our board have the right to temporarily suspend or not enforce a rule(s) that are in our rules & regulations, our CC&Rs, or the master CC&Rs? Our board voted to suspend enforcement of some holiday decoration rules but did not say which holiday rules. Last year families defied all our holiday rules. These suspended rules now contradict our HOA CC&Rs and master CC&Rs, which state there can be no difference from the master CC&Rs unless it is more restrictive. I have found nothing on the right of HOA Boards to suspend HOA rules. Sincerely, J.M., San Diego

Dear J.M.: Association boards have discretion under the Business Judgment Rule to decide not to enforce a rule if the violation does not merit HOA effort or expense, per the 1977 Beehan v. Lido Isle appellate decision, or to reasonably interpret their governing documents, per the 2018 opinion in Eith v. Ketelhut. However, boards cannot simply ignore clear language of their CC&Rs, per the Ekstrom v. Marquesa at Monarch Beach ruling from 2008.

Another issue you reference is the master CC&Rs, which means there is an authority superior to the HOA board in this regard – the master association board. An important question is whether the HOA board is exposed to possible action by the master association. 

J.M, I like holiday decorations as much as the next person, so long as they are attractive in appearance. If the HOA wishes to have a seasonal moratorium on decorations, instead of temporarily ignoring their rules, perhaps a more effective approach would be to modify the rule to match the community desires.

Best regards, Kelly.

Carnegie Hill, Manhattan

HABITAT Magazine

A messy and complicated dispute between a condo board and its commercial unit-owner has landed the parties in court while highlighting the importance of reaching an alteration agreement before work begins.

The dispute is between the condo board and the commercial unit-owner at 1055 Madison Ave., a 27-story, postwar building with a distinctive double-height base level clad in granite. This ground floor level contains, among other things, the building’s residential lobby and a single commercial unit.

The commercial unit-owner proposed subdividing the commercial unit into three different retail spaces. In order to do so, the unit-owner had proposed punching additional shop windows through the granite facade near the corner, disassembling a mezzanine level and catwalks used to access certain building pipes and valves located in the ceiling above the commercial unit’s 20-foot high interior space, and drilling anchorages into the granite facade to hang new signage for the prospective new retail tenants.

The parties engaged in lengthy negotiations over an alteration agreement but could not come to terms. Undeterred, the commercial unit-owner went ahead and did all of the work contemplated by the unsigned alteration agreement anyway.

Bring in the lawyers. The board sued, and a lower court issued a decision that denied most of the relief sought by both parties. Even though it agreed that the board had an easement to access the building pipes and valves, the court denied the request for relief ostensibly because the board had a contractual remedy to restore access. With respect to the exterior windows and signage, again the court denied relief even though it conceded that the unit-owner had installed the windows and sign without permission. The ruling stated that the unit-owner would suffer a “hardship” if its improperly installed windows and signage were removed.

On appeal, the Appellate Division, First Department found that the board should have been granted a declaratory judgment that the unit-owner had no authority to alter the exterior facade or demolish the mezzanine and catwalks without board permission, noting that a showing of “irreparable harm” is not a predicate for granting relief. On the other hand, the court largely refused to disturb the lower court’s decision denying injunctive relief to the board, finding that requiring the unit-owner to restore the catwalks and removing the signs would be “extremely costly” and “disruptive to defendant’s tenants,” even though the board had produced expert testimony that the lack of immediate access to the building pipes constituted a continuing violation of the Building Code.

It is unclear from the decision how the board’s easement to access building pipes and valves will be restored. In addition to being a regulatory requirement, this is clearly a safety issue, and it will be imperative for the board to exercise its contractual right and fiduciary obligation to enter the commercial space and restore that access as soon as possible. Unless the parties are somehow able to negotiate a settlement, it seems inevitable that as soon as the board’s contractors arrive to restore the catwalks, the parties will be back in court.

The moral of this ongoing legal saga is clear: come to an alteration agreement before the alterations begin.

This is a lightly edited version of an article that appears in the March 2026 Condo/Co-op Digest prepared by the law firm Moritt Hock & Hamroff.

Filing Deadlines, Extensions, & Further Information

By Cooperator Staff 

The NYC Department of Buildings (DOB) published a service notice at the end of February reminding boards, managers, and building owners of the 2026 filing deadlines for the City’s local sustainability laws, including: 

Benchmarking Energy & Water Use

Buildings covered by Local Law 84 must submit benchmarking reports by May 1. For a detailed explanation of the requirements, visit nyc.gov/LL84.

Energy Efficiency Scores & Grades 

Buildings covered by Local Law 33 must post the Building Energy Efficiency Rating Label near each public entrance starting October 1 and no later than October 31. For a detailed explanation of the requirements, visit nyc.gov/LL33. 

Greenhouse Emissions Reductions

 Buildings covered by Local Law 97 that are required to demonstrate compliance in 2026 must submit a compliance report by May 1 and no later than June 30. Buildings also have until June 30 to apply for a 60-day filing extension. For a detailed explanation of the requirements, visit nyc.gov/LL97. 

Lighting Upgrades & Submeter Installation 

Buildings covered by Local Law 88 that have not yet demonstrated compliance must submit a compliance report by May 1. For a detailed explanation of the requirements, visit nyc.gov/LL88.

Energy Audits  

Buildings covered by Local Law 87 that are required to demonstrate compliance in 2026 must submit an Energy Efficiency Report (EER) by December 31. For a detailed explanation of the requirements, visit nyc.gov/LL87.

By Emily Myers in Bricks & Bucks For Habitat Magazine

What began as a routine look at deterioration in a parking structure quickly turned into a much bigger project for the board of a 200-unit condo in Rego Park. With engineers on site to address mandated facade repairs, the condo board decided to deal with garage repairs — only to uncover failed waterproofing, cracked and flaking concrete and an unexpected electrical hazard.

Built in the 1980s, the condo has an underground single-level concrete garage where the roof is an outdoor asphalt parking lot. “You would think the majority of damage would be overhead,” says Michel Monteiro, senior project engineer at Cowley Engineering, the firm engaged by the board. Most of the damage, however, was on the slab on grade, the concrete poured directly onto the ground.

The structure’s original waterproof coatings had failed, allowing salt and de-icing chemicals to enter cracks and accelerate the deterioration. A large portion of slab needed to be repoured. “What started originally as minor cracks expanded, causing significant spalling and corrosion to the reinforcement,” Monteiro says. Spalling, the flaking or breaking away of concrete, is often associated with corrosion of steel reinforcements inside the structure.

Facing a cost of $1.6 million, the condo board is paying for the work with a loan and an assessment. In addition to financing, there was also the logistical challenge of moving cars offsite during the repairs. With close to 130 cars to work around, the project was completed in phases. To help accommodate vehicle owners, the property manager sought out public parking for 50 or 60 cars while each phase was completed.

Originally the concrete work was going to be partial depth repairs, but during the excavation the contractor uncovered an unexpected problem — live electrical conduits buried in the concrete. “Typically these conduits are buried within the soil beneath the slab,” Monteiro says. In this case, the live electrical wiring was two inches below the surface. Work was immediately halted in order to carry out a ground penetration radar (GPR) scan, a type of concrete X-ray to rule out other hidden dangers.

The discovery of buried electrical wires delayed the project by about three months as wiring was refitted overhead. The GPR scan did not identify live conduits in other parts of the garage, which meant the second and third phases of the project were unaffected. In addition to the new concrete on the garage floor, repairs have also been made to the perimeter of the building where water was getting into the garage from above.

Silence around capacity, clarity, and connection costs individuals and teams.

Key Points

• The most important conversations at work are often the ones that don’t happen.
• There are three commonly avoided conversations that carry real costs when left unspoken.
• When difficult conversations are handled skillfully, they create better outcomes for individuals and teams.

Written in collaboration with Melanie Sodka, capacity management expert and author of Diary of a Functioning Burnout.

In our work with leaders, professionals, and high performers who care deeply about what they do, we listen closely to how people talk about work. What consistently stands out is not what is said, but what is avoided.

Most workplaces are full of meetings, emails, and updates, yet the conversations that would actually improve how people work and how they feel while doing it rarely happen. Instead, people adapt, carry more, stay quiet, and tell themselves this is just how it is. Over time, that silence shows up as burnout, disengagement, and erosion of trust, both in the organization and in oneself.

There are three types of conversations we see people generally avoid. Although there are plenty of topics people don’t like talking about at work, these conversations left unspoken carry a real cost to workplace culture.

Conversation 1: “This Is Not Sustainable”

Many professionals are not struggling because they lack discipline, resilience, or time-management skills. They are struggling because the volume, pace, and emotional load of the work no longer match their capacity. Psychologists often describe this as role overload, when expectations quietly exceed human capacity over time. Instead of naming that mismatch, they internalize it. They say yes, stay late, and absorb temporary demands that quietly become permanent. They develop a pattern of being overworked and underrested.

This conversation is avoided because of what it might signal. People fear being seen as less committed, less capable, or not cut out for the role. They genuinely fear reprisal and judgment. For leaders, this conversation is a strategic opportunity that allows for clearer priorities, more honest trade-offs, and better decisions about where energy is actually needed. For individuals, it restores agency. This is not about doing less or finding excuses. It is about doing the work in a sustainable way, so the work gets done and the people stay well while doing it.

Two approaches people often find helpful:

• Name the pattern, not the pressure – Instead of focusing on how overwhelmed you feel in the moment, anchor the conversation in what you are noticing over time. E.g., “I want to talk about the pace and volume of work I’ve been carrying over the last few months. I’m noticing some patterns that don’t feel sustainable long term.”
• Lead with impact, not complaint – Framing the conversation around quality, effectiveness, and outcomes helps others understand that this is about doing good work, not avoiding it. E.g., “I care deeply about the quality of my work, and right now, the current workload is starting to impact how consistently I can deliver at that level.”

Conversation 2: “I Need to Manage Up”

This is the conversation many people feel they are not allowed to have. Not every manager is equipped, supported, or ready to lead people. Managers may be stretched thin, some were promoted without training, and some are navigating pressures their teams never see.

People avoid this conversation because it feels risky. They worry about damaging the relationship, being labeled difficult, or limiting future opportunities. So instead, they adapt, over-prepare, redo work, and spend cognitive and emotional energy trying to anticipate expectations. This kind of invisible labour is expensive, consuming energy that never appears on a workload plan or performance review, and it feels off because it doesn’t seem fair or right.

Managing up is often misunderstood as ego stroking or politically self-serving. In reality, it is about clarity, understanding what your manager is accountable for, how decisions are made, and what constraints exist. This might look like asking for clearer priorities, naming trade-offs clearly, or setting boundaries around what can realistically be done well. It is not about calling someone out, but rather working within the reality of the system.

When this conversation is avoided, frustration compounds, but when handled with skill and care, trust can increase, and capacity is improved on both sides.

Two approaches people often find helpful:

• Name the work around the work – Instead of talking about tasks or priorities, name the invisible effort that’s been happening behind the scenes. E.g., “I want to talk about the decision-filling, the second-guessing, and the extra checking I’ve been doing, and whether that’s actually the best use of my energy or yours.” This reframes over-functioning as a process issue, not a personal one, and creates shared curiosity instead of defensiveness.
• Name what you don’t want this conversation to become – This removes fear before it has a chance to take hold. E.g., “I want to say upfront that this conversation is not about avoiding responsibility. It’s about making sure I’m using my capacity in a way that actually serves the team.”

Conversation 3: “I Am Disconnected From This Work”

Disengagement builds slowly through misalignment, repeated compromise, or work that no longer fits who someone is in this season of their life. People will continue to show up, meet expectations, and remain reliable, but the sense of connection, the part that fuels motivation, begins to erode. This is not a character flaw, but information signaling that something needs attention, whether that is role design, growth opportunities, values alignment, or simply recovery from prolonged strain.

Leaders who are unable to have this conversation often lose people without ever understanding what happened. For individuals, naming disconnection allows for reflection and intentional choice.

Two approaches people often find helpful:

• Name the gap rather than the feeling – Instead of leading with emotion, this approach frames disconnection as a misalignment between effort and meaning. E.g., “I’ve been reflecting on the gap between how much energy I’m putting into my work and how connected I feel to it. The gap isn’t a crisis, but it is growing, and I think it’s important for us to talk about.”
• Name the change, not the disengagement – This approach names that something has shifted without labeling it as a problem yet. E.g., “I’ve noticed that the way this role fits me has changed over time. I’m noticing some shifts, and I think it would be helpful to think about what that might mean going forward.”

What Leaders May Not Always See

People are not avoiding these conversations because they are weak, entitled, or uncommitted. These conversations are often avoided because the environment doesn’t feel safe enough to have them. If honesty is met with defensiveness, minimization, or subtle penalty, people learn quickly. Staying silent becomes a form of self-protection, and over-functioning becomes the norm.

When we normalize conversations about capacity, clarity, and connection, we create conditions where people can do meaningful work without sacrificing themselves in the process.

Our Final Invitation

Difficult conversations are necessary and part of any team or group. Having these important conversations signals that we care. When we handle them with intention, they strengthen engagement, improve productivity, and create workplaces where people want to stay and contribute.

These conversations tend to find their way to the surface eventually. The difference is whether we create space for them early and openly or later, after concerns have accumulated. When we choose to address things earlier, it often makes everything that follows easier for everyone involved.

By Kelly G. Richardson, Esq., HOA Homefront Column

Here are five pending bills that would not help HOAs:

SB 1238 would create many problems. It proposes to add to Civil Code 2295 a legally incorrect statement that HOA managers are fiduciaries to the HOA BOARDS and members, since managers are fiduciaries to the ASSOCIATION, not to boards or individual members.

The bill also adds three additional categories to the disclosures currently required under Civil Code section 4525 for prospective buyers. The three new items would contain specifics regarding 1. the number of “exterior elevated elements” in the association and how many involve “imminent repairs;” 2. those requiring non-imminent repair, and 3. any requiring over $10,000 of repairs. Balconies are only one of the three “elevated exterior elements” in most condominium buildings, so it’s unclear why the bill omits stairs and elevated bridges.

Additionally, the bill would add several provisions prohibiting HOAs from spending reserve funds on litigation or threatened litigation with members or relatives of member. This provision would deny associations the right to temporarily borrow from reserves to prosecute OR DEFEND lawsuits with HOA members. The reason for singling out members’ relatives for protection is unclear.

Last, the bill would greatly expand the “elevated exterior elements” disclosures, requiring report preparers to make far more detailed judgments on building components than they may be willing to make.

AB 1184, the “Homeowner Association Accountability and Transparency Act of 2026,” proposes significant changes to existing law. It would disallow board email deliberations; require specific litigation disclosures be in Annual Budget Reports; require case names be identified in executive session minutes in which the case was discussed; require open session board meeting recordings to be available to members; require specific information items be contained in board minutes; require election results announcements state each elected director’s term; and ban charges for unredacted documents requested and sent electronically to members. The bill makes many technical changes to board governance which volunteer directors will likely miss. 

AB 739 proposes to heighten scrutiny of management fees by creating a new Civil Code 5378, requiring HOAs to email to requesting members a list of management fees. The bill would also add to the board’s monthly financial reviews an annual review of the management fees charged to the HOA. This bill if passed will further spotlight extra charges management companies use to make ends meet and make the management sector’s current revenue model much more difficult. 

AB1684 would add another “protected use” by creating Civil Code 4737, which would prohibit HOAs from prohibiting or restricting installation, upgrade, replacement, or use of cooling systems. The bill would allow HOAs to force removal of illegal installations, but not to “restrict” installations. This could create a major problem if HOAs cannot impose any reasonable restrictions (allowed regarding solar installations and electric vehicle charging stations). Condominium associations would be unable to stop owners from installing systems that could harm the building or adversely affect neighbors.

SB 222 would create a new “protected use” by creating Civil Code 4737, which would prohibit HOAs from banning heat pumps or from completely banning replacement of carbon burning appliances with electric appliances. I haven’t heard of HOAs banning heat pumps or replacement of carbon (gas/wood/oil) heating systems with electric systems, so this may not affect most HOAs.

Pending bills – www.leginfo.legislature.ca.gov 

Upper West Side, Manhattan

HABITAT Magazine

Savvy co-op and condo boards are always on the lookout for ways to soften today’s hard insurance market — a brutal world of rising premiums, shrinking coverage and, above all, microscopic scrutiny of a building’s claims record.

An Upper West Side condo built in 2010 suffered three major leaks over four years. Though none was catastrophic — the largest insurance claim was for $60,000 — the carrier took a dim view of the building’s track record.

The condo board brought in Sophie Bird, a senior vice president at insurance brokerage IMA Financial Group, who instantly saw the writing on the wall. “For the carrier,” Bird says, “the pattern indicated that there was a larger, more serious problem,” adding that buildings with multiple insurance claims on their loss record can have trouble renewing coverage, especially in the current hard market.  

That’s precisely what happened to the condo, which was pushed into the dreaded “non-admitted” market — a last resort for buildings that insurers consider too risky — where coverage comes with higher premiums and less favorable terms. The condo’s annual insurance costs nearly tripled, ballooning from $50,000 to $130,000.

Bird’s task was to find specific steps the board could take to assure the carrier that the water problems wouldn’t continue, with the goal of keeping premiums steady — or, even better, bringing them down. Poring over the claims, she found a hidden culprit: the condo’s own governing documents.

“They made the association responsible for the cost of repairs for anything original to the units, including the floors,” Bird explains. “Since this was a relatively new development and few unit-owners had renovated, that meant most of the apartments had original floors. Every time water damage struck, the condo was footing the bill for repairs.”

And watching its insurance premiums go into the ionosphere. 

Bird and her team saw a way out. “We spoke with the board and the property manager  and pointed out that the governing documents were working against them,” she says. “We suggested that they look at amending the bylaws to make the unit-owners responsible for their floors and insure them on their homeowners’ policies. That would shift risk away from the building and, over time, improve the way insurers viewed them.”

Amending the condo’s governing documents required a supermajority vote, and convincing reluctant unit-owners wasn’t easy. “We helped the board make the case that bringing down the number of claims would bring down premiums, which would result in significant savings over the years (for everyone),” Bird says. “This was about making an investment in the building’s financial health.”

Eventually the amendment passed, and Bird’s team was able to go back to the carrier with a new message. “We said, ‘Here are the past claims, and a lot of the repair costs were for the floors. Now that unit-owners are responsible for them, you won’t be paying these claims going forward.’”

The strategy worked; in the first year alone, the building’s premiums dropped by $15,000. Bird is optimistic there will be more reductions ahead. “And if the insurance market softens in the next few years,” she adds, “it will improve their pricing even further.”