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PUBLIC TESTIMONY

Testimony by Jason Gamel, President/CEO of American Resort Development Association (ARDA) on Hotel Licensing Legislation

3:07:22

·

145 sec

Jason Gamel, representing the American Resort Development Association (ARDA), testified about the potential impact of the hotel licensing legislation on the timeshare industry. He argued that timeshares should be exempted from the legislation due to their distinct business model and existing regulations.

  • Highlighted that there are fewer than 12 timeshare properties in New York City
  • Explained that timeshares are already highly regulated by the New York Attorney General's office
  • Expressed concern about potential conflicts between AG jurisdiction and the proposed legislation
Jason Gamel
3:07:22
Thank you very much, Trevor Mennen and other members of the city council.
3:07:26
My name is Jason Gammel, and I represent the American Resort Development Association for the Trade Association that represents the timeshare industry.
3:07:34
And our membership comprises of over 350 companies, both privately held firms and publicly traded.
3:07:41
Corporations.
3:07:42
Artists active and engaged members have been have extensive experience in shared ownership interests and leisure real estate.
3:07:48
We do not believe the New York City Council necessarily intended for the hotel license legislation to apply to time shares.
3:07:54
But if it does, to believe it will, we believe it will negatively impact our industry.
3:07:59
Just to begin, there are by the many hotels in New York City, there are less than 12 timeshare properties that are currently in the city limits.
3:08:06
It's obviously a very small percentage of accommodations overall.
3:08:09
The timeshare properties are already highly regulated by the New York attorney general's office.
3:08:14
And before they can operate, open, or market, or sell any type of timeshare interest, there has to be an approval from a file that's that is of a plan that is filed with the AG's office.
3:08:26
The submission and review of a timeshare offering plan is highly complex.
3:08:30
It usually takes several months to complete and tens of 1000 of dollars in both legal costs and fees in order to be able to submit.
3:08:38
In addition, there are always zoning and department of building approvals that are required for any time share that's developed in city limits.
3:08:45
And if a time share developer violates any of those regulations, they're subject to penalties and enforcement actions by the AG's office.
3:08:51
Once a property is sold out, it might be managed by a hospitality brand, but it is always overseen by an owner's association, which is responsible for all the common expenses, including services such as housekeeping and front desk operations, which are all essentially paid for by the timeshare owners instead of a situation where a hotel where those costs and expenses are all generally baked into the average daily rate.
3:09:14
And under this legislation, one thing that we're very concerned about is that there will be a conflict between or potential conflict between the jurisdiction of approval of a time strain plan by the New York attorney general's office and the jurisdiction of rape.
3:09:28
Okay.
Julie Menin
3:09:28
I'm gonna ask you to come and wrap your testimony up.
Jason Gamel
3:09:31
Absolutely.
3:09:32
We've we would in this case, we would gladly disrespect fully request that our that time shares be exempted from this legislation as we don't believe that they that's the same business models, the hotels, and it would apply that same.
3:09:45
But happy to answer any questions, and thank you for your time.
Julie Menin
3:09:48
Okay.
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