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California Department of Real Estate: FAQs - Mortgage Loan Brokering in California California Home DRE Home Contact Us What's new About DRE Careers at DRE DRE Records Consumers Escrow Violations eLicensing Examinees Licensees Subdivisions Real Estate Law Regulations Publications Forms FAQs Links Index Department of Real Estate My CA FAQs: Mortgage Loan Brokering in California indicates an item is in Portable Document Format (PDF). You will need Adobe Reader (or an Adobe Acrobat product) to view it. Click on the icon below to download a free copy of Adobe Reader. Click here for information about using Adobe Reader. Provided below are answers to some of the most frequently asked questions regarding licensing and other related issues for those who are interested in some aspect of the mortgage business in California. Questions come from both licensees and non-licensees from other states and California expressing an interest in California licensing requirements to engage in mortgage activity. The following questions and answers are intended to answer many, but by no means all, of these inquiries from the standpoint of the Department of Real Estate requirements. Q . - As a mortgage broker in Kansas (or any other state), my plan is to move to California and pursue this same business. Does California issue mortgage broker licenses and is there any reciprocity in licensing with other states? A . - California does not issue a "mortgage broker" license. A majority of those engaged in mortgage loan brokering do so with a real estate broker license. To the surprise of some, the license that allows the listing and sale of real property (the traditional activities associated with a real estate broker license) is the same license that allows the solicitation of borrowers or lenders, the negotiation of loans secured by real property and the collection of payments on notes secured by real property. For further details concerning the definition of licensed activity, review Business and Professions Code Sections 10130 and 10131. It should be noted there are other licenses that allow mortgage loan brokering under a limited set of circumstances, such as the California finance license and the residential mortgage lending license. For information about these licenses contact the California Department of Corporations. (See addresses at end of pamphlet.) California does not have reciprocity with any other state as far as a real estate license is concerned. Information regarding obtaining either an individual or corporation real estate broker license is explained in Instructions to License Applicants . Q . - As a mortgage broker working outside of California, I occasionally have clients who are moving to California and have asked me to broker a loan for them to be secured by their new home. Although I am not licensed in California, can I broker a loan secured by California real estate? Does California have a rule that allows me to broker a small number of loans in California before I would have to be licensed? A . - No. To broker even one loan in California you need to be licensed here. However, California Real Estate Law does allow a California broker to share a commission with a broker from another state. Therefore, it may be possible to co-broker the loan with a licensed California broker. Q . - I am a licensed California real estate broker and I specialize in the sale of real property, primarily residential homes. I would like to branch out and engage in mortgage brokering. What additional licensing must be obtained? A . - As a licensed real estate broker, you may engage in mortgage brokering without any additional license. A real estate broker may engage in a variety of real estate related activities including residential home sales, mortgage brokerage, and property management, among others. You may, however, wish to consult with the Department of Housing and Urban Development to determine their rules regarding real estate sales and the arranging of FHA loans. Additionally, if you represent a buyer or seller in a real estate transaction, and will also be compensated for obtaining the loan for the buyer, Commissioners Regulation 2904 requires you to disclose, to all parties in the transaction, the form, amount, and source of the compensation received or expected for the loan. Go to Top of Page Q . - Another broker told me that the kind and volume of mortgage brokerage activity I engage in makes me a "threshold" broker. What does that mean? A . - Determining whether a broker meets the "threshold" criteria takes a careful reading of Section 10232 of the Business and Professions Code. Generally, the criteria is met by brokers who arrange, sell, or service "private investor" or "private lender" loans, sometimes referred to as "hard money" loans. The "threshold" criteria is satisfied by negotiating 10 or more loans or sales of notes or real property sales contracts in any 12-month period in an aggregate amount of more than $1,000,000 (all of which were funded or purchased by private investors or small pension trusts). A broker can also meet the "threshold" criteria by servicing loans on behalf of investors or on behalf of obligors. If the aggregate amount of payments collected is $250,000 in any 12-month period, the "threshold" criteria has been met. Included in the $250,000 aggregate is any amount the broker collects on loan payoffs. Brokers who collect payments on behalf of obligors are typically those who collect payments from homeowners on a bi-weekly mortgage payment plan. Within 30 days of meeting the "threshold" criteria, a broker is required to submit a Threshold Notification (RE 853)   to the Department. The notification form is available at any DRE office or may be downloaded from the DRE Web site at http://www.dre.ca.gov . Q . - Once Ive submitted a Threshold Notification (RE 853) to the Department advising of my "threshold status," what happens next? A . - After receipt of the "threshold" notification, the Department sends the broker information and necessary documents for required quarterly and annual reporting to the Department and adds the broker to the "threshold" list. The Department then tracks and records each required report from the broker. Q . - What kind of reporting requirements are necessary if I satisfy the "threshold" criteria? A . - "Threshold" brokers make quarterly and annual reports to the Department on their trust fund bank accounts and an annual report on their business activities. Except for the annual trust fund report (which is done by a public accountant per instructions from the Department), the Department provides the necessary forms for the quarterly trust account and annual business activity reports. These are provided to the broker upon receipt of the "threshold" notification form. Go to Top of Page Q . - I am a broker who arranges loans for, and sells notes to, private investors and small pension trusts. May I also borrow personally from any of these investors? A . - Yes. However, these "self-dealing" loans are highly scrutinized and require notice to DRE before the transaction is completed. Before a broker, or salesperson acting on behalf of a broker, solicits and accepts funds for the direct or indirect use or benefit of the broker, the broker must submit to DRE a true copy of the Lender/Purchaser Disclosure Statement prior to obtaining the signature of the investor/purchaser. The Lender/Purchaser Disclosure Statement must be accompanied by the brokers statement that the submittal is being made pursuant to Business and Professions Code Section 10231.2. While the broker need not wait for DREs approval of the transaction, the Lender/Purchaser Disclosure Statement must be presented to the investor/lender not less than 24 hours prior to that person becoming obligated to make the loan or purchase the note. The Lender/Purchaser Disclosure Statement must also give a detailed explanation of the intended use of the funds, including an explanation of the nature and extent of the benefits to be derived directly or indirectly by the broker. It is very important to understand that "self-dealing" is not permitted in multiple investor (fractionalized) transactions except under the limited circumstances set forth in Business and Professions Code Section 10229(d)(1). Q . - When engaged in mortgage loan brokering, are there any special trust fund record keeping requirements? A . - Yes. In addition to the trust fund record keeping requirements of the Business and Professions Code that apply to all real estate brokers, mortgage brokers must also maintain quarterly trust fund reconciliations of their trust account on special forms available from the Department. These forms are completed, maintained in the brokers office, and made available upon request to a Department representative for review. The quarterly reconciliation forms are, Trust Fund Status Report ( RE 855)   and Trust Fund Bank Account Reconciliation (RE 856)   . Q . - Are there specific disclosure statements that must be used by a real estate broker in the mortgage business? A . - Every real estate broker who negotiates a loan to be secured directly or collaterally by a lien on real property shall, within three business days after receipt of a completed written loan application or before the borrower becomes obligated on the note, whichever is earlier, cause to be delivered to the borrower a statement in writing (borrowers disclosure statement), containing all the salient features of the loan to be negotiated by the broker. The statement must be personally signed by the borrower and by the real estate broker negotiating the loan or by a real estate licensee acting for the broker in negotiating the loan. When so executed, an exact copy thereof shall be delivered to the borrower at the time of its execution. A federal Good Faith Estimate (GFE) may also be required in a loan transaction under the Real Estate Settlement Procedures Act (RESPA). The GFE may contain some similar disclosures but it cannot, without modification pursuant to Business and Professions Code Section 10240(c), be a substitute for the disclosure statement required by state law. The state disclosure statement is called the Mortgage Loan Disclosure Statement (MLDS). If a GFE is necessary in the loan transaction, the Department has available a Mortgage Loan Disclosure Statement/Good Faith Estimate (MLDS/GFE). The MLDS/GFE satisfies the state disclosure requirement and the federal GFE requirement. In addition to a disclosure statement for the borrower in a loan transaction, there are lender disclosure statements that a broker may be required to use. Unlike the MLDS or MLDS/GFE which must be provided to a borrower in virtually every loan transaction, the disclosure statement for a lender/investor is limited to private and small pension trust lenders/investors. Lenders/investors such as banks, savings and loan associations, credit unions, and a variety of others need not receive the lender/investor disclosure statement which is called the Lender/Purchaser Disclosure Statement (LPDS). Every real estate broker, in making a solicitation to a private investor and in negotiating with that investor to make a loan secured by real property or to purchase a real property sales contract or a note secured by a deed of trust, is required to deliver to the investor solicited the applicable completed statement as early as practicable before he or she becomes obligated to purchase or make the loan. The statement shall be signed by the prospective lender or purchaser and by the real estate broker, or by a real estate salesperson licensed to the broker, on the brokers behalf. When so executed, an exact copy shall be given to the prospective lender or purchaser. The Department has available three versions of the LPDS, depending on the type of transaction. There are statements for loan origination, sale of an existing note and one for a collateralized loan. Please note that collateralized loans are not permitted in multi-lender transactions. Go to Top of Page Q . - Are there specific rules or laws that pertain to advertising by real estate brokers engaging in mortgage activity? A . - Yes. The law states, in part, that: "No real estate licensee shall knowingly advertise, print, display, publish, distribute, telecast or broadcast, or cause or permit to be advertised, printed, displayed, published, distributed, televised or broadcast, in any manner any statement or representation with regard to the rates, terms, or conditions for making, purchasing or negotiating loans or real property sales contracts which is false, misleading or deceptive." To assist licensees in complying with the law, Commissioners Regulation 2848 sets forth sixteen (16) subsections of "donts" of mortgage loan advertising. Q . - What about those who advertise from outside of California via the Internet? A . - Advertising real estate services on the Internet, including mortgage loan services, is considered solicitation of a California resident when read by a resident of California. Either the out-of-state advertiser on the Internet must be properly licensed in California or the ad must contain a disclaimer to the effect that the ad is not valid in California. The Department has prepared information regarding Internet advertising which is available from any Department district office and is partially reproduced here: Internet Advertising These guidelines have been prepared by the California Department of Real Estate to assist real estate brokers and businesses that are not licensed in California who are considering advertising real estate services on the Internet. If you are not properly licensed in California, you may not solicit California residents. To do so would be considered conducting activity for which a real estate license is required. Because the Internet can be read by anyone in any location, advertising your services on the Internet would be considered soliciting a California resident when read by a resident of this state. If you conduct activity which requires a California real estate license, but you are not a California licensee, you could be subject to administrative sanction such as a Desist and Refrain Order. If you are now conducting, or plan to conduct, the above activity in California, you need to apply for a real estate broker license . If you dont plan to become licensed in California, you should make sure your Internet advertising contains a disclaimer such as the following: "Notice: This offer is valid only in State 1, State 2..." (states wherein you are licensed or authorized to do business). If you are licensed in numerous states, you may want the disclaimer to read: "Notice: This offer is not valid in State 1, State 2..." (states in which you are not licensed or authorized to do business). Q . - Are there some advertising violations that are more often encountered than others? Yes. Some of the more common advertising violations are: Using terms in a comparative or superlative degree to describe any aspect of the business or any terms applicable to loans negotiated by the broker, without setting forth in the ad additional information to render the superlative or comparative terms unambiguous in the context in which they are used. For example, a broker who advertises "FAST LOANS" must also set forth in the ad how "fast is fast" (e.g. "most loans closed in 90 days from application"). A broker who advertises "LOW RATES" should also set forth in the ad what rates are available so that the term "LOW" is actually defined. It should be noted that the Department may require the broker to substantiate any claims made in an ad or require additional qualifiers in the ad to ensure the ad is not misleading to the public. Advertising a specific payment for a loan without including in the ad an equally prominent disclosure of the loans interest rate, APR, principal amount, number, amount and period of payments scheduled to maturity and the balance due at maturity if not a fully amortized loan. Advertising an interest rate without disclosing whether the rate is for first mortgages, junior loans or both. Advertising a loan program with special qualifying restrictions or special requirements without setting forth those requirements or restrictions in the ad. Advertising an interest rate without an equally prominent disclosure of the APR. It should be noted that if a rate appears in an ad without an APR, a disclosure of "APR NOT CALCULATED" is not sufficient. An APR must be disclosed if a rate appears in the ad. In addition to the above examples, which are based on specific subsections of the regulation, phrases and words used in advertising can be misleading in themselves. "No Cost" loans and "No Fee" loans are such words. All real property secured loans have certain inherent costs, such as title insurance, escrow, appraisal, recording fees, etc. These services are bought and paid for by the borrower in all loan transactions. In the cases where a broker arranges a premium priced loan where a lender rebate is used to pay for these services, the services are still performed and the costs incurred. The borrower pays the costs of the services via a higher interest rate than would be available if the borrower paid for the services out-of-pocket. In effect, the borrower finances the closing costs over the entire life of the loan. Although there may be no out-of-pocket costs to the borrower, clearly there are fees and costs involved, contrary to the claims in these ads. Go to Top of Page Q . - I understand something called the "multi-lender rule" was transferred from the California Department of Corporations to the Department of Real Estate. What is this and how may I as a mortgage broker be affected? A . - The Department of Corporations enforces the state securities laws which require that any security in an issuer transaction be qualified prior to sale with certain exemptions. Such an exemption was the "multi-lender rule" (Section 260.105.30) which permitted the sale of interests in notes secured by real property to not more than 10 persons as defined. This "rule" was legislatively transferred by Assembly Bill 754 (Kuykendall) to the Department of Real Estate as Section 10229 of the Business and Professions Code. Any real estate broker (mortgage broker) involved in loan transactions secured by real property where the investors number 10 or less, but more than one, known as fractionalized notes, must notify the Department of Real Estate of the engagement in "multi-lender" activity. Any broker who arranges, sells or services such fractionalized notes must file a Multi-Lender Transaction Notice (RE 860)   with the Department within 30 days of the first such transaction. Quarterly, CPA-prepared reports must be filed by any broker who acts as the servicing agent for such notes where the payments due during any period of three consecutive months exceeds $125,000, or the number of persons entitled to payments exceeds 120. The quarterly reports are in addition to the "threshold reports" previously discussed. Section 10229 is very detailed and should be carefully reviewed before becoming involved in multi-lender transactions. Q . - As a mortgage broker, can I collect fees from a borrower to cover certain costs in a loan transaction when a loan application is taken, such as a fee to cover my expenses in processing the application or fees for credit report and appraisal? A . - Fees that are collected by the broker from a borrower prior to the services being rendered are defined as "advance fees." To preclude the inappropriate use of such fees, a broker can only collect "advance fees" if the contract or agreement to do so has been submitted to and approved by the Department in advance of use. This agreement specifically tells a borrower how the "advance fees" are to be used by the broker. The broker must also maintain all "advance fees" in a trust fund bank account and they must be expended only on behalf of the borrower. In addition, whatever other materials the broker might use in collecting "advance fees" must also be submitted to the Department, prior to use, for review and approval. Credit report and appraisal fees, although technically "advance fees" are not considered as such and may be collected without adhering to the prescribed advance fee procedures. These fees are invariably passed to third parties performing the services. They must, however, be maintained in a trust fund bank account and expended appropriately. A broker may not profit from the collection of credit report and appraisal fees. If actual costs are less than collected, the excess must be refunded to the borrower. Q . - I am not licensed as a real estate broker or real estate salesperson and I am only going to assist private parties who wish to sell their notes (secured by real property) for cash to another party (investor), perhaps in another state. Is a real estate license required if I conduct this activity in California? A . - The activity described, so-called note brokering , requires a real estate license if performed in California. This includes the solicitation of California note owners, whether in person, by mail, telephone, or other means of communication. One of the definitions of a real estate broker is: "...a person who, for a compensation or in expectation of a compensation, regardless of the form or time of payment, does or negotiates to do one or more of the following acts for another or others: (e) Sells or offers to sell, buys or offers to buy, or exchanges or offers to exchange a real property sales contract, or a promissory note secured directly or collaterally by a lien on real property or on a business opportunity, and performs services for the holders thereof." There are companies engaged in the discounted purchase of certain mortgages, primarily those carried back by residential sellers and secured by the transferred real property. The companies hold seminars to recruit people to solicit and negotiate the sale of these mortgages. Seminar attendees are informed that they do not need a real estate license to engage in this activity. In California, this is wrong because the activity fits the definition quoted above. Go to Top of Page Q . - Is a real estate licensee in the mortgage business required to show any specific disclosure of his or her license status in an ad? A . - All California real estate licensees, when acting as such, must disclose licensure in advertising. For a broker engaged in mortgage loan activity, the following also applies: "No real estate licensee shall place an advertisement disseminated primarily in this state for a loan unless there is disclosed within the printed text of that advertisement, or the oral text in the case of a radio or television advertisement, the license under which the loan would be made or arranged." A real estate broker must include one of the following disclosures in any mortgage loan advertising: "Real estate broker, California Department of Real Estate" or "California Department of Real Estate, real estate broker." The words "California" and "Department" may be abbreviated as "CA", "CAL" or "CALIF" and "DEPT." In addition to the license and licensing department identifiers, mortgage brokers must include their 8 digit broker license identification number in the ad. In the borrower and lender/purchaser disclosure statements (MLDS and LPDS), a broker must disclose the license identification number and the information telephone number established by the Department that a consumer can call to inquire about the license status of the broker. Q . - Has there been a change in the retention period that brokers are required to keep records? A . - The general rule is that brokers are required to keep records for a three-year period. However, pursuant to Business and Professions Code 10229(e)(1), the investor qualification statement required on a multi-lender loan has a four-year retention period requirement. Also, self-dealing statements, pursuant to Business and Professions Code 10231.2(b), must be retained for four years by the broker. Real estate brokers are not only affected by laws and regulations enforced by the Department of Real Estate, but also many others at both the state and federal level. The foregoing questions and answers are based on the California Business and Professions Code and the Regulations of the Real Estate Commissioner. Real estate brokers should be familiar with the other laws affecting their business. In this regard, they may receive assistance from other enforcement agencies, private legal advisors, and/or professional trade organizations. Office Locations Department of Real Estate Sacramento District Office 2201 Broadway P.O. Box 187000 (mailing address) Sacramento, CA 95818-7000 (916) 227-0770 (Mortgage Loan Section) Fresno District Office 2550 Mariposa Mall, Suite 3070 Fresno, CA 93721-2273 (559) 445-5009 Los Angeles District Office 320 W. 4th Street, Suite 350 Los Angeles, CA 90013-1105 (213) 620-2072 Oakland District Office 1515 Clay Street, Suite 702 Oakland, CA 94612-1462 (510) 622-2552 San Diego District Office 1350 Front Street, Suite 3064 San Diego, CA 92101-3687 (619) 525-4192 Department of Corporations: Sacramento 1515 K Street, Suite 200 Sacramento, CA 95817 (866) ASK-CORP - (866) 275-2677 US Department of Housing and Urban Development (HUD) Regional Office: San Francisco P.O. Box 36003 450 Golden Gate Avenue San Francisco, CA 94102-3448 (415) 436-6550 Federal Trade Commission (FTC) Regional Offices: San Francisco 901 Market Street, #570 San Francisco, CA 94103 (415) 356-5270 Los Angeles 10877 Wilshire Blvd., #700 Los Angeles, CA 90024 (310) 824-4343 Back to Top of Page Conditions of Use | Privacy Policy | Tech Problems 2003 State of California This page last modified on Tuesday, August 31, 2004
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Real estate - Boston.com Buying Renting Recent Sales Place an ad Luxury Living Community data Mortgage Commercial Moving Guides Real estate Boston.com Check out the Real estate Section on Boston.com. December 29, 2005 -- Skyline at Station Landing Starting at: $339,000 Allston 2 bedroom $384,390 Newport 1 bed/1 den $755,000 Quechee Lakes, VT 3 bedroom $455,000 Sugarbush, VT 2 bedroom $166,457 Loon Mountain, N.H. Now accepting reservations Newbury 4 bedroom $749,900 Malden 2 bedroom $314,900 The Grandview Starting at: $600,000 Swampscott 3 bedroom $329,000 Boston 2 bedroom $545,000 South Boston 3 bedroom $429,000 Needham 4 bedroom $1,195,000 Dorchester 2 bedroom $314,000 York Beach, ME 3 bedroom $629,000 Battery Wharf Starting at: $1.15MM 210 South Street Regatta Residences Rooney Real Estate NOTE: We are experiencing technical problems that are preventing some photos from appearing in our listings. We are working now to correct the problem. We apologize for the inconvenience and thank you for using Boston.com Real Estate. Homes New developments Condominiums Open houses Get started All rentals Apt. communities Vacation rentals Get started HOME OF THE WEEK Old styles in a bustling area Amid a neighborhood becoming known for new restaurants, shops, and condos, the residential block where this narrow, four-level home sits may be one of the few things that has yet to significantly change. Homes of the week: Watertown | Sudbury | Westminster See photos of this home Brockton builds on legacy This working-class city's once moribund downtown is being revived by young professionals drawn to the industrial chic of old factories where laborers plied their trade more than a century ago. (The Boston Globe, 12/25/05) Kerouac's Cape home up for sale ON LOCATION Historic cottage for sale The Pratt House in Northampton, which was commissioned in 1859 by Boston doctor Alvah Littlefield and once faced demolition, is now on the market for $1.285 million. (The Boston Globe, 12/25/05) GALLERY Editor's picks: On the market Check out our favorites this week and see all different sizes, shapes, prices, and locations. (Boston.com) Last week's picks METRO HOME FEATURE A safe haven Several designers donated their time and expertise to decorate 13 bedrooms and living areas at a Children's Hospital shelter. (Metro Boston, 12/16/05) See photos of the hospital makeovers Submit photos of your pad to be featured More in Home MESSAGE BOARDS Where are prices headed? Open house advice Things to consider when buying View all message boards NEWS From one generation to another A group of young developers felt a need to give back to their Jewish community in a way that has never been done before. (Boston Globe, 12/18/05) Formal room is hereupon retired Office market shows signs of rebound COMMUNITY SNAPSHOT Holbrook Holbrook offers a mix of properties for first-time home buyers seeking more affordable options and for those in the market for more high-end housing. (The Boston Globe, 12/25/05) More profiles: Hingham | Somerville | Wellesley | Southborough All Community statistics and town data | Compare towns GALLERY A look at Manny's condo Boston.com toured Ramirez's penthouse condo, on sale for $6.9 million, and caught a glimpse into the daily digs of the World Series MVP. (Boston.com) Alternatives to heating See what others are doing to cut down on their heating bill this winter. (Boston.com) Cost comparison What is your home heating plan? Heating tips Q&A about your home heating bills More in home heating NEWS Sellers chop prices as market slows Boston-area homeowners trying to sell their houses are sharply reducing asking prices -- in some cases, by $100,000 or more -- in response to a sudden slowdown. (By Kimberly Blanton, Boston Globe) Holiday season is the ideal time to buy Lilly's five steps to real estate success 14 tips to finding a great apartment Need some help finding your next new pad? Here are a few items you should make sure to check for. (Boston.com) Print the list A sense of community in a rental Sept. 1 moving scenes Self-storage how-to Step-by-step moving guide Print box labels What are your tips for moving? Pointers on renting, your rights and so much more Search rentals Renting guides NEWS Rises in rent outpace some wages The cost of rental housing has increased more rapidly than have wages, making it increasingly difficult for low-income families to afford even modest apartments. (By Stephen Ohlemacher, Boston Globe) Tools and calculators Run the numbers on everything from your income to upfront costs and credit. Instant mortgage quotes Mortgage rates 30-yr Fxd: 6.30% 15-yr Fxd: 5.85% 1-yr. ARM: 5.15% Mortgage quotes Daily commentary NEWS Real estate slump chills 'flippers' Get in, get out, get the next deal. That's the code of the ''flipper." Flipping -- buying and quickly reselling homes -- has helped some investors make a killing over the past few years in markets such as the North Shore. Selling a house? 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MemeFirst: New York real-estate prices explained -- MemeFirst December 01, 2005 New York real-estate prices explained The 2.2 million jobs in Manhattan pay, on average, $2,025 per week . (You know that feeling you get when you find out you're below average? I've been having that for years.) Manhattan is 22 square miles, which means that the island of Manhattan pays, on average, $378 per square foot per year . And that includes Washington Heights. Posted by Felix at 02:54 PM GMT All proceeds go to MSF -- Comments #1 Pity we can't all work for Goldman Sachs. Posted by: Gherimiah on December 1, 2005 03:28 PM #2 I'll happily defer to someone with a firmer grasp of stats on this, but in the meantime, I wonder, does that average income number tell you very much? Given the massive disparity in Manhattan incomes, between, say, the dishwasher and the hedge-fund owner, which surely are among the widest in the country, wouldn't you also need to know the distribution of the data points? At a minium, wouldn't you want also to know the median income? Also, is this net or gross? Article talked about paychecks, which could probably mean either. Posted by: Matthew on December 1, 2005 04:36 PM #3 Oh, and also, Felix, presumably the 2.2 million people with jobs in Manhattan don't all live there, so your extrapolation doesn't wash. Posted by: Matthew on December 1, 2005 04:38 PM #4 Obvs mean incomemedian income, and I'd be surprised if more than 40% of Manhattanites made above average. Probably less. But even so. And actually, the fact that there are 2.2 million jobs to 1.5 million people in Manhattan actually only serves to exacerbate the demand-supply imbalance when it comes to real estate. Posted by: Felix on December 1, 2005 04:53 PM #5 I hate to be the one to break this to you, Felix, but nearly all residential housing in Manhattan consists of multi-story buildings. The salary range you describe explains real estate prices in Westchester County, NY and Bergen County, NJ to about the same degree as prices in Manhattan. Posted by: Sterling on December 1, 2005 07:05 PM #6 How delightful that the discussion of property prices one is sometimes unable to defuse at dinner parties just carries on here - almost as if taunting one with its dreary ineluctability. And how nice that Felix should bring along his no doubt expert appreciation of statistical lore. The one thing I am missing is the crucial evaluation of bedbug incidence as it affects property prices in Manhattan. In another thread, Betty has said this bedbug malarkey is all a plan of Bush's. For myself, I prefer to recall that bedbugs tend to originate in Belgium. Schtumm for now. More on this later. Posted by: Claude de Bigny on December 1, 2005 08:40 PM #7 Also, this seems to imply that everyone pays all of their income for housing, which is hopefully not the case. To be more realistic (ignoring the issues rightly brought up by the other commentators, including whether all of those people actually live in Manhattan and whether you can just take the sq ftge of Manhattan as the residential sq ftge), say people on average spend 40% of their income on housing. That gets your income for housing per sq ft to around $151. Posted by: Susan on December 1, 2005 09:14 PM #8 Susan and Sterling, you are embarassingly confused. What percentage of real estate in Manhattan is used for housing? According to this http://www.nyc.gov/html/dcp/pdf/landusefacts/landuse_tables.pdf (in case you are confused by the graph, the percents sum together veritcally and the land area sum horizontally). And even assuming that all "Mixed Residential and Commercial" was used for housing, less than 38% of the land in Manhattan is for housing. These data certainly allow for the idea that much of rent paid in Manhattan is for commercial use, and even then, a considerable percent is used for public space (Central Park alone is 10% of the area of Manhattan). Anyway, the amount people earn in a particular location is not directly related to the amount the people who live there earn, or the amount the people live there pay for rent. Look at this site: http://www.census.gov/hhes/www/saipe/index.html The direct link is unavailable, but the Median household income for New York County was 43,573. Nassau County on the other hand is more than 71,000. In which place is it cheaper to rent by the foot? Posted by: Andrew on December 2, 2005 07:22 AM #9 I don't think I'm confused. My points are: a) there is actually quite a bit more than 22 square miles of residential floor space in Manhattan because of vertical construction b) a lot of upper-income Manhattan workers live outside Manhattan, and their buying power lifts prices in tony bedroom communities Posted by: Sterling on December 3, 2005 03:38 PM #10 OK, Sterling, let's do it your way. Assume that each of the 1.5 million residents of Manhattan has 400 square feet to call their own: that works out to 1200 square feet for the average family of three and 1600 square feet for the average family of four. Generous, I'd say. That comes out to 600 million square feet of residential real estate in Manhattan. Using that figure, my calculation actually comes out slightly higher : $386 per square foot per year, rather than $378. What makes you think that there's more than 22 square miles of residential floor space in Manhattan? As for your point b, I fail to see how it is in any way germane. Posted by: Felix on December 3, 2005 11:09 PM #11 OK, 22 square miles equals about 613,324,800 square feet. That would leave each of Manhattan's 1.5 million residents with 409 square feet of living space. But I don't believe that most Manhattan residents are actually so deprived, especially when you take into account common areas in apartment buildings such as laundry facilities, hallways, lobbies, etc. I'd be surprised if the average wasn't at least 600, and it's probably more than 800. And besides, that's not what you originally meant - you were dividing Manhattan's land footprint and not taking into account its vertical expansion. As for the second point, I suspect there's a strong tendency among $100,000 - $1,000,000 per annum Manhattan earners - which is well-off to wealthy-on-a-budget - to live in places like Valhalla and Ho-Ho-Kus, especially if they're married with kids. Family-flight in turn increases the average per-capita-square-footage of the Manhattan residential footprint through bleed-off of children. Posted by: Sterling on December 4, 2005 02:29 AM #12 Sterling jumped the shark so long ago it's probably not surprising, but for those of you keeping score at home, he really did just say that the average Manhattanite has 800 square feet of their own. So if you're an average person living with 2 roommates, that means you're in a 2400 square foot apartment. In Manhattan. Yeah. Oh, and that 350 square foot apartment you've got? It's not 350 square feet at all, it's probably more than 4000 square feet. You're just not including the lobby and all the hallways. Posted by: Felix on December 4, 2005 02:43 AM #13 My claim is that the amount of residential-zoned floor space in Manhattan probably works out to between 600 and 800 square feet per resident of Manhattan. You're not only challenging this, but asserting that my claim is absurd. Sure you wanna do that? Posted by: Sterling on December 4, 2005 02:59 AM #14 I've tried to find the statistic, but to no avail. It seems that while office space inventor is measured in square footage, residential space is simply measured, in all documents, by units. But we can work with that. So far I've learned that 82% of zoned lots in Manhattan are residential, making up about 280,000,000 square feet, which includes permanently undeveloped spaces like yards and gardens. If the average height of development across all that land is four stories, then, we're looking at about 750 square feet per person. I've also learned that in 1999 there were about 727,000 residential units in Manhattan , which means that the average unit houses two people. So those three-roomies crammed into one 800-square-foot-tenement-with-the-bathtub-in-the-kitchen examples are mostly fiction. Which is a shame because I get a tingle from the mental picture of Manhattan twenty- and thirty-somethings living in cramped, dingy conditions. If we divide the total residential land area by the total number of units, we get 385 square feet, which works out to 192.5 square feet per person, assuming no dwellings above one story in height and no unimproved/vacant land. If the average height is assumed to be four stories, in this scenario we get about 770 square feet per person. Here's a report from Prudential Douglas Elliman that details its 1Q 2005 sales. Units sold averaged 1,334 square feet, which divided by two yields 767 square feet per person. Breaking it down further we find co-ops averaging 1,197 square feet, condos at 1,496 square feet, luxury at 2,921 and loft at 2,145. So that's 598.5 square feet per person at the low end all the way up to 1,460.5 at the top. There's three separate analytical models for you Felix, all of which yield per-person square footage of 750 or better. I admit they're not all that fleshed out, but I'm stuck inside with a cold watching The Taking of Pelham One-Two-Three on DVD, and I'm disinclined to dig deeper. But you're welcome to. Posted by: Sterling on December 4, 2005 04:04 AM #15 Sterling: do your calculations include infrastructure or is the 280MM number a percentage of raw space? Building density is higher here than anywhere else in America, but 15% to circulation (in buildings and streets themeselves) would be an easily defended metric. Counting hallways in urban residential structures is like counting sidewalks as part of sf for suburban homes. As much Sterling does sound like a set designer for Friends, Felix, I gotta say, of the 25 or so apartments of people that I can definitely make an estimate of size, we average 500 sf easy. Most everyone is a half a standard tenement lot (25 x 25), with a couple of lofts and post-war, large-scale developments thrown in. This is skewed because many of them are single (I live in a 2bd alone) or have rent-controlled apartments from way back. Posted by: 99 on December 4, 2005 07:19 PM #16 Where does your 280m sq ft number come from? Your first two calculations are based on it, so I'd like to know. (They're also based on a multiplier of 4, which as far as I can tell came pretty much out of thin air.) As for apartment sales, in Manhattan individual condos and coops tend to be much larger than the apartments inside rental buildings. So if you look just at sold apartments as opposed to rented apartments, you're going to get a skewed figure. What's more, if a 3800-square-foot brownstone in Harlem, say, is sold and then the downstairs floor is rented out, that still counts as a 3800 square foot deal under these figures. Posted by: Felix on December 4, 2005 09:21 PM #17 The multiplier of 4 was back-of-envelope guess. The 280,000,000 number came from this PDF . Sorry, thought I'd linked to it initially. As for rental apartments being smaller than privately owned condos or co-ops...not sure I buy that. But even if it's true, how much smaller could they be? 10%? Doesn't really matter. You can apologize any time now. Posted by: Sterling on December 4, 2005 10:06 PM #18 if anyone is real curious why not pony up the $250 to get a list of every tax lot in the city? http://www.nyc.gov/html/dcp/html/bytes/applbyte.shtml in the meantime, simply because i am tired of having to read sterlings pontifications about things he knows anything about, i downloaded a list of all the residential tax lots from 14th street and below from propertyshark. only 14th street and below, because after 6000+ entries, i became bored. 14th street down is a good representative sample of the 99000+ residential tax lots in manhattan. it includes spacious luxury lofts of tribeca, tenements of the les, projects on the eastside, high rise high density battery park and half building condo conversions of downtown (note that a rental bldg with multiple units counts as a single tax lot with the number of units listed as a seperate data field). the average unit size works out to 1100sf with 590sf per person (based 2000 census population stats for 14th st & below). this includes all common space in a building as it is based on total building size for single tax lot (rental) buildings and counts common space tax lots for condo buildings (read lobbies, circ, etc.) multiplying back out by the 2000 census population numbers for manhattan of 1,537,195... we get 906,945,050sf of residential space in manhattan. let's call that an even 9Bsf since the city lists 3800 acres of lot area in manhattan (165,500,000sf), that gives a rough overbuild factor of 5.5. this will obviously skew higher with the ues & uws densities without actually affecting the sf/person. summary- -590sf of residential per person (inclusive of common areas). close to sterlings low estimate of 600, but nowhere near the 800sf -1100sf average size per unit (inclusive of common areas). again close to sterlings guess based on broker mumbojumbo, but still below the stated average. -9Bsf of residential space in manhattan sterling- close on your numbers, but not nearly close enough to be quite so pompously smug. stick to things you know about, like why bush is a foreign policy genius. felix- remind me what this related to? Posted by: geoff on December 5, 2005 12:34 AM #19 Geoff - The only reason I was pompously snug is because Felix had reacted to to my estimates with such comedic outrage. Also, I don't think 14th St. and below is a good representative sample. Newer and I suspect more spacious high-rises make up a much larger proportion of housing from the 30s up through the low 100s. So I'm sticking with 600+. I suspect the actual number is around 750, as stated above. As for your justification of your work - "simply because i am tired of having to read sterlings pontifications about things he knows anything about" - I'm not sure what it means. Perhaps you meant to write "nothing" instead of "anything"? I'm not claiming to be right all the time - I am not right all the time. I am, however, pretty much always right whenever Felix gets all worked up and tells me I have no idea what I'm talking about. Thanks for your small role in marking off another example for me to throw back at him at some future date. Posted by: Sterling on December 5, 2005 06:19 AM #20 Renter-occupied apartments are much smaller than owner-occupied apartments. And as the PDF you yourself linked to shows (see page 24), the vast majority of apartments in Manhattan are renter-occupied. Think about it: one needs maybe 350 sq ft per person to live in some reasonable comfort. Beyond that, you're shelling out extra cash for extra space. Owners are happy doing that because they have 100% equity in that space: everyone has heard the advice that they should buy the biggest apartment they can afford. Renters, on the other hand, are simply giving away thousands of dollars in rent every month, with nothing at all to show for it. So they tend to go not for the biggest apartment they can afford, but rather the cheapest apartment they find adequate. Put it this way: Manhattan is full of individuals spending an enormous proportion of their income on outsize mortgage payments. Almost everyone, when they move from renting to buying, sees their monthly housing costs rise substantially. If you move to Manhattan and have a relatively low income, then you might spend a crazy amount of it on rent, it's true. But if your income is average or higher (and remember that average is $2,025 per week), I very much doubt that your rent is making nearly as much of a dent in your paycheck as it would if you owned your own apartment. You reach a standard of living you're comfortable with, and you stop. Anything beyond that is money which you could otherwise spend on clothes, or travel, or restaurants. Whereas if you buy , you're not spending so much as investing. The only money which you're really spending is the interest on your mortgage -- and even that comes with a tax deduction. Or let's put it another way. That Elliman report you linked to has an average sales price of $1.21 million. A typical rental yield in Manhattan these days is 4%, so if rentals were functionally identical to owner-occupied apartments, which you seem to assume, then the average rent in Manhattan would be over $4,000 a month. In fact, of course, it's nowhere near that. Posted by: Felix on December 5, 2005 06:55 AM #21 There's the shark, and then there's the A train. Sterling's Manhattan clearly stops at 96th street. Sterling, dear, north of that bright white line, the housing stock is incredibly stable and consistent in terms of size and layout. Harlem is just now getting it's first 'luxury' apartment building in a half century. Any larger apartment complexes are housing projects, which have smaller units by definition, and, allowing for the dispersal of the towers in some International Style fantasy also insures that the density does not increase much. Posted by: 99 on December 5, 2005 04:03 PM #22 Felix, just because apartments are currently going for $1.21 million a pop doesn't mean that everyone who owns an apartment paid that much. Rent prices move in sympathy with real estate prices but are less prone to bubbles. What you're missing here, and you've missed the same thing when we've talked about the stock market in the past, is the difference between speculative investors and income investors. Speculators don't buy an apartment (or apartment building) primarily for the benefit of the rent; their main motivation is the hope of flipping the property at some later date for a larger sum than they paid for it. The current Manhattan real estate bubble is the product of speculators. Real estate income investors view rent collection as their goal - most apartment buildings in any town or city in the U.S. are owned by income investors. They get less press than speculators, but they also tend to go bankrupt less often. The market value of a rental property can be determined by the amount of rent it generates for the owner, not the other way around. Manhattan rents are high - probably even ludicrously high - but that is a function of large demand chasing relatively low supply, and is only weakly related to current real estate prices. I do acknowledge your point about space not being a priority for Manhattan renters, there is some truth in that. People who do see space as a necessity tend to wind up in rental units in Brooklyn, Queens or Hudson County. But that's not exclusively the case. Posted by: Sterling on December 5, 2005 04:59 PM #23 This thread is hilarious and sad, although a good example of how the same statistics can be applied to support any and all political positions. Posted by: sac on December 5, 2005 06:39 PM #24 Sterling, Manhattan is the one real-estate market in the US where there are, to all intents and purposes, zero speculators under your definition. No one buys Manhattan property in order to flip it. For one thing, co-op boards (and even condo boards, for that matter) hate flippers, and are likely to punish them. There's flip taxes, brokers' fees of 6% for the seller, and a luxury tax of 1% on any apartment over $1m for the buyer. Prices are so high that the carrying costs are enormous -- and you can't rent out the apartment in the meantime, because that makes it pretty much unsaleable. There are, of course, lots of buildings owned by income investors in New York. Most of the East Village, where I live, is comprised of such buildings: they normally have 20 or so apartments (say 5 floors, 4 apartments per floor), and they've been going up in price almost as much as individual apartments have -- the only reason they haven't gone up just as much is because many of the tenants are rent-controlled or rent-stabilised below market. These are typical New York apartments, from a renter's point of view -- but I can tell you, as someone who was apartment hunting in the East Village for almost a year, they're much less typical from an owner's point of view. Also, there's a strong incentive for for-sale apartments to be as large as possible: price per square foot is positively correlated with size. That's not the case in the rental market: it's easier to rent out a 650sqft apartment for $2500 than it is to rent out a 1300sqft apartment for $5000. Posted by: Felix on December 5, 2005 09:14 PM #25 "Manhattan is the one real-estate market in the US where there are, to all intents and purposes, zero speculators under your definition. No one buys Manhattan property in order to flip it." Felix, of course people speculate on property in Manhattan. Just because the barriers to entry are high doesn't mean some won't jump them. How else do you think a modest apartment winds up costing as much as a dozen Mercedes-Benz CL500s? Who do you imagine is providing demand at that level? You know banks are not issuing $1,000,000 mortgages to households with joint incomes of $200,000. It's trust fund kiddies - who are often divorced from fiscal reality - and speculators. As for your point about different-sized apartments being suitable for rent versus sale, I might agree with you except for the fact that every rental apartment IS OWNED by someone. It IS PART of the for sale market. I'd be surprised if fewer than half of the condos in Manhattan are rented out by their owners. Posted by: Sterling on December 6, 2005 01:51 AM #26 Sterling, I'm afraid the factors leading to high apartment prices are much more mundane than your feverish mind would like to imagine. Lots of global liquidity, driving down interest rates and banks' credit tests. Lots of demand, due to Manhattan's status as the center of the universe and high Wall Street bonuses. And very limited supply. The market for flippers is Miami, not NYC -- where a condo can be bought and sold three or four times before it is even built. As for your point about rental apartments being owned by someone, it sounds clever until you stop to think about what I've already said. Rental buildings are owned by landlords; the vast majority of condos and co-ops are owner-occupied. For one thing, co-ops vastly outnumber condos, and they're hard to rent. And as for condos, they generally get rented out when they're not the place their owner really wants to live. Given how valuable they are, few owners who don't want to live here would rather rent out their condos rather than simply sell them. Take my East Village condo building, for instance: when it went condo in 1983, only one owner lived here. Today, all the units bar one are owner-occupied. I haven't done my homework on this, but I'll happily accept your wager: I'll bet the standard bottle of vintage champagne that more than half the condos in Manhattan are owner-occupied. Deal? Posted by: Felix on December 6, 2005 02:43 AM #27 If you go double or nothing on the proposition that the amount of existing residential floor space in Manhattan divided by the number of residents of Manhattan is equal to or greater than 600 sq. ft., then it's a bet. How are we going to research this? FWIW, I am descended from a man who is reputed to be the first person to negotiate a real estate deal in New York: Wessel Wesselse (ten Broek). He may have been the man to offer 60 guilders (often misreported as $24) as the purchase price of Manhattan from the Canarsies. (Technically the Canarsies didn't own Manhattan Island - it's not for nothing that "Canarsie" is in Brooklyn. Also technically the Dutch West India Company didn't care which tribe owned it. It just needed some bunch of natives to smile and sign off on the deal to keep the English away.) This of course conveys no special knowledge upon me, but it certainly adds a humorous subtext to our disagreement. Posted by: Sterling on December 6, 2005 04:14 AM #28 I'm not sure about the terms of the wager: we seem to be betting on two different things at the same time. But spell it out, and I'll be amenable. I do want to ensure, of course, that hallways and elevator shafts and the like do not count as residential floor space. And please also ensure that if one of the propositions can be determined while the other one can't, then the other wager still stands. Posted by: Felix on December 6, 2005 05:55 AM #29 I'm not sure how we could specify the terms to exclude elevators if they are included in filings. However, it occurs to me that Manhattan Borough probably requires a statement of total dwelling space for its Certificate of Occupancy, so that would work for me. And no, I think double or nothing sounds good to me, especially since we will be attempting to falsify two of my estimations, rather than either of yours. Posted by: Sterling on December 6, 2005 06:20 AM #30 You've lost me, I'm afraid. When you say "double or nothing", are you proposing a 2BVC bet on the residential floor space, and no bet at all on the proportion of condos which are rented out? Or what? It makes no sense to me: "double or nothing" normally happens after A has lost a bet and B has won it. Then going double or nothing means that either B wins double the original amount, or he wins nothing. You essentially run the bet over again. Are you maybe trying to propose something whereby if I lose I lose 2BVCs, and if I win I win nothing? Posted by: Felix on December 6, 2005 07:44 AM #31 Are you trying to squirm out of it? Posted by: Sterling on December 6, 2005 06:03 PM #32 Sterling, will you propose your bet already? I've already said that I'm likely to accept. Just tell me the terms! Posted by: Felix on December 6, 2005 06:12 PM #33 I did! Posted by: Sterling on December 6, 2005 06:25 PM #34 OK, have a few moments now, I had to get someplace before 2pm and the roads are crap with snow and slush. Um, OK. My terms for the bet is those two things specified, avg. sq. footage = 600 and = 50% of condos. Either side has to get both right to collect. gotta run Posted by: Sterling on December 6, 2005 06:51 PM #35 So if one of us gets both right, he wins 1BVC or 2BVCs? And if one of the two turns out to be unverifiable, then it's a wash? Posted by: Felix on December 6, 2005 07:22 PM #36 Honestly, Felix, I doubt either number is verifiable. Like I wrote above, the city appears to track residential rental inventory by units, rather than by square footage. Also, most owners of condominium units who rent them out do so through agents - even the tenant may be only vaguely aware of the legal status of the unit. In NJ I don't think an individual condo owner even needs to report the unit as a rental property if it's in a building that's already inspected under multi-family housing regulations (or if it's a standalone unit or duplex). The rent revenue has to be reported as taxable income, naturallly, but not to any entity with housing oversight. So make it for one bottle and yes both figures have to be verifiable. That said, if either of us can show a grouping of not-completely-conclusive figures from multiple sources that seem reasonable and fall long or short of my guesses by ten percent or more, then I think we should accept them. (Of course, I have arguably already met this condition with my square footage prediction, and Geoff's calculations don't contradict it under the 10% rule I suggest.) Posted by: Sterling on December 6, 2005 10:05 PM #37 as i mentioned earlier, you can get the sf and unit count for every residential tax lot in the city from the cities web site... google 'bytes of the big apple' and look at the 'pluto' product. the license fee is $250 or you can get the info from propertyshark.com. there are 99000+ listings for manhattan. at 100 listings per page, thats a lot of cutting and pasting into excel. both of these will give you tax lot sizes (whole buildings/unit count or condo unit), which will be inclusive of common area. 10-15% is considered a fairly standard deduction for circulation. mechanical space is not included in the floor area count. happy dueling Posted by: geoff on December 6, 2005 10:29 PM Post a comment Name: Email Address: URL: Remember personal info? Yes No Anti-spam question: Share four cupcakes equally among four people. How many does each person get (in digits)? 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(7) Comments 06/12: geoff: as i mentioned earlier, you can get the sf and unit count for every residential tax lot in the ci 06/12: Sterling: Honestly, Felix, I doubt either number is verifiable. Like I wrote above, the city appears to tr 06/12: Felix: So if one of us gets both right, he wins 1BVC or 2BVCs? And if one of the two turns out to be unv 06/12: Sterling: OK, have a few moments now, I had to get someplace before 2pm and the roads are crap with snow an 06/12: Sterling: I did! 06/12: Felix: Sterling, will you propose your bet already? I've already said that I'm likely to accept. Just te 06/12: Sterling: Are you trying to squirm out of it? 06/12: Felix: You've lost me, I'm afraid. When you say "double or nothing", are you proposing a 2BVC bet on the 06/12: Sterling: I'm not sure how we could specify the terms to exclude elevators if they are included in filings. 06/12: Felix: I'm not sure about the terms of the wager: we seem to be betting on two different things at the s 06/12: Sterling: If you go double or nothing on the proposition that the amount of existing residential floor spac 06/12: Felix: Sterling, I'm afraid the factors leading to high apartment prices are much more mundane than your 06/12: Sterling: "Manhattan is the one real-estate market in the US where there are, to all intents and purposes, 05/12: Felix: Sterling, Manhattan is the one real-estate market in the US where there are, to all intents and p 05/12: sac: This thread is hilarious and sad, although a good example of how the same statistics can be appli 05/12: Sterling: Felix, just because apartments are currently going for $1.21 million a pop doesn't mean that ever 05/12: 99: There's the shark, and then there's the A train. Sterling's Manhattan clearly stops at 96th stree 05/12: Felix: Renter-occupied apartments are much smaller than owner-occupied apartments. And as the < 05/12: Sterling: Geoff - The only reason I was pompously snug is because Felix had reacted to to my estimates with 05/12: geoff: if anyone is real curious why not pony up the $250 to get a list of every tax lot in the city?<br 04/12: Sterling: The multiplier of 4 was back-of-envelope guess. The 280,000,000 number came from <a href 04/12: Felix: Where does your 280m sq ft number come from? Your first two calculations are based on it, so I'd 04/12: 99: Sterling: do your calculations include infrastructure or is the 280MM number a percentage of raw 04/12: Sterling: I've tried to find the statistic, but to no avail. It seems that while office space inventor is 04/12: Sterling: My claim is that the amount of residential-zoned floor space in Manhattan probably works out to b 04/12: Felix: Sterling jumped the shark so long ago it's probably not surprising, but for those of you keeping 04/12: Sterling: OK, 22 square miles equals about 613,324,800 square feet. That would leave each of Manhattan's 1 03/12: Felix: OK, Sterling, let's do it your way. Assume that each of the 1.5 million residents of Manhattan ha 03/12: Sterling: I don't think I'm confused. My points are: a) there is actually quite a bit more than 22 02/12: Andrew: Susan and Sterling, you are embarassingly confused. What percentage of real estate in Manhattan i Trackbacks
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