Years ago, bringing, or defending, a Fair Market Rent Appeal (FMRA) was a routine part of any rent regulatory practice. Because there are so few rent-controlled apartments left, FMRAs have become somewhat of a rarity. Nevertheless, the successful defense of an FMRA, under appropriate circumstances, can lead to a ruling that the apartment had been deregulated under the luxury deregulation provisions of the RSL that existed prior to the HSTPA.