The facts are not in dispute. Clark & Associates, Inc. (Clark) built a number of townhouses, including the one at issue in these proceedings. Washington Federal was the beneficiary of a Deed of Trust executed by Clark on these premises. Subsequent to the Deed of Trust, Clark leased the premises to Whiteside and two others (Whiteside) for a term of three years. After Clark defaulted on the note, Washington Federal caused the Trustees in the Deed of Trust to sell the premises. Washington Federal purchased the premises at the Trustees’ sale and sent a notice to quit to Whiteside on May 23, 1983. On June 14, 1983, Whiteside filed a complaint with RAO.* On July 23, 1983, while the complaint was still pending before RAO, Washington Federal filed a suit for possession in Superior Court based on a 30-day notice to quit, contending that Whiteside was a “tenant” only within the meaning of D.C.Code § 45-222 (1981).