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MarieL (Illinois)
Posts: 82
Posted:
Every month our HOA pulishes and circulates a treasurer's report,listing all the HO's by name. . It shows if the HO is current or delinquent in their assessments.Can the BOD publish and circulate this information or is in conflict with The Federal Act 804 (2). The Fair Debts Collection Act?

Need to mention, I am not one of the delinquents. For 37 years my assessments have always been paid on time. Never delinquent or even 1 day late!
MelissaP1 (Alabama)
Posts: 13,836
Posted:
This information went ONLY to the board members. It was NOT for public/member view. We referenced people NOT by names but Lot #'s. The information should be on the Treasurer's report. Just kept confidential between the pary involved individually. However, GENERAL collection rates such as 75 out of 100 pay on time can be revealed.

Former HOA President
BrianB (California)
Posts: 2,820
Posted:
The Fair debt collections act only regulates 3rd party debt collections.

So, if the debt is between the owner (party 1) and the HOA (party 2) as an original debt, then the Federal Law has no jurisdiction.

If the HOA has given the debt to any other party to collect (a lawyer, a debt collection agency, or a management company) then yes, the FDCA applies, and what they are doing COULD be wrong (without reading the act entirely, I can't offer an opinion on the exact nature of right/wrong).
CrystalK1 (South Carolina)
Posts: 30
Posted:
Some board members in our HOA had wanted to publish the names of property owners whose dues are delinquent. After much discussion, it was decided that we would not offer the names or addresses of delinquent properties.

Treasurer reports would read something like this: "5 properties delinquent one year, 2 properties delinquent two years".

If a member asks directly for the addresses of delinquent properties, we would answer. Our HOA is subject to the Open Meetings Act and the Freedom of Information Act.

In the end, the board concluded that public humiliation was never a good idea, and could even lead to a claim of harassment.

The Treasurer files an assessment lien on a property if the property is delinquent in dues for one year or more.

LarryB13 (Arizona)
Posts: 4,099
Posted:
Quote:
Posted By MarieL on 04/26/2012 6:14 AM
Every month our HOA pulishes and circulates a treasurer's report,listing all the HO's by name. . It shows if the HO is current or delinquent in their assessments. Can the BOD publish and circulate this information or is in conflict with The Federal Act 804 (2). The Fair Debts Collection Act?

Need to mention, I am not one of the delinquents. For 37 years my assessments have always been paid on time. Never delinquent or even 1 day late!

I am of the opinion that I have a contractual relationship with every other property owner in my association and that this relationship allows me to know who is not performing their part. I have no reasonable expectation that my performance - or lack thereof - of my obligations will be kept secret from other owners.

There are, however, some states with statutes that allow the deadbeat owners to keep their nonperformance secret from the rest of the members.

In my state the statutes prohibit the association from releasing "personal financial information" without defining what that term means. I interpret it to mean that the association cannot reveal the credit card number or checking account number used to make the payments, but can reveal whether or not payment was received from an owner.

As Brian pointed out above, the federal debt collection act applies only to third-party debt collectors.

The fact that the payment status of all homeowners is made available to members every month should kill the argument that this is harassment. It's just a report of the facts.
SteveM9 (Massachusetts)
Posts: 3,699
Posted:
Fair Debts Collection Act does not apply. They may publish the info. I support it, and we publish too.
MarieL (Illinois)
Posts: 82
Posted:
Thanks to all of you who respond to my question. Another HO in my association, who also is not delinquentasked me this question I did not know how to answer him. I do now. Thank you.

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