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LarryB13 (Arizona)
Posts: 4,099
Posted:
From time to time on this forum we hear about HOA's that were administratively dissolved. Having had some experience with this subject I may be able to offer some insight into what that means.

Administrative dissolution is an action taken by the state against the HOA's corporate entity. The most common reasons for this action is failure to file annual reports and or failure to pay fees. If the HOA was never incorporated then it cannot be administratively dissolved. An incorporated HOA may also dissolve itself but this is not covered here.

When a corporation is administratively dissolved, it does not cease to exist but it is severely limited in what it may do. The board of directors remains in control and may perform those acts necessary to wind down the business of the HOA. The HOA is prohibited from "doing business" while under administrative dissolution. I would interpret this to mean that the HOA cannot levy assessments, file liens arising from debts that arose after the date of dissolution, initiate new foreclosure actions arising from debts that arose after the date of dissolution or enter into new contracts. As part of the winding down process, I believe that the HOA could still act to collect old debts.

Administrative dissolution is not necessarily permanent. Filing the missing annual reports and paying all fees owed to the state may be sufficient to reinstate the corporation. In my state, the corporation commission will reserve the name for a period of five years. If the corporation is not reinstated within five years anyone may take the association's name for their own corporation. I have found no limitations on how many years may pass before seeking reinstatement nor have I found a limitation on how long a corporation may take to wind down its affairs.

There seems to be no requirement that a dissolved corporation dispose of real estate or other property but somehow it would still be required to pay whatever taxes are due without collecting assessments from members.

I am uncertain as to whether dissolution would prevent an election of the board of directors because that could be seen as "doing business." My best guess is that if there was an election and the new board filed whatever it needed to have the corporation reinstated that no one at the corporation commission is going to dispute their authority to do so. It would be up to any dissenters to file a lawsuit in court to challenge the new board's authority.

Corporations are a creation of state legislation and subject to the law of the state where they are incorporated.
NpS (Pennsylvania)
Posts: 4,216
Posted:
Nice summary Larry.

My take is that they can't continue doing business as a corporation, but they might be able to operate as a non-corporate entity. Technically, they would not be able to do anything in the name of the corporation (which the state has revoked). And directors would no longer be protected personally. But everything else can probably be run as it always has.

Like you said, reinstatement is generally easy.

Even though you have a 5 year rule, the state database will still show the old name - Not likely that someone else will want to re-use it.


Sikubali jukumu. Read all posts at your own risk.
AmandaR2 (South Carolina)
Posts: 566
Posted:
In South Carolina an HOA can be incorporated or not either way it's allowed and considered "legal" (can have a Board and conduct business, collect dues and such). Most are incorporated and many declarations include the fact that the HOA is to be incorporated on the deed. Some CC&Rs don't mention the specifics regarding incorporation, just depends on what attorney or declarant decided include.
TimB4 (Tennessee)
Posts: 21,059
Posted:
Incorporation is typically a State requirement, if any requirement exists. Associations can certainly operate as an unincorporated business. However, this adds some legalities and additional risk to it's members (as Larry has pointed out).

Here are some additional resources:


Does HOA need to be incorporated?
a 2012 article from CA newspaper

What Is an Unincorporated Nonprofit Association? from About Money

What Is the Difference Between Incorporated & Unincorporated Businesses? from LegalZoom

JohnB26 (South Carolina)
Posts: 1,001
Posted:
Incorporated: no personal member liability for actions of the HOA (except for interest in any common element)

Not incorporated: personal member liability for acts of the HOA (including negligence suits for any injuries sustained on a common element), your PERSONAL assets incl. your home at risk

INC vs. non INC ?

D'OH
AmandaR2 (South Carolina)
Posts: 566
Posted:
Double D'OH,
but..........we still have quite a few unincorporated HOAs in SC and it's recognized and legal for them to conduct business. (Though I would not advise.)
JohnB26 (South Carolina)
Posts: 1,001
Posted:
Of course they may conduct business.

In fact, they MUST conduct the business of the requisite HOA.

The HOA exists whether incorporated or not.

to repeat:

The HOA exists whether incorporated or not.

if not incorporated each member of the MANDATORY association is PERSONALLY liable without any corporate shielding for any matter involving the common elements

D'OH

p.s. I assume you meant you do not advise to do business without being incorporated.

as opposed to: not doing REQUIRED business

AmandaR2 (South Carolina)
Posts: 566
Posted:
Actually JohnB my original comment had nothing to do with you or your comments (if that's what you call what you do most of the time). The OP stated that when a corporation is dissolved, and not incorporated he interpreted it to mean that an HOA could not levy assessment, file liens and such. I was just pointing out that a association is not required by law to be incorporated at all. Incorporation is a choice and sometimes a requirement if the governing doc's state the requirement. Maybe some states also have this requirement I know some do not including SC. I am of the belief that incorporation is a good thing and benefits almost all HOAs but.......there is the possibility that it may not be right for some very, very small HOAs and running their HOA as a partnership may be best and certain types of insurance may be a better choice when they weigh in all the factors.

Why don't you stop just trying to make fun of people please.
JohnB26 (South Carolina)
Posts: 1,001
Posted:
Why did you not write the above in the first place ?

Much better than the previous Jabberwocky.

I actually see your point regarding very small HOAs.
LarryB13 (Arizona)
Posts: 4,099
Posted:
Quote:
Posted By AmandaR2 on 03/28/2015 3:58 PM

The OP stated that when a corporation is dissolved, and not incorporated he interpreted it to mean that an HOA could not levy assessment, file liens and such. I was just pointing out that a association is not required by law to be incorporated at all. Incorporation is a choice and sometimes a requirement if the governing doc's state the requirement. Maybe some states also have this requirement I know some do not including SC. I am of the belief that incorporation is a good thing and benefits almost all HOAs but.......there is the possibility that it may not be right for some very, very small HOAs and running their HOA as a partnership may be best and certain types of insurance may be a better choice when they weigh in all the factors.

I see several problems.

First, if the CC&R's mandate that I be a member of the XYZ HOA and the CC&R's define that association as a non-profit corporation then you would have no lawful authority to foist some other form of association onto me. My state, and I believe most states, expressly forbid compelling membership in an organization without consent.

Second, if the non-profit corporation known as XYZ HOA is dissolved then by law it cannot continue to do business. You would have a hard time finding a sympathetic judge if the same board of directors continued to do business under the same name but claiming to be unincorporated. If you wished to continue existence as an unincorporated association you would need to find a different name and different directors, and then amend your CC&R's to become an unincorporated association.

Finally you may run into another problem, depending on which laws the courts in your state have adopted. A number of states have adopted common law that holds that a homeowner cannot be burdened with more restrictive covenants than what he originally bargained for. If your CC&R's required a non-profit incorporated HOA, which would protect the homeowner from vicarious liability, the CC&R's could not be amended in a way that would impose liability on the homeowner by becoming an unincorporated association.
AmandaR2 (South Carolina)
Posts: 566
Posted:
Quote:
Posted By AmandaR2 on 03/28/2015 3:58 PM
I was just pointing out that a association is not required by law to be incorporated at all. Incorporation is a choice and sometimes a requirement if the governing doc's state the requirement. Maybe some states also have this requirement I know some do not including SC.


I agree Larry that if your CC&Rs say it's required then it is. I'm not aware of any states that require incorporation of HOAs as a law, but Tim had mentioned that there are so I'm sure he's right.

(I wasn't disagreeing with your point about dissolution, you seem to know more of those specifics than I do, that's obvious.)
AmandaR2 (South Carolina)
Posts: 566
Posted:
My point was there are some rare instances where incorporation may not be worth it. Just a general statement about incorporation. Off topic from dissolution, sorry about that!
TimB4 (Tennessee)
Posts: 21,059
Posted:
Quote:
Posted By AmandaR2 on 03/28/2015 5:09 PM

I'm not aware of any states that require incorporation of HOAs as a law, but Tim had mentioned that there are so I'm sure he's right.

FL is one of them (FL 720.303(1)). Perhaps others.

Also, I didn't specify that States required it or not. I said if there was a requirement to incorporate, it would be with State Statutes.
AmandaR2 (South Carolina)
Posts: 566
Posted:
Quote:
Posted By TimB4 on 03/28/2015 5:28 PM
Posted By AmandaR2 on 03/28/2015 5:09 PM

I'm not aware of any states that require incorporation of HOAs as a law, but Tim had mentioned that there are so I'm sure he's right.


FL is one of them (FL 720.303(1)). Perhaps others.

Also, I didn't specify that States required it or not. I said if there was a requirement to incorporate, it would be with State Statutes.

Thanks Tim,
Remember I'm here in SC and we don't have a lot of the same laws that some other states do. Here in SC if there is a requirement to incorporate, it would not be in the State Statutes it would be found in the CC&Rs for the community and recorded at the Register of Deeds.
AmandaR2 (South Carolina)
Posts: 566
Posted:
Quote:
Posted By AmandaR2 on 03/28/2015 3:58 PM
Actually JohnB my original comment had nothing to do with you or your comments (if that's what you call what you do most of the time). The OP stated that when a corporation is dissolved, and not incorporated he interpreted it to mean that an HOA could not levy assessment, file liens and such. I was just pointing out that a association is not required by law to be incorporated at all. Incorporation is a choice and sometimes a requirement if the governing doc's state the requirement. Maybe some states also have this requirement I know some do not including SC. I am of the belief that incorporation is a good thing and benefits almost all HOAs but.......there is the possibility that it may not be right for some very, very small HOAs and running their HOA as a partnership may be best and certain types of insurance may be a better choice when they weigh in all the factors.

Why don't you stop just trying to make fun of people please.

AmandaR2 (South Carolina)
Posts: 566
Posted:
Quote:
Posted By JohnB26 on 03/28/2015 4:04 PM
Why did you not write the above in the first place ?

Much better than the previous Jabberwocky.

I actually see your point regarding very small HOAs.

AmandaR2 (South Carolina)
Posts: 566
Posted:
Quote:
Posted By JohnB26 on 03/28/2015 4:04 PM
Why did you not write the above in the first place ?

Much better than the previous Jabberwocky.

I actually see your point regarding very small HOAs.

seems like you did have another opinion regarding small HOAs.
PitA
Posts: 311
Posted:
Very small = 4 units, 2 stories, 1 building; no amenities

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