💬 Join us to post & get advice from 50,000 HOA & Condo leaders.

Create Free Account →

⚡ Takes 30 seconds

Already a member? Log in

LarryS3 (Washington)
Posts: 13
Posted:
Our HOA continues to use complaint driven CC&R enforcement. Many violations are easily visible. I am trying to convince them that we need an active approach to enforcing CC&R's. Does anyone know of any articles, lawyer opinions, etc. to back up my opinon?
BradP (Kansas)
Posts: 2,640
Posted:
Larry:

Sounds good in theory...couple of issues. 1) If you have a property manager then this is a no brainer as that should be part of there duties, depending on how your contract would be structured. 2) if you don't then I can see why you might have this issue, the question of who is going to do it arises. I suggestion I might have for you is to volunteer to go around the neighborhood and report these violations to the board. Speaking from experience, sometimes as a board member you get wrapped up in other things and don't take the time to do this. It would be nice to have a volunteer or two to be your eyes.
RogerB (Colorado)
Posts: 5,067
Posted:
Larry, my opinion is don't use one or the other - use both.
RobertG (Arizona)
Posts: 505
Posted:
I would add that you should look at the goal of the violation system. I believe strongly that what you want is compliance, not punishment. I would even go as far as to say that if a violating homeowner fixes a problem, then the fine (if imposed) could be dropped. It is not about punishing people, it is getting people to do what is right. I have many disagreements with board members about waiving the fine for violators. Most of the board wants to fine all the time. I am not even sure fining repeat offenders is the best way to go. It is true you need something to get their attention. However, if the homeowner fixes the problem, isn't that was is the goal in the first place?
HaroldS1 (Arizona)
Posts: 314
Posted:
Robert, are you saying your board fines before giving the homeowner an opportunity to correct the violation? And then doesn't want to repeal the fine when the violation is corrected? What state are you in? It could be your state has laws regarding due process before issuing fines. Even if not, your board needs a course in due process.
Just as an aside: Since your board is so fine-happy, what does your board do if the homeowner doesn't pay the fine? Harold
RogerB (Colorado)
Posts: 5,067
Posted:
I agree with Harold. No fine should ever be issued prior to giving the alledged violator the opportunity for a Hearing.
RobertG (Arizona)
Posts: 505
Posted:
I'm sorry if I gave the impression that there wasn't an appeal process. We also have a multiple notice sent out before the fine is actually imposed (1st warning, 2nd warning), etc.

My point was more of a situation where someone has weeds in their yard (a clear violation of our rules). They are given several notices and then the fine is imposed. About the same time as the fine letter goes out, the homeowner removes the weeds. Now the homeowner has fixed the problem and there is still a fine outstanding. Should the homeowner be given ability to ask for the fine to be waived? The problem is solved, what point is there in collecting the fine?
MelissaP1 (Alabama)
Posts: 13,836
Posted:
Most states do NOT allow liens or foreclosures to be placed on the basis of liens. Liens and foreclosures are the legal means for a HOA to collect unpaid assessments. They don't extend into fine collections.

I am saying this because fines may NOT be enforceable in a court of law by your HOA. So trying to collect on them may be irrelevant. If the fines were challenged by a member in court, the fines may NOT stand up.

I've already posted this almost same information in another post so please bare with me. Fines and Late fees are NOT considered a source of "income" for a HOA. The members are ONLY required to pay the monthly/special assessments. So when a fine is levied against a member, there is no real "loss of income" to the HOA. The HOA doesn't pay out anything to issue a fine. (They do to collect). So if there is no money loss, then there is no "resitution" that is required. The court can only rule to give back a loss and NOT a gain. A fine would be a gain.

I would simply drop the fine process and consider the violation compliant. They did what they were told and no need to pursue farther until it presents a problem again.

Former HOA President
BradP (Kansas)
Posts: 2,640
Posted:
Melissa:

I disagree 100% with your post, our state allows fines and I think it is a good source of punishment. Even if you can't lien for them you can still take them to court and make it sting.

While you shouldn't count on fines for income it is. The process or collecting and enforcing is in your operational budget. Furthermore, late fees for us are considered a source of revenue and are collectable. We probably have 1-2% of our annual income is in late fees from Dues.
TracyT (Maryland)
Posts: 228
Posted:
Hey guess what my BOD did recently?

We have a structure that the CC can (optional) collect an ARC application review fee as defined in our CC&R. But we have NOTHING in any of our docs to allow for fining of a violation. Since we've never collected the application review fee, so the Board of Directors voted to use the fee for as a violation fine :o
KevinK5 (California)
Posts: 64
Posted:
Everything I have read indicates that you should enforce actively. If you enforce only by complaint then you open yourselves up to two problems. One is that when you try to enforce against a complaint, the violator will start citing all the other issues that you have not been enforcing. Believe me, people may say they don't see any problems, but if you send a violation letter to them, they will be able to recite all the addresses of the other residents with problems. Now you have to go back and send letters to lots of other residents so you appear to be fair.
Second is that if you only respond to complaints, you are opening yourselves up to legal challenges against selective enforcement or waiver of enforcement by allowing issues to go uncorrected.
Enforcing only those issues that come to light from complaints also opens the association up to charges of favoritism and makes enforcement unequal through the neighborhood. If you read the complaints about associations, you know that these are hot issues.
One final comment: The board needs to enforce the rules. Don’t use your neighbors as “tattletales”.
Kevin
MicheleD (Kentucky)
Posts: 4,491
Posted:
I've been reading this thread with interest and have not commented yet, but felt compelled to after reading Kevin's post.

I would like to respectfully disagree with some of his comments.

First I'd like to say that, on the contrary, complaint-driven enforcement stands up very well in court (it has done so for us on 2 occasions).

The caveat is this: you MUST have a policy that you enforce CONSISTENTLY.

You MUST document each and every complaint, retain it in a database of some sort, even if it's a hand-written "log," so that IF someone decides to press their luck and hit back with that "selective enforcement" as a defense, you can show, on the contrary, that the board instituted a complaint-based process, and based on that process, each and every complaint, regardless of how large or small, was quickly and consistently addressed.

It doesn't take much to track, but you need to show your history of WHEN the complaint was made (you do NOT need to show who made it -- and we simply state whether it was made in person, by phone call, by email, or by snail mail);that the violation was CONFIRMED by a board member; WHAT action was taken (letter sent, phone call made, etc); RESPONSE from the violator; WHETHER FURTHER ACTION was required or WHETHER COMPLIANCE was obtained.

Once a violation is noted as "CLOSED," we still retain the details for historical purposes, especially if we need to see if the violation is a repeat.

Now, having said all that, there is still the issue of the board's FIDUCIARY RESPONSIBILITY to the CC&Rs. First of all, our subdivision has over 275 homes on 10 streets. The BOD is all volunteer. It is unreasonable to expect that we should be somehow "policing" the neighborhood, trolling for violations. Especially since most of the BOD work and that would leave violations that occur when we're not around to go completely un-dealt with.

But going back to our FIDUCIARY RESPONSIBILITY to the CC&Rs, as we are residents as well as directors/officers, we have the right and duty as other residents to log a "complaint" about a violation. In fact, our duty to do so is a little higher for several reasons, not the least of which, we will often have a broader understanding and knowledge of what is allowed and what is not allowed. Therefore, if we "notice" a violation, then it would be our duty to report it IF it could be determined that we would have a reasonable awareness of the infraction.

In other words, if, on my way to work every day I pass a car parked on the street at a certain address, I might SUSPECT that they have parked it there overnight or that it is there for most of the day, but I really have no real knowledge of that, especially if it is gone when I return and I don't generally leave that way any other time of night.

However, if I live next door to or down the street from someone who I SEE has a car parked on the street when I let my dog out at 11:00 pm, and then it is there STILL, with dew on it, at 6:30 am when I let my dog out again, I SHOULD be able to reasonably assume that it was parked there overnight. And if this happens every day, I SHOULD, as part of my fiduciary responsibility, log a formal (yet still anonymous) complaint.

Now, to address the people who want to complain about OTHER people who are violating, then we say the same thing each and every time:

We do not police the neighborhood for violations and rely on the residents to inform us when a violation may have occurred. We have a policy on the board of investigating each and every complaint. If you would like to file a formal complaint and provide the address, we would be more than happy to send that resident a reminder notice of the CC&Rs as well.

Then if that person actually goes out and does the leg work and provides us with a list of any alleged violations, we have no problem logging and reviewing the complaints. Why would we? It's our responsibility.

At any rate, it's never a fun thing to do, that's for sure, but the key with whatever process you use is in the consistency -- and keeping a record.
HaroldS1 (Arizona)
Posts: 314
Posted:
Tracy - Do I understand your post correctly? Your board has never utilized the allowed ARC review fee, so they now have converted it to a fine fee? Yet there is noting in your documents allowing for a fine fee? Did your members approve this change? Harold
LarryS3 (Washington)
Posts: 13
Posted:
I am the one who started this discussion. Great discussion. Some people have mentioned that "things they have read" indicate it is necessary and/or desireable to have active CC&R enforcement. This is actually what I am looking for. The actual article, court ruling, lawyer opinion, etc. This way I can have a factual basis to make my argument to the Board for active CC&R enforcement. I too have my opinions, but I need to convince them with more than my opinion. If you know of any written expert information I can use to make my argument, please let me know where I can find it. thanks, Larry
LarryS3 (Washington)
Posts: 13
Posted:
Kevin do you know where I can find any articles, lawyer opinions, other expert written opinion, etc. on this matter? I am trying to convince our Board to add active CC&R enforcement.
LarryS3 (Washington)
Posts: 13
Posted:
FYI In our HOA, we only use complaint driven enforcement. Another problem with only using this system is that, in most cases in our HOA, neighbours that reported neighbours ended up disliking or hating each other. In my opinion, the Board should be the bad guy not the members. Members have also used this process as a way of getting back at members they had disagreements with. This is another reason I am pushing to add active enforcement.
PaulM (Pennsylvania)
Posts: 1,347
Posted:
Larry:

I agree with the problems you cited when associations rely on complaint driven reinforcement. It does not present a total picture of violations since the Board is only acting on resident complaints...and we know how human nature works...

Active Enforcement is not only a better way to handle violations, but in many communities, it is part of the BOARD'S ROLE. Certainly, it is always best to enforce all violations and not be selective when doing so.

Do your CC&Rs & Rules/Regs, speak to having an Arch. Committee and fining for violations? You can also refer to your state's document (planned community act or condo assn. act) to learn of what the state regs. are--your commu. docs should be based on these.
PaulM (Pennsylvania)
Posts: 1,347
Posted:
TracyT:

You have stated your assn. has an ARC Committee but you have no allowance to fine for a violation.

What does the ARC Committee actually do? If they are to approve or disapprove arch. requests, what is the follow-up process being used to ensure that all is being done in line with the ARC and CC&R guidelines?
RobertG (Arizona)
Posts: 505
Posted:
Just as a point of information. In Arizona, a new law came into effect last year that provided that if a homeowner asked for information (with a certain set of steps to follow) on a violation that is given them, the HOA must provide:
"Within ten business days after receipt of the certified mail containing the response from the member, the association shall respond to the member with a written explanation regarding the notice that shall provide at least the following information unless previously provided in the notice of violation:

1. The provision of the community documents that has allegedly been violated.

2. The date of the violation or the date the violation was observed.

3. The first and last name of the person or persons who observed the violation.

4. The process the member must follow to contest the notice.
"
Many of the HOAs that have a property manager utilize that person to be the one reporting the violation to eliminate the possible bad feelings of a neighbor turning in a fellow neighbor. However, it might have an impact on some HOAs that favor compliant driven enforcement.
TracyT (Maryland)
Posts: 228
Posted:
Paul:

Our CC responsibilities are to review and approve/disapprove ARC requests. To my knowledge we use sort-of the complaint based and board observation procedure. However, based on my coversation with some of my neighbors and my own observations, this method is not very effective especially with the repeat offenders - mostly trash storage issues.

Harold:

You understood my post correctly. The board changed the CC&R and no the membership did not vote on it.

Michelle:

Very nice complaint procedure. You or someone on your board must be a quality assurance professional. Do you monitor compliants for trend and apply CAPA?

I agree that you should pick a procedure and follow it consistently but would add that many HOAs do have an active enforcement committee.

T
MicheleD (Kentucky)
Posts: 4,491
Posted:
Robert: You wrote above:

3. The first and last name of the person or persons who observed the violation.

This is one of the reasons we require a board member to confirm the violation. If a resident sends in a complaint, sometimes it comes in anonymous, sometimes it doesn't, but for consistency we have a board member's name attached as the official "observer" since he or she must confirm the violation in order for it to become a formal action item. Another reason is to avoid a resident trying to slam another with bogus complaints. Yet another is so that we CAN operate as the "middle" man. If a board member's name is tied to the complaint, then it minimizes animosity between immediate neighbors.

LarryS3 (Washington)
Posts: 13
Posted:
We do have a good HOA. Good ACC Committee work. Just lack the active enforcement of CC&R's.
RobertG (Arizona)
Posts: 505
Posted:
Quote:
Posted By MicheleD on 06/29/2007 9:05 AM
Robert: You wrote above:

3. The first and last name of the person or persons who observed the violation.

This is one of the reasons we require a board member to confirm the violation. If a resident sends in a complaint, sometimes it comes in anonymous, sometimes it doesn't, but for consistency we have a board member's name attached as the official "observer" since he or she must confirm the violation in order for it to become a formal action item. Another reason is to avoid a resident trying to slam another with bogus complaints. Yet another is so that we CAN operate as the "middle" man. If a board member's name is tied to the complaint, then it minimizes animosity between immediate neighbors.

We have about 800 homes. If the board had to verify each complaint, they would not have a life. We average 400 violations per month (though some of those maybe the same violation that hasn't been corrected). Our property manager's duties require a drive through all the property every week just for violations and general problem detection.
MicheleD (Kentucky)
Posts: 4,491
Posted:
Robert, of course I'm only sharing my experience, but in comparing yours to mine, it's apples and oranges.

We don't have a management company, probably never will. If we did, and we were as large a community, our process would no doubt be different.

Even so, 400 a month (even on carry overs) seems a little high for an 800-home community.

We have 275 homes and average about 3 to 5 violations a month. Those are generally parking violations or yard maintenance.

In the summer we may get about 4 or 5 additional per month, when basketball goals and above-ground swimming pools come out.

Last year we got a string of reports (anonymous) about not enough trees in about 10 or 15 yards. We suspect it was from someone we had to send a notice to about his yard maintenance. But we did send out the notices and all complied (we gave them 60 days and they could ask for an extension, but all the trees got planted.)

RobertG (Arizona)
Posts: 505
Posted:
If my memory serves me correct, a huge portion of the violations are for weeds or dead plants in the yard, followed by a few for trash cans out. Because we live in the desert, most of the landscaping is desert rock and when the spring warmth comes, the weeds come out in a few days. The weeds really stand out and people are lazy in getting them out. Our rules say that it is not enough to just spray and kill the weeds, you can't have the dead weed there, it has to be pulled. It really does make a difference in how it looks. Because of the weed issue, we have many repeat offenders that will take care of the problem when told, but the weeds come back. This is especially true of out of state homeowners.
GloriaM (North Carolina)
Posts: 829
Posted:
Larry:

What state are you in? Before anyone could give you particulars on enforcement, I/we would need to know what state you are in.
KevinK5 (California)
Posts: 64
Posted:
Quote:
Posted By LarryS3 on 06/28/2007 9:30 PM
Kevin do you know where I can find any articles, lawyer opinions, other expert written opinion, etc. on this matter? I am trying to convince our Board to add active CC&R enforcement.

Here are my notes from one of our meetings with a lawyer. Here's a possible scenario: A resident has a visible violation that no one complains about. Five years later another resident does the same thing and the neighbor complains. You try to enforce the rule but the resident claims selective enforcement because the same violation exists elsewhere. You try to enforce against the first violation and they claim statute of limitations. Now you're in a lawsuit with valid arguments against the HOA.
Sorry that I don't have anything official you can use to convince your board.

Discussed enforcement issues and other items with the lawyer today.

Regarding enforcement, there are typically 5 defenses used by homeowners to not comply with a restriction.
1- Selective/unequal enforcement – Rules must be enforced equally. All restrictions against a particular violation must be enforced. An owner can win a lawsuit if they can prove selective enforcement. However, the claim of selective enforcement only applies to the same or similar restriction. For example, if the association doesn’t enforce the commercial vehicle restriction, it has no impact on the mailbox restriction.
2- Unclean hands/equitable estopple – Example is if the president tells someone it is okay to build a fence, and then the board says no. The president has no power to approve this on his own, but the owner relied on what he thought was valid information. If the owner can prove they had reason to believe what they were told was valid, they can win the case.
3- Waiver – If the violation is widespread and the board has not enforced the restriction, the owner can claim the board has waived the right to enforcement. However, the board has the right to “reinvigorate” a restriction and begin enforcement again if they notify everyone of the intent to enforce in the future.
4- Statue of limitations – Florida law states that a lawsuit must be filed within 5 years from the date they knew about a violation.
5- Covenant is vague – if a covenant is clearly ambiguous, arbitrary, unreasonable, or violates a constitutional right, it can be ruled too vague to enforce. However, most judges use everyday definitions to determine meanings, and rarely declare covenants too vague.
KevinK5 (California)
Posts: 64
Posted:
PS - I am in Florida. The legal opinions from our lawyer may / may not be valid elsewhere.
RogerB (Colorado)
Posts: 5,067
Posted:
Kevin, thanks for sharing your notes. I agree with 1,2,3 &5. Are you sure the statute of limitations is 5 years in FL? Seem way too long. I believe CO is 1 year.
LarryS3 (Washington)
Posts: 13
Posted:
Gloria, I live in Arizona.
RobertR1 (South Carolina)
Posts: 5,164
Posted:
In an HOA, could management withold specific services provided by the Association until a violation is ccorrected or a fine paid? Maybe trash pick up, lawn mowing, restrict use of pool ,playgrounds. I know in a condo that has community water and the violation is severe enough, we can turn off water to the specific unit. We do this in foreclosures when owners are in arrears with any fees. I am not sure but we may have allowed the unit to be rented and received some of the rent money.
KevinK5 (California)
Posts: 64
Posted:
Quote:
Posted By RogerB on 06/30/2007 6:52 AM
Kevin, thanks for sharing your notes. I agree with 1,2,3 &5. Are you sure the statute of limitations is 5 years in FL? Seem way too long. I believe CO is 1 year.

I have never checked it out. The notes are from almost two years ago now. It is just what I wrote at the meeting.
Jadedone4 (Virginia)
Posts: 495
Posted:
Robert, if the governing doc's have any mention of "due process" requirements, it may prove hard, or long to enforce infractions in that manner.
KevinK5 (California)
Posts: 64
Posted:
Quote:
Posted By MicheleD on 06/28/2007 6:27 PM
I've been reading this thread with interest and have not commented yet, but felt compelled to after reading Kevin's post.
I would like to respectfully disagree with some of his comments...

Maybe I wasn't really clear in my comments. I meant that if the board ignores violations they see and ONLY enforce when they get a complaint from other residents then they will have the problems I mentioned.
Kevin
hoatalk (California)
Posts: 603
Posted:
Quote:
Posted By RobertR1 on 06/30/2007 4:55 PM
In an HOA, could management withold specific services provided by the Association until a violation is ccorrected or a fine paid? Maybe trash pick up, lawn mowing, restrict use of pool ,playgrounds. I know in a condo that has community water and the violation is severe enough, we can turn off water to the specific unit. We do this in foreclosures when owners are in arrears with any fees. I am not sure but we may have allowed the unit to be rented and received some of the rent money.

There has been some discussion of that here before. Other HOAs do take away use of pools, etc for non-paying members. Be careful with taking away basic utilities like water. I believe this is prohibited in some states.

HOATalk.com, A free service of Community123.com
Provider of Upscale Community Websites
CLICK HERE to get a FREE trial community website
*See legal notice below (end of page)
JM2 (Oregon)
Posts: 439
Posted:
Hi Larry (and everybody else...)

My job is to be the "compliance coordinator" for a large (1900+ living units) master planned community. We do active enforcement, along with complaint-driven enforcement as well (I keep lobbying the board for a helicopter to do site reviews of back yards, but to no avail)...

There is a senior (55+) community nearby that has a 5-member "compliance committee" that walks the neighborhood every week (they divide it up) and reports to the manager, who then follows up with compliance issues. This might be something your board would consider.

In the HOA that I work for, the first step in the compliance process is to write articles on relevant issues for our newsletter - using education as the first part of the process. When that doesn't work, then I typically write a "customer-service friendly" letter. Then, there's a notice in line with the procedures in our enforcement policy, with a specific number of days to bring things into compliance, followed by fines if there's no compliance. A good, well written policy can be a great help, since it lays out your due process for owners in the enforcement process.

Larry, you might check out the CAI website for any books on covenant enforcement.

J. Patrick Moore, CMCA

🎯 You've read this entire discussion

Join the conversation with 50,000 HOA & Condo Leaders:

  • ✓ Ask follow-up questions
  • ✓ Share your experience
  • ✓ Get expert advice
  • ✓ Access 350,000 discussions
Create Free Account →

⚡ Takes 30 seconds

Already a member? Log in here