This is in reference to maximum charges for disclosure packages for homeowners' associations that are not professionally managed.  The changes appear reasonable; and I am in support of them. I am the Secretary of an all volunteer HOA and responsible for developing and providing disclosure statements for new buyers.  The issue I find frustrating is the once every five-year change cycle; they should be changed annually to keep up with costs.  

The guidance document appears to only address maximum fees for disclosure packets for professionally managed associations (55.1-1810) which will have increased by 41% from the initial maximum fees set in 2008.  Maximum fees for disclosure packets for associations not professionally managed (55.1-1811) appear not to be increased and remain at the level set in 2008.  May I request that appropriate steps be taken to increase the maximum fees for associations not professionally managed by a similar amount to those for professionally managed associations.  Volunteer associations are already shortchanged by not being allowed to charge for items such as inspection and post-closing that professionally managed associations can charge for.  The preparation of disclosure packets is a substantial effort for volunteers for which the association should be fairly compensated.

I voluntarily prepare packets for two associations to which I belong, one of which requires two separate packets depending on lot number/address (different C&R's), so both need to be updated.  I follow the DPOR/CIC Discl Packet Notice (20 items) to the letter, which requires searching VA and DPOR/CIC sites to make sure I am up to date on any changes/additions.  I must check to ensure our registrations with DPOR/CIC and the SCC are up to date.  I must also verify that the lot and structures are in compliance with our docs, and whether fees are up to date.  I must also insert new annual and BOD minutes plus all the required financials.  Each packet requires hours of my attention to detail to ensure it is correct for each sale before it is distributed to those involved.

Obviously, to do this, I must communicate with the secretary and treasurer on our Board for each packet, as well as have someone look at the property.  I must communicate with the selling agent and the closing agent, and sometimes field questions from the seller or the buyer or buyer's agent, too.  All of this takes considerable time.

I believe the allowable fees for a disclosure packet are far too low in consideration of the time it takes to do a complete and accurate update for each sale.  If the DPOR and CIC wish us to have the best packets (which take considerable time and effort), we should be able to have a better compensation.  I have been told by real estate agents that our packets are better than many professionally managed associations.  Well, we take pride in our work for our community.

Please consider raising the fee to adequately compensate the Association for handling this complicated task as well as the professionals.  Thank you.

Sincerely,

Mary Page