Thank you for the opportunity to comment.  

The new language in 18VAC48-50-15 (A) Necessity for licensure of firms and certification of employees seems to highlight the available exemptions under § 54.1-2347 from CIC Manager licensing requirements.  

1. Is it the CIC Boards intent to further highlight the exemptions available under § 54.1-2347?
2. If yes, as it applies to § 54.1-2347. (A)(9), is it the intent of the Board to further highlight the exemption for "firms" (further real estate brokerage firms)?
3. If not, is it the intent of the Board to require duly licensed real estate brokerage firms, brokers, and salesperson to also be licensed with the CIC Board when providing management services to CIC's? 
4. Will the CIC Boards enforcement standards for firms who are required to be licensed change  if/when the new regulations take effect?  

I don’t understand why the last sentence is needed. What more information can a surety/insurance company “certify” as to “sufficient coverage” than is already required to be provided by the subsection? A surety/insurance company may be reluctant, if not decline outright, to interpret the statute and provide such a statement to an insured party

#1. Are the “communications” part of this intended to be directly related to the “governance and legal matters” that precede? If not, I suggest removing it from #1, adding “and customer service” after “communications” and making this a separate potential training opportunity.

#4 and #7. I suggest combining as they directly relate to one another and any training regarding maintenance will inevitably bring up contracting, and vice versa

What does the Board envision when using the word “audit,” when might the Board invoke the process and how would the Board go about conducting the process? Would the provisions of 18-VAC-48-50-220 possibly apply?

#15. While I recognize it is (unfortunately) used in the statutes the word “improper” is a  subjective term and I respectfully request the Board to strike the word from this provision. If the Board is attempting to insert language related to “proper conduct in providing management services” then I suggest language that refers to “generally accepted standards” similar to the language struck from #10

Thank you for your consideration of all my comments.