Dear Members of the Virginia Common Interest Community Board and Virginia Department of Professional and Occupational Regulations (DPOR),

 

Thank you for your remarkable work on developing the regulations for the Common Interest Community Manager licensure program.   Our comments are collaborative work of the Community Associations Institute Virginia Legislative Action Committee (VA-LAC) and the National Board of Certification for Community Association Managers (NBC-CAM). Together, we represent the community association management profession in Virginia and the homeowners living in community associations throughout the Commonwealth of Virginia who are protected by the Common Interest Community Manager Licensure Program. 

 

Thank you in advance for your favorable considerations of our comments.

Our specific comments are listed below:

 

Comment:          The comprehensive training program is already approved by the Virginia CICB and therefore has been determined to meet with the Board’s requirements.

 

Comment:          This option is a significant variance from the other options. This option says that the SUPERVISORY EMPLOYEE will have nearly the same requirements as the certified manager. 

 

                                It is our understanding that the original purpose of this option was to provide a solution to companies who were concerned that they would be unable to meet the requirements in the required timeframe (by June 30, 2011). Since the deadline has been extended, this option is no longer necessary.

 

Suggestion:        Delete the option “Has successfully completed an introductory training program as described in 18VAC48-50-250 A, as approved by the board, and has at least five years of experience in providing management services, the quality of which demonstrates to the board that the individual is competent to provide management services;”

 

Comment:          We assume that the Virginia CICB is looking for quality in programming; which is much more easily measured than quality in experience.

 

Suggestion:        Insert “, the quality of which demonstrates to the board that the individual is competent to provide management services” after “ Has not completed a board-approved training program but who, in the judgment of the board, has obtained the equivalent of such training program by documented coursework that meets the requirements of a board-approved comprehensive training program as described in Part VI (18VAC48-50-230 et seq.) of this chapter”

Delete “ the quality of which demonstrates to the board that the individual is competent to provide management services” from the end of the paragraph. 

 

 

Has not completed a board-approved training program but who, in the judgment of the board, has obtained the equivalent of such training program by documented coursework that meets the requirements of a board-approved comprehensive training program as described in Part VI (18VAC48-50-230 et seq.) of this chapter - , the quality of which demonstrates to the board that the individual is competent to provide management services, and has at least 10 years of experience in providing management services.

Comment:         The language is too broad and may be interpreted in situations that are irrelevant or potentially insignificant to community management. For example, driver’s license, pet license, bicycle license, hunting license, etc…). These examples do not indicate that a person has “character or minimum skills” issues which are the statutory rationale for the regulations.

 

Suggestion:        Insert “, all as related to providing management services as defined in §54.1-2345 of the Code of Virginia” after “action” at the end of the section.

Any disciplinary action taken by ay jurisdiction, board, or administrative body of competent jurisdiction, including but not limited to any reprimand, license or certificate revocation, suspension or denial, monetary penalty, requirement for remedial education, or other corrective action, all as related to providing management services as defined in §54.1-2345 of the Code of Virginia.

 

Comment:          The language is too broad and may be interpreted in situations that are irrelevant or potentially insignificant to community management. For example, driver’s license, pet license, bicycle license, hunting license, etc…). These examples do not indicate that a person has “character or minimum skills” issues which are the statutory rationale for the regulations.

Any voluntary surrendering of a license, certificate, or registration done in connection with a disciplinary action in another jurisdiction, all as related to providing management services as defined in §54.1-2345 of the Code of Virginia.