Homeowner association

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could be released at the pre-development flow level. Since these detention areas serve multiple residences, they are almost always designated as "common" areas. This requirement was a reason for developers to establish an HOA. Although these areas can be placed on an individual homeowner's lot, eliminating the need for an association, some U.S. municipalities now require these areas to be part of a common area to ensure an entity, rather than an individual or the municipality itself, has maintenance responsibility. Real estate developers have frequently established HOAs to maintain such common areas. Having established the HOA, the developers have expanded their scope, giving them authority to regulate changes to residences, landscaping and maintenance requirements, color of houses, etc., a variety of other requirements and amenities that the developers believe will make their project more desirable to the market.

601:. These are likely the most important documents affecting the subdivision and are usually created when the subdivision is initially formed, and as such are often recorded in the official property records of the county or other jurisdiction where the subdivision is located. Commonly the CC&Rs specify what types of structures can be placed on a lot (e.g. an upscale community may prohibit mobile homes or travel trailers and require minimum sizes on dwellings, along with offsets from the property line where building is prohibited) and other property restrictions (e.g. no animals except for traditional household pets, no operation of commercial business). 760:"...critics of private governments claim that HOAs erode support for public institutions. Those who join can bypass the public system: homeowners who fear crime do not have to vote for tax dollars to attack the root of the problem; they can build a gate to keep the criminals out. Opponents maintain that the erosion of public support, reflected at the ballot box, leads to further deterioration of municipal services and reductions in local revenues. Nonmembers experience a reduction in public service levels and may be worse off. At the extreme, HOAs may contribute to sentiments of secession and withdrawal from the public sector." 1220:"Curiously, with rare exceptions, when the State has notified boards of minimal association legal obligation to owners, they dispute compliance. In a disturbing number of instances, those owners with board positions use their influence to punish other owners with whom they disagree. The complete absence of even minimally required standards, training or even orientations for those sitting on boards and the lack of independent oversight is readily apparent in the way boards exercise control" 1345: 241: 710:, "houses in HOAs have prices that are on average at least 4%, or $ 13,500, greater than observably similar houses outside of HOAs. The HOA premium correlates with the stringency of local land use regulation, local government spending on public goods, and measures of social attitudes toward race." The study also found that people in HOA neighborhoods "are on average more affluent and racially segregated than those living in other nearby neighborhoods." 1251:

owner cannot use. The proliferation of planned unit developments has resulted in a cost savings to local governments in two ways. One, by requiring developers to build 'public improvements' such as parks, passing the cost of maintenance of the improvements to the common-interest owners; and two, by planned-unit developments being responsible for the cost of maintaining infrastructures that would normally be maintained by the municipality.

77: 179: 36: 1958:, 37 (Supreme Court of California September 2, 1994) ("...owners associations "can be a powerful force for good or for ill" in their members' lives. Therefore, anyone who buys a unit in a common interest development with knowledge of its owners association's discretionary power accepts "the risk that the power may be used in a way that benefits the commonality but harms the individual.""). 612:

declared unenforceable as a matter of public policy in at least one state, where the developer attempted to amend years after he had sold all the property. That state's legislature later codified that public policy. Other examples include CC&Rs which prohibited sales of property to certain racial groups; the Fair Housing Act rendered all of these also to be unconstitutional and unenforceable.

1238:

only five percent of the membership demand a vote. This part of the civil code also ensures that any dissenting individual who seeks a director position must be fully represented to the membership and that all meetings be opened and agenda items publicized in advance. In states like Massachusetts, there are no laws to prohibit unilateral changes to the documents by the association board.

837:, whose values or incentives may not be aligned with the tenants'. However, some HOAs limit owners of multiple properties to one or two votes regardless of the number of lots owned, so absentee owners do not end up controlling the HOA to the detriment of residents who only own a single lot or two contiguous lots as a current or future residence or vacation home. 1226:

inability to secure the attention of boards or property managers, to acknowledge no less address their complaints. Perhaps most alarming is the revelation that boards, or board presidents desirous of acting contrary to law, their governing documents or to fundamental democratic principles, are unstoppable without extreme owner effort and often costly litigation.

731:"...Owners associations 'can be a powerful force for good or for ill' in their members' lives. Therefore, anyone who buys a unit in a common interest development with knowledge of its owners association's discretionary power accepts 'the risk that the power may be used in a way that benefits the commonality but harms the individual.'" 1029:. However, the need for an unscheduled examination can arise in cases of major changes, like a transition to a new board or management company, implementation of a large-scale improvement project, receipt of a significant sum of money under unusual circumstances, suspicion of fraud or embezzlement, or other misconduct. 990:

boards carry appropriate liability insurance to indemnify the association from any wrongdoing. The large budgets and expertise required to run such groups are a part of the arguments behind mandating manager certification (through Community Association Institute, state real estate boards, or other agencies).

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municipalities of the costs of road and utility maintenance, developers may obtain more favorable terms. Ordinarily, the developer retains some control over the HOA until a specified number of units are sold, and the covenants, conditions, and restrictions of the HOA are put in place to further this goal.

1104:

and make sure all the funds were spent as intended and properly documented. Also, an auditor can verify bank statements, reconciliations, payroll records, canceled checks, loan statements, approved contracts and leases, proof of real estate and equipment ownership, records on capital assets, supplies

1020:

In the US, auditing requirements vary from state to state, as well as from HOA to HOA. Some associations are obliged to audit their financial statements on an annual basis or once every few years. For others, it is enough to conduct a review, a compilation or an agreed-upon procedures engagement. The

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HOA boards can also collect special assessments from its members in addition to set fees, sometimes without the homeowners' direct vote on the matter, though most states place restrictions on an association's ability to do so. Special assessments often require a homeowner-vote if the amount exceeds a

748:

Many municipalities have welcomed HOAs in the belief that they may reduce operational costs for the local government. Since the homeowners sometimes pay for roads, parks, and other services within the development, the local government may believe it can gain revenue from property taxes from owners in

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Disadvantages to homeowners may include the financial burden of association fees, punitive fines, and costs of maintaining appearance standards; restrictions on property use and personal autonomy; and the potential for mismanagement by the board, including the possibility of arbitrary or heavy-handed

611:

Generally CC&Rs are enforceable as legal documents. However, there are instances where a CC&R is rendered illegal by later enacted state or federal law and therefore is no longer enforceable. For example, a developer-drafted covenant giving the developer sole rights to amend the CC&Rs was

572:

Although in some cases membership in an HOA may be voluntary for a property owner, in the majority of cases membership in an HOA is mandatory. Once an owner purchases property within the subdivision, that owner becomes a mandatory member of the HOA, and must pay assessments to, and abide by the rules

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or for homes in subdivisions that had a qualifying HOA. The rationale was that developers wanted to get around density laws. The effect, however, was to divert investment from multi-family housing and home construction or renovation in the inner cities. This accelerated the middle-class exodus to the

1246:

Most homeowners are subject to property taxation, whether or not said property is located in a planned unit development governed by an HOA. Such taxes are used by local municipalities to maintain roads, street lighting, parks, etc. In addition to municipal property taxes, individuals who own private

1237:

California law has strictly limited the prerogatives of boards by requiring hearings before fines can be levied and then reducing the size of such fines even if the owner-members do not appear. In California, any rule change made by the board is subject to a majority affirmation by the membership if

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Increasingly, HOAs handle large amounts of money. Embezzlement from associations has occurred occasionally, as a result of dishonest board members or community managers, with losses up to millions of dollars. Again, California's Davis–Stirling Act, which was designed to protect owners, requires that

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disputes the claim that HOAs protect property values, stating, based on a survey of Harris County, Texas (which had an unusual legal regime regarding foreclosures): "Although HOA foreclosures are ostensibly motivated by efforts to improve property values, neither foreclosure activity nor HOAs appear

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held that private residential communities had the right to place reasonable limitations on political speech, and that in doing so, they were not acting as municipal governments. With few exceptions, courts have rejected claims that private actors are subject to constitutional limitations in a manner

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note that the association's creator (e.g. a developer) has an incentive to set up a government structured in such a way as to maximize profits and thus increase the selling price of the property. If a certain decision would increase the selling price of certain parcels and decrease the selling price

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The perception of the benefits that an HOA provides to homeowners varies depending on the specific regulations and practices of the HOA. These benefits may include amenities (eg. a pool, tennis courts, clubhouse, and open areas). Individuals may also benefit more or less depending on their political

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When determining what the assessment should be, it is important to consider what funds are required. There should always be a minimum of two funds: an operating fund and a reserve fund. The operating fund is used to pay for the operating expenses of the association. A reserve fund is used to pay for

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to the property owners; violation of that duty may result in liability for individual directors, and as such the HOA will often adopt an ethics code for the board members to ensure they act ethically and in accordance with their responsibilities. To gain a clear understanding of the responsibilities

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Usually, the board (or parts of it) will be elected at an annual meeting of the homeowners, as specified in the Bylaws. In order to avoid an owner of multiple lots (who likely own the lots for resale or rental property) controlling the HOA's operation (to the detriment of those owners who only own a

1285:

Many HOAs have restrictive covenants preventing a homeowner from installing an OTA (over-the-air) rooftop antenna. These restrictions are also no longer enforceable, except in some instances. For example: the antenna may be installed at any location unless it imposes upon common property. Also, the

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Corporation and HOA laws provide a limited role for HOA homeowners. Unless either statutory law or the corporation's governing documents reserve a particular issue or action for approval by the members, corporation laws provide that the activities and affairs of a corporation shall be conducted and

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A CPA determines what obstacles can float up when testing the association's accounting procedures and preparing financial statements, gauges the significance of potential problems, and finds ways to overcome them. To collect the necessary information and evaluate an HOA's financial performance, the

985:

In some exceptional cases, particularly in matters of public health or safety, the amount of special assessments may be at the board's discretion. If, for example there is a ruptured sewer line, the Board could vote a substantial assessment immediately, arguing that the matter affects public health

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In California, for example, a special assessment can be imposed by a board, without a membership vote, only when the total assessment is five percent or less of the association's annual budget. Therefore, in the case of a 25-unit association with a $ 100,000 annual operating budget, the board could

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A 2009 study of California HOAs suggested that this assumption was partially true, but that the overall effect of HOAs on municipalities was mixed. While HOAs did offset the costs of city governments to a small degree, they also reduced overall tax revenues because their members, insulated from the

543:

In the 1970s, a growing scarcity of land for suburban development resulted in escalating land costs, prompting developers to increase the density of homes on the land. In order to do this while still retaining a suburban look, they clustered homes around green open areas maintained by associations.

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HOAs have been criticized for having excessively restrictive rules and regulations on how homeowners may conduct themselves and use their property. Some maintain that HOA leaders have limited financial incentive to avoid indulging in rigid or arbitrary behavior, and unless people begin to leave in

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The assessment may be paid monthly, quarterly, or annually; generally the more amenities provided the more frequent the assessment must be paid. Some associations operate little or no common property, and the expenses relate solely to enforcement of use restrictions or assumed services. Others are

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In return, the owner/member is permitted to participate in the HOA's governance and use the amenities offered by the HOA, provided that they are current on assessments (or on a payment plan to become current). Once an owner sells or otherwise transfers interest in all the property owned within the

1250:

A non-HOA property owner pays taxes to fund street repairs performed by the city. The HOA property owners pay these same taxes, and benefit from their use of public roads, etc. without the local government (i.e. taxpayers) having to pay for the HOA's private roads, etc. which the non-HOA property

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a member's house without any judicial procedure in order to collect special assessments, fees and fines, or otherwise place an enforceable lien on the property which, upon the property's sale, allows the HOA to collect otherwise unpaid assessments. In 2008, a soldier, who was serving in Iraq, was

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Real estate developers establish HOAs in the belief that they can contribute to the developer's ability to build and sell units profitably. Providing common amenities may enable developers to build at a higher density, if the local government has encouraged such results. In addition, by relieving

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Education requirements for managers varies from state to state, with some requiring certification under all circumstances and others having a more lenient approach. For instance, while California does not require HOA managers to be certified, it does require that managers meet certain educational

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of 1977 required that all new real estate developments had to detain storm water so that flow to adjoining properties was not greater than the pre-development runoff. As a result, nearly all residential developments had to construct detention or retention areas to hold excess storm water until it

1225:

Overwhelmingly ... the frustrations posed by the duplicative complainants or by the complainants' misunderstandings are dwarfed by the pictures they reveal of the undemocratic life faced by owners in many associations. Letters routinely express a frustration and outrage easily explainable by the

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Depending on the governing documents or state law, the HOA may have the authority to place liens on a property (for non-payment of assessments and/or noncompliance with CC&Rs, an example would be the costs to remove a non compliant structure such as a mobile home on a lot restricted to "site

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Depending on the governing documents, HOA boards may create committees, such as an "architectural control committee" (this is a very common one, and frequently this committee has the ultimate authority to approve or deny a building request), a pool committee, a neighborhood watch committee, etc.

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Early covenants and deed restrictions were established to control the people who could buy in a development. In the early postwar period after World War II, many were defined to exclude African Americans and, in some cases, Jews, with Asians also excluded on the West Coast. For example, a racial

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founded in 1916. These were the children of deed restrictions in a new kind of planned subdivision, and they established the national legal precedent for zoning districts exclusively for upscale, single-family residences. Private restrictions normally included provisions such as minimum required

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Benefits to homeowners may include maintenance and management services, provision of recreational amenities such as pools and parks, insurance coverage, enforcement of community appearance standards which may lead to higher property values, and the opportunity for members to plan development in

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Homeowners have the ability to defend against such actions, and are usually entitled to sue HOAs for contractual or statutory violations, or for a legal determination as to the enforceability of a provision in the governing documents. However, because HOAs are private associations, they are not

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services plus help with board meetings (keeping minutes, agendas, etc.), board elections, and maintenance duties (obtaining contractor bids, etc.). On-site management typically includes all of the full management services plus direct assistance to homeowners with an assigned manager to the HOA.

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Management services are typically divided into three categories: financial only, full management, and on-site management. Financial services typically cover administration of bank accounts, bookkeeping, assessment collection, and the HOAs budget. Full management typically includes the financial

585:

Usually HOAs are structured as private corporations or private unincorporated associations (commonly as non-profit ones). HOAs are governed by federal and state statutes applicable to corporations (or unincorporated associations if so structured), as well as the HOA's own "governing documents".

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may have multiple votes for each lot it retains, but the homeowners are limited to only one vote per lot owned. This has been justified on the grounds that it allows residents to avoid decision costs until major questions about the development process already have been answered and that as the

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The major power of the HOA is the ability to compel property owners to pay a share of common expenses for the overall maintenance of the HOA and the amenities, usually proportionate to the ownership interests (either by unit or based on square footage). These expenses generally arise from the

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These associations provided services that formerly had been provided by municipal agencies funded by property taxes. Residents of such development also had to pay their local taxes. Accordingly, local governments began promoting subdivision development as a means of improving their cash flow.

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The board of directors makes decisions regarding the HOA, including management of the HOA's finances, protecting the HOA's real and intangible assets (generally the amenities provided which were the basis for inducing people to purchase lots), and enforcing the governing documents. Boards of

627:

Initially, the board is composed of developer-appointed members, in order to maintain the character of the community that the developer has for it. As the percentage of ownership shifts from the developer toward owners, the corresponding percentage changes from developer-appointed members to

1202:

to be filed against the board and the HOA. In some instances, a known failure to rectify the board's governance to meet the state's statutes can open the board's members to personal liability as most insurance policies indemnifying the board members against legal action do not cover willful

1057:. The auditee must provide the CPA with the most recent audit report, copies of annual tax returns, current and ensuing year's budget, board minutes, covenants, bylaws, and other internal documents. The CPA tests internal controls for incoming and outgoing transactions, the maintenance of a 690:

effectively private towns, with elaborate amenities including private roads, street lights, services, utilities, commonly owned buildings, pools, and even schools. Assessments paid to HOAs in the United States amount to billions of dollars a year, but are not classed as property taxes.

1100:. The previous year's results are compared with the current results. Since it is impossible to cover all of an HOA's transactions in an audit, a CPA selects a sample of transactions and scrutinizes details. For example, they can use a sample of outgoing transactions to verify 914:

permitting homeowners to post political signs and strike down the political signage restrictions by the association as unconstitutional. The appeals court held the restrictions on political signs unconstitutional and void, but the appeals court was reversed when the

1190:"all corporate powers shall be exercised" by or under the direction of the board of directors. Many boards are operated outside of their state's non-profit corporation laws. Knowledge of corporate laws and state statutes is essential to properly managing an HOA. 1134:

One more option is a disclaimer of opinion, a document compiled when a CPA is unable to issue an audit report due to conflicting interests with an HOA, non-provision of the requested financial documents, or significant uncertainty in the association's accounting

1278:. Many communities still have these rules in their CC&Rs, but after October 1996, they are no longer enforceable. With a few exceptions, any homeowner may install a satellite dish of a size of one meter or smaller in diameter (larger dishes are protected in 669:

Through its board an HOA will provide some level of amenities (though differing greatly between HOAs), regulate activities within a development, levy assessments, and may (if authorized by CC&Rs or a state legislature) impose fines for noncompliance.

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Depending on the state, board meetings may be required to be open to the public, except in instances where a board may enter into an "executive session" for discussion on confidential matters (e.g. discussions with its attorney on an upcoming lawsuit).

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property located within planned unit developments are subject to association assessments that are used by the development to maintain the private roads, street lighting, landscaping, security, and amenities located within the planned unit development.

3035:

The Homes Association Handbook: A Guide to the Development and Conservation of Residential Neighborhoods with Common Open Space and Facilities Privately Owned and Maintained by Property-owners Associations Founded on Legal Agreements Running with the

1301:. In spite of the law, at least one homeowner has faced harassment and threat of fines from an HOA for having insufficient grass after landscaping his yard to reduce water usage. Similar legislation was introduced and passed by the legislature in 1061:, the appropriateness of financing of major contracts and improvement projects, the proper disposal of funds acquired in legal cases and under other extraordinary circumstances, and the availability and accuracy of journal entries of receipts and 1286:

antenna must be of a design to receive local, not long-distance signals and must not extend any higher than twelve feet above the top roof-line of the home, unless an exception is granted by the HOA due to extenuating terrestrial interference.

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operation and maintenance of common property, which vary dramatically depending on the type of association. An HOA may have, in addition to a regular assessment, a "special" assessment for unexpected expenses (such as for road maintenance).

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Improvement recommendations in an audit report can be used to fix the board's past mistakes, establish internal discipline, and adopt more effective accounting practices. Also, audited financial statements serve as evidence of the board's

1328:

In both cases, certain guidelines are set out by the covenant or the lease contract. In the latter scenario, the landowner has a stronger incentive to maximize the value of all the governed property in the long term (because they are the

1309:. Residents in Colorado have continued to call for regulation to protect xeriscaping, citing HOAs that require the use of grasses that consume large quantities of water and threaten fines for those who do not comply with the covenants. 408:

in 1985. In Canada, HOAs are subject to stringent provincial regulations and are thus quite rare compared to the United States. However in recent decades, HOAs have infrequently been created in new subdivision developments in

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larger community, tended to vote down taxes that the city required to fund services. This led to an overall decrease in government expenditures that disproportionately affected those citizens who did not reside in an HOA.

1065:. These issues are given the most attention, since they have the strongest influence on an HOA's financial health. Also, an auditor reaches out to third-party organizations to verify the HOA's transactions on both sides: 1193:

Once notified by a homeowner, attorney or other government official that an HOA organization is not meeting the state's statutes, the board has the responsibility to correct their governance. Certain states, such as

993:

In 2006, the AARP voiced concern that HOAs pose a risk to the financial welfare of their members. They have proposed that a homeowners "Bill of Rights" be adopted by all 50 states to protect seniors from rogue HOAs.

865:, number of cars on a property, what animals you can have on your property, the maximum volume for playing music at certain times of day, what signs you can display on your property, and what plants you can plant. 817:

HOAs established a new community as a municipal corporation. Voting in an HOA is based on property ownership, By the 1970s, only property owners had were eligible to vote, while renters are prohibited from directly

368:

In most cases, a person who wants to buy a residence within the area of a homeowner association must become a member, and therefore must obey the governing documents including articles of incorporation, CC&Rs

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An HOA board makes an initial inquiry to an accounting specialist about the need to conduct an audit. A consultation is held to negotiate the objectives, time frame, report deadlines, and cost of the examination.

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the infrequent and expensive common area assets maintenance, repair and replacement costs. The reserve fund is crucial for reducing the chances of a special assessment (mentioned in the risks below). Obtaining a

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Qualified opinion: minor misrepresentations or deviations from GAAP were found in the HOA's accounting papers. This does not significantly influence its overall financial performance, and mistakes are easy to

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a level of government. Homeowners who believe a breach of duty has occurred by the board of directors may run for the board at the next election or, in extreme cases, sue the association at personal expense.

773:

The potential disadvantage to a developer is that they may be exposed to liability to the HOA for poor construction, misleading marketing, or other problems. In these cases, the HOA may sue the developer.

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and inventories. If the HOA's actual financial performance deviates from the planned indicators, the auditee must provide evidence that fluctuations are not due to the board's negligence or misconduct.

1009:(Certified Public Accountant) conducts a comprehensive analysis of an association's financial records and accounting procedures, to determine whether they are accurate, legitimate and compliant with 1113:

An audit report states the CPA's opinion on the HOA's financial health and its compliance with accounting documents and with generally accepted standards. There are three types of audit reports:

1021:

HOA's budget, size and terms prescribed in covenants and bylaws often act as decisive factors when determining whether an audit is obligatory for a particular board. An audit at the end of each

373:, conditions and restrictions) and by-laws—which may limit the owner's choices, for example, exterior design modifications (e.g., paint colors). Homeowner associations are especially active in 3212:

Goodwin, Kimberly R.; La Roche, Claire Reeves; Waller, Bennie D. (2 July 2020). "Restrictions versus amenities: the differential impact of homeowners' associations on property marketability".

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Barton, Stephen E.; Silverman, Carol Janet (1994). "Common Interest Communities: Private Government and the Public Interest Revisited". In Barton, Stephen E.; Silverman, Carol Janet (eds.).

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single lot or two contiguous lots as a current or future residence or vacation home), the Bylaws may limit all owners (regardless of the number of lots owned) to one or two votes per owner.

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estimated that in 2010, HOAs governed 24.8 million American homes and 62 million residents. Throughout the rest of the world, HOAs—though they do exist in some neighborhoods—are uncommon.

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that an HOA's power to fine owners for rule violations (including being in arrears) is limited to those expressly provided in the HOA's valid governing documents (e.g. the HOA's Bylaws).

1446: 484:, neighborhood stated, "No part of said property hereby conveyed shall ever be used or occupied by any Hebrew or by any person of the Ethiopian, Malay or any Asiatic race." In 1948, the 1234:, for example, requires a due process hearing to be held before any homeowner may be fined for a covenant violation. It also limits the amount of the fine and sets other restrictions. 504:

According to Donald R. Stabile, the explosion in the number of CIDs (many of which were based on homeowners' associations) was strongly influenced by a 1964 publication (TB 50) by the

1994: 3149:

MacCallum, Spencer Heath (2002). "The Case for Land Lease versus Subdivision: Homeowners' Associations Reconsidered". In Beito, David T.; Gordon, Peter; Tabarrok, Alexander (eds.).

1318: 868:

Homeowners have challenged political speech restrictions in associations that federal or state constitutional guarantees as rights, claiming that certain private associations are

830:, author Hugh Mields, Jr. raised questions about the constitutionality of having an association that had the authority of a municipal government, despite being private in nature. 982:

only impose a $ 5,000 assessment on the entire population ($ 5,000 divided by 25 units equals $ 200 per unit). A larger assessment would require a majority vote of the members.

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context, it would not view judicial enforcement of a private contract as state action, but as private action, and accordingly would disallow any First Amendment relief.

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The Community Associations Institute (CAI) is a trade association of individuals and businesses that sell supplies or services to HOAs, and is dominated by lawyers and

2317: 2308: 3011:

Boudreaux, Donald J.; Holcombe, Randall G. (2002). "Contractural Governments in Theory and Practice". In Beito, David T.; Gordon, Peter; Tabarrok, Alexander (eds.).

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Tabarrok, Alexander (2002). "Market Challenges and Government Failure: Lessons from Voluntary City". In Beito, David T.; Gordon, Peter; Tabarrok, Alexander (eds.).

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Unqualified opinion: in all respects, the HOA's financial statements are accurate, legitimate, reflect the actual activity of the association and comply with GAAP.

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of it all) and to keep the residents happy, since their income is dependent on their continued patronage. These factors are cited as arguments in favor of MTIPs.

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had been foreclosed on and sold for $ 3,500 to recover unpaid HOA dues of $ 800. In 2010, the case was settled and the soldier regained ownership of the home.

1282:). While HOAs may encourage that dishes be placed as inconspicuously as possible, the dish must be allowed to be placed where it may receive a usable signal. 593:, which means that all current and future owners of property within the HOA will be bound by them as a condition of property ownership. They usually include: 804:

of others, the developer will choose the option that yields his project the highest net income. This may result in sub-optimal outcomes for the homeowners.

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considered "state actors" subject to constitutional constraints, and therefore homeowners cannot sue for civil rights violations under 42 U.S.C. 1983.

405: 320:, is a private, legally-incorporated organization that governs a housing community and sets rules for its residents. They are found principally in the 2380: 2109: 1865: 564:. The CAI does not represent HOAs. It lobbies the legislatures of states that have HOAs in order to promote legislation beneficial to its interests. 540:

suburbs and into common-interest housing. The rapid expansion of federally subsidized highways under federal programs made access to new areas easy.

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costs for home construction and the exclusion of all non-Caucasians, and sometimes non-Christians as well, from occupancy, except domestic servants.

3283:

Sproul, Curtis C. (1994). "The Many Faces of Community Associations under California Law". In Barton, Stephen E.; Silverman, Carol Janet (eds.).

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Several court decisions have held that private actors may restrict individuals' exercise of their rights on private property. A 2007 decision in

833:

Additionally, voting representation is equal to the proportion of ownership, not to the number of people. The majority of property owners may be

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Account confirmations are requested from banks to check whether the association's operational and reserve accounts contain the claimed sums.

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Many HOAs (especially larger ones with more upscale amenities) hire management companies to handle the governing duties of the association.

525: 2002: 1421: 1157:

and investors. After issues revealed in the initial audit are fixed, a repeat examination is conducted according to the standard scenario.

1321:(MTIP). CIDs and MTIPs have fundamentally different forms of governance. In a CID, dues are paid to a nonprofit association. In an MTIP, 365:, as a de facto form of segregation, designed to keep out African-Americans and Jews (and later Asians) in his real estate developments. 3347: 17: 2508: 2348: 1506: 645:

of the HOA board, community members need to read their association's CC&Rs, Articles of Incorporation and Bylaws, and other rules.

1153:

The need for a repeat audit may arise if the board has received an adverse opinion and wants to restore its good name in the eyes of

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and sound strategies when reporting to unit owners, investors, potential real estate buyers, tenants and other interested parties.

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auditor interviews board members at their office, monitors the main day-to-day operations, tests their security, and performs

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standing in the association and the degree to which the community's decisions match their preferences. In the 1994 court case

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case, a group of homeowners collectively called The Committee for a Better Twin Rivers sued the association, for a mandatory

509: 120: 2922: 2903: 1597: 1215:"It is obvious from the complaints that that owners did not realize the extent association rules could govern their lives." 698:

is recommended to help determine and set the reserve contribution rate which is included in the regular monthly assessment.

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and safety. In practice, however, most boards prefer that owners have a chance to voice opinions and vote on assessments.

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Barton, Stephen E.; Silverman, Carol Janet (1994). "Introduction". In Barton, Stephen E.; Silverman, Carol Janet (eds.).

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By requiring approval of tenants and new owners, HOAs still have the potential to permit less formalized discrimination.

966:. Foreclosure without a judicial hearing can occur when a "power of sale clause" exists in a mortgage or deed of trust. 3453: 3443: 2228: 1177:, describing HOAs as a kind of private entity, HOA boards of directors are not bound by constitutional restrictions on 127: 3129: 3118: 1075:

The same is done for loans. A CPA verifies loan balances, interest rates, repayment terms and other important details.

3405:

Sussman, Marvin B. (October 1957). "The Role of Neighborhood Associations in Private Housing for Racial Minorities".

3192: 3097: 2844: 628:

homeowners elected at an annual meeting, and ultimately the board will consist solely of homeowner-elected members.

607:

In some cases the documents may include board-enacted rules as authorized (expressly or implicitly) by the CC&Rs.

303: 285: 222: 160: 63: 3076: 1829: 204: 2751: 2385: 1510: 1306: 1013:(GAAP) or other reporting frameworks. Upon completion of the planned auditing procedures, a CPA issues an official 445: 2279: 471:, a transit magnate who developed several whites-only housing divisions. The Los Feliz Improvement Association in 109: 949: 3272:

California Real Property Journal: Official Publication of the Real Property Law Section, State Bar of California

3171: 2210: 1753:"RCW 64.38.028 - Removal of discriminatory provisions in governing documents—Procedure, see footnote on intent" 1271: 513: 189: 98: 2416: 1363: 561: 358:. The developer may transfer control of homeowner association after selling a predetermined number of lots. 3243:""Hemmed in": The Struggle against Racial Restrictive Covenants and Deed Restrictions in Post-WWII Chicago" 1127:

Adverse opinion: accounting violations that point to fraud or the board's blatant negligence were detected.

2800: 2390: 2120: 1862: 1211:

The New Jersey Department of Community Affairs reported these observations of Association Board conduct:

1006: 485: 425: 3032:

Hanke, Byron R; Krasnowieki, Jan; Loring, William C.; Tweraser, Gene C.; Cornish, Mary Jo, eds. (1970).

2884: 536: 263: 55: 2054: 590: 1260: 826:

under their lease contract, since that is the party who has responsibility to them. In the 1973 book

792: 404:, have limited HOA law. HOAs are commonly found in residential developments since the passage of the 2254: 1583: 970: 916: 724: 429: 377:, zoning, and land use—decisions that affect the pace of growth, the quality of life, the level of 267: 134: 1892:

Clarke, Wyatt; Freedman, Matthew (2019-07-01). "The rise and effects of homeowners associations".

2801:"Shadowood Condominium Association et al., v. Fairfax County Redevelopment and Housing Authority" 2464: 841: 521: 389: 355: 200: 87: 2952: 1874: 1781: 259: 196: 2818:"Reston's Shadowood condominiums make new Va. case law, can't fine owners for rule violations" 1265:

Shadowood Condominium Association et al. v. Fairfax County Redevelopment and Housing Authority

1092:

The auditor conducts a profound analysis to establish relationships between the association's

3349:

The Rise of the Community Builders: The American Real Estate Industry and Urban Land Planning

1170:

have charged that, in a variety of ways, HOAs suppress the rights of their residents. Due to

1514: 3099:

Wiley GAAP 2020: Interpretation and Application of Generally Accepted Accounting Principles

2889: 2673: 1294: 1058: 891:

beyond racial discrimination and disallowed a challenge to an association's prohibition of

505: 8: 2927: 2822: 1014: 800: 796: 481: 468: 441: 362: 2923:"Water Bill Gets Caught in Wash Four Vetoes Expand List of Owens' Rejects to 28. (News)" 1752: 3418: 3375:"When the Developer Controls the Homeowner Association Board: The Benevolent Dictator?" 2434: 1917: 784: 621: 598: 490: 460: 433: 2858: 2606: 1688:"Home Owner Associations Growing in Power While with Little Oversight or Transparency" 872:

municipal governments and should therefore be subject to the same legal restrictions.

577:

HOA, the owner ceases to be a member of the HOA and loses all rights previously held.

3422: 3391: 3353: 3332: 3311: 3307:

Community Associations: The Emergence and Acceptance of a Quiet Innovation in Housing

3290: 3254: 3229: 3198: 3177: 3156: 3135: 3103: 3082: 3061: 3040: 3018: 2997: 2976: 2649: 2342: 1921: 1909: 1330: 919:

overturned the appellate court's decision in 2007 and reinstated the decision of the

846: 834: 448: 3385: 3326: 3305: 3150: 3033: 3012: 2941: 2458:"Homeowner Association Foreclosures and Property Values in Harris County, 1985–2001" 2062:

Proceedings of the 2009 Land Policy Conference: Municipal Revenues and Land Policies

1620: 952:

may have been his defense; however, a gag order prevents details from being known.

861:

Some of the restrictions commonly put into place by HOAs are limiting the length of

3414: 3221: 2582: 1901: 1579: 1142: 1093: 495: 392:

and HOAs. State oversight of HOAs varies from state to state; some states, such as

3225: 1198:, permit misdemeanor charges to be filed against a non-compliant board and permit 3173:

Privatopia: Homeowner Associations and the Rise of Residential Private Government

2948: 2773: 1869: 1383: 1378: 1358: 900: 548: 339: 1668: 2908: 2733: 1350: 1275: 1174: 1002: 789: 374: 370: 2552: 1905: 1695: 535:

In 1963, the FHA had approved federal home mortgage insurance exclusively for

3437: 3426: 3258: 3233: 1913: 1097: 1082:

is contacted to check whether the association is involved in any legal cases.

1026: 963: 945: 695: 444:. Since 1964, HOAs have become increasingly common in the United States. The 401: 321: 1422:"Title XL REAL AND PERSONAL PROPERTY, Chapter 720: HOMEOWNERS' ASSOCIATIONS" 1933: 1931: 1734: 1062: 385: 2110:"Litigation Involving The Developer, Homeowners Associations, and Lenders" 858:

droves, it will have little effect on the value of a board member's home.

2840: 2534: 1322: 1298: 1154: 1022: 920: 849:, the developer has the incentive to maximize the value of the property. 472: 437: 343: 329: 3286:

Common Interest Communities: Private Governments and the Public Interest

3242: 2993:

Common Interest Communities: Private Governments and the Public Interest

2972:

Common Interest Communities: Private Governments and the Public Interest

1928: 3194:

Federally Assisted New Communities: New Dimensions in Urban Development

2553:""Office of the Professions." NYS Public Accountancy - Initial License" 1178: 932: 911: 876: 819: 397: 361:

In the United States, the first HOAs were established in California by

351: 1716: 1017:

that states an opinion regarding the organization's financial health.

3289:. Institute of Governmental Studies Press, University of California. 2996:. Institute of Governmental Studies Press, University of California. 2975:. Institute of Governmental Studies Press, University of California. 2055:"Homeowners Associations and Their Impact on the Local Public Budget" 1951:

Natore A. Nahrstedt v. Lakeside Village Condominium Association, Inc.

1230:

Certain states are pushing for more checks and balances in HOAs. The

1005:. In the framework of such an inspection, an independent third-party 940: 641: 347: 334: 2304:

Committee for a Better Twin Rivers v. Twin Rivers Homeowners' Assoc.

1470: 207:. Statements consisting only of original research should be removed. 76: 1302: 960: 828:

Federally Assisted Communities: New Dimensions in Urban Development

823: 494:. However, private contracts effectively kept them alive until the 464: 2509:"Certified Hawaii fires CEO Floerke over condo association thefts" 1598:"How The Fair Housing Act Protects Homeowners From Discrimination" 2632:"Homeowners Association (HOA) Audit. Everything You Need to Know" 1804:"The Fiduciary Duties of An HOA: Know Your Rights As A Homeowner" 1290: 1199: 1101: 956: 892: 421: 414: 410: 393: 3387:

Private Neighborhoods and the Transformation of Local Government

2690: 2191: 459:

Some of the first HOAs were formed early in the 20th century in

3268:"The Legislature Addresses Problems in the Law of Condominiums" 2167: 1955: 1639: 1637: 1635: 1279: 1079: 1037:

The auditing process for HOAs can be divided into four stages:

597:

The covenants, conditions, and restrictions (CC&Rs) of the

325: 3031: 2229:"A Guide To Architectural Control In Homeowners' Associations" 1626: 1195: 1171: 998: 936: 862: 749:

a development that costs the municipality little or nothing.

1632: 978:

prescribed limit established in the association's by-laws.

950:

Federal laws protecting military personnel from civil action

822:

for the unit. They could, however, deal directly with their

3131:

West of Jim Crow: The Fight against California's Color Line

2841:"Federal Communications Commission (FCC) Information Sheet" 2783: 2781: 1369:

Comparison of homeowner associations and civic associations

1297:

from prohibiting "Florida-Friendly Landscaping," a type of

1167: 1822:"Guide to Community Association Management Certifications" 1735:"Civic Leaders – Or More Community Association Institute?" 1548: 332:, as well as some other countries. They are formed either 2420: 1970:"Pros and Cons of Living Within a Homeowners Association" 378: 3328:

The Voluntary City: Choice, Community, and Civil Society

3247:

Journal of the Illinois State Historical Society (1998-)

3152:

The Voluntary City: Choice, Community, and Civil Society

3123:. Office of Scientific and Technical Information (OSTI). 3014:

The Voluntary City: Choice, Community, and Civil Society

2778: 1784:. Educational Community for Homeowners. 12 November 2013 1560: 2859:"373.185 Local Florida-friendly landscaping ordinances" 2179: 2157: 2155: 2153: 2138: 1844: 2702: 1325:

are paid to a landowner, who decides how to spend it.

678:

built" housing) and to, ultimately, foreclose on it.

400:, have a large body of HOA law. Other states, such as 3211: 3120:

Arroyo Seco Improvement Program ( 2019 Annual Report)

2417:"Not So Neighborly Associations Foreclosing on Homes" 1995:"Benefits & Drawbacks of Homeowners Associations" 1937: 1828:. Educational Community of Homeowners. Archived from 1471:"Massachusetts HOA Laws, Regulations & Resources" 3078:

City of Quartz: Excavating the Future in Los Angeles

2752:"Chapter 47F – North Carolina Planned Community Act" 2714: 2482:"Hallandale arrests give teeth to other condo cases" 2150: 1649: 1526: 1524: 1487: 1340: 944:

informed that his fully paid-for, $ 300,000 home in

1608: 1536: 101:. Unsourced material may be challenged and removed. 974:linked with the above average home price growth." 547:In an effort to control water pollution, the U.S. 3010: 2989: 2968: 2696: 2563: 2211:"7 Ridiculous Homeowners Association (HOA) Rules" 2197: 2173: 2001:. Accord Property Management, LLC. Archived from 1669:"CAI Lawyers Slaughter Homeowner Protection Bill" 1521: 1414: 3435: 1395: 997:However, many HOAs introduce regular accounting 926: 388:, and are subject to state statutes that govern 27:Type of private association in the United States 1274:, HOAs could limit or prohibit installation of 883:In 2002, the 11th Circuit Court of Appeals, in 721:Nahrstedt v. Lakeside Village Condominium Assn. 604:The HOA's Articles of Incorporation and Bylaws. 1891: 1776: 1774: 1374:Davis–Stirling Common Interest Development Act 969:A self-published report by a professor at the 406:Davis–Stirling Common Interest Development Act 2851: 764: 463:. The Arroyo Seco Improvement Association in 248:The examples and perspective in this article 2835: 2833: 2108:Kennedy, E. Richard; de Haan, Ellen Hirsch. 2022: 2020: 508:. This technical bulletin was funded by the 2734:"Battle at Twin Rivers – AARP Amicus Brief" 2280:"When your neighbors become your overlords" 2064:. Lincoln Institute of Land Policy: 338–366 2029:"Homeowner associations: Devils or angels?" 1771: 64:Learn how and when to remove these messages 3449:Housing organizations in the United States 3265: 2787: 2410: 2408: 2296: 2107: 381:, and the value of land in the community. 3373:Ronald M. Sandgrund and Joseph F. Smith, 3148: 2830: 2026: 2017: 1685: 1643: 648: 304:Learn how and when to remove this message 286:Learn how and when to remove this message 223:Learn how and when to remove this message 161:Learn how and when to remove this message 3324: 3266:Rosenberry, Katherine N. (Winter 1985). 3169: 3039:. Washington, DC: Urban Land Institute. 2708: 2456:Adolph, Christopher (October 21, 2002). 2311: (July 26, 2007), archived from 2185: 2144: 1850: 1655: 1493: 1406:sfn error: no target: CITEREFCaves2004 ( 1011:Generally Accepted Accounting Principles 589:The HOA's governing documents generally 498:of 1968 prohibited such discrimination. 3404: 3303: 3240: 3116: 2674:"Code of Conduct for HOA Board Members" 2414: 2405: 2277: 1614: 1566: 743: 14: 3436: 3383: 3282: 3190: 3127: 2940:Jen Brooks, Cary (September 8, 2007). 2720: 2535:"AARP targets condo, homeowner boards" 2455: 2381:"New Jersey Supreme Court Case (7/07)" 2347:: CS1 maint: archived copy as title ( 2161: 2052: 1967: 1530: 1312: 488:ruled such covenants unenforceable in 3345: 3128:Hudson, Lynn M. (28 September 2020). 3095: 3074: 3053: 2806:. Virginia HOA and Business Law Blog. 2569: 1968:Lerner, Michele (December 23, 2013). 1887: 1885: 1554: 1542: 1507:"Industry Data – National Statistics" 1401: 661:requirements to claim certification. 615: 512:and by certain federal agencies: the 510:National Association of Home Builders 338:(such as in a building with multiple 3096:Flood, Joanne M. (5 February 2020). 2885:"Where Saving Water Bends the Rules" 2726: 2557:www.op.nysed.gov/prof/cpa/cpalic.htm 2527: 2506: 1604:. Homeowners Protection Bureau, LLC. 1232:North Carolina Planned Community Act 234: 172: 99:adding citations to reliable sources 70: 29: 2904:"Bill Embraces Landscaping Options" 2235:. Homeowners Protection Bureau, LLC 2027:Bannister, Paul (January 1, 2004). 1782:"Ethics Code for HOA Board Members" 1686:Hentschel, Nancy (August 4, 2010). 1254: 1206: 1166:Some scholars and officials of the 1032: 899:, the court ruled that outside the 518:United States Public Health Service 24: 3419:10.1111/j.1540-4560.1957.tb01387.x 3367: 3117:Holland, Robert (1 January 2020). 1882: 1241: 736:accordance with community values. 354:, and selling homes and lots in a 25: 3465: 3170:McKenzie, Evan (1 January 1994). 3075:Davis, Mike (17 September 2006). 2883:George, Justin (March 25, 2004). 2845:Federal Communications Commission 2515:. American City Business Journals 2084:"HOAs and Real Estate Developers" 1475:Homeowners Protection Bureau, LLC 880:comparable to courts and police. 713: 706:According to a 2019 study in the 428:(CIDs), a category that includes 45:This article has multiple issues. 3331:. University of Michigan Press. 3304:Stabile, Donald (30 June 2000). 3155:. University of Michigan Press. 3134:. University of Illinois Press. 3017:. University of Michigan Press. 2650:"Internal Audit - Audit Process" 2386:Community Associations Institute 1511:Community Associations Institute 1343: 446:Community Associations Institute 239: 177: 75: 34: 2934: 2915: 2902:Darst, Kevin (April 13, 2005). 2896: 2877: 2810: 2793: 2758: 2744: 2666: 2642: 2624: 2599: 2575: 2545: 2500: 2474: 2449: 2427: 2415:Goodwyn, Wade (June 29, 2010). 2373: 2355: 2271: 2247: 2221: 2203: 2101: 2076: 2046: 1987: 1961: 1943: 1856: 1814: 1796: 1745: 1727: 1709: 1679: 1661: 1590: 1572: 1319:multiple-tenant income property 1295:covenants and deed restrictions 852: 424:in the United States today are 86:needs additional citations for 53:or discuss these issues on the 2962: 2921:Bartels, Lynn (June 1, 2005). 2678:Community Associations Network 1580:"Racial Restrictive Covenants" 1499: 1463: 1447:"Common Interest Developments" 1439: 1317:An alternative to CIDs is the 1272:Telecommunications Act of 1996 777: 620:The HOA will be governed by a 13: 1: 3384:Nelson, Robert Henry (2005). 3226:10.1080/09599916.2020.1740765 3054:Caves, Roger W., ed. (2005). 2697:Barton & Silverman a 1994 2278:Stewart, Emily (2023-04-20). 2198:Boudreaux & Holcombe 2002 2174:Barton & Silverman b 1994 1389: 1364:Business improvement district 927:Financial risk for homeowners 807: 580: 346:developer for the purpose of 3214:Journal of Property Research 1757:Washington State Legislature 567: 530:Urban Renewal Administration 426:common-interest developments 420:The fastest-growing form of 18:Homeowners' association 7: 3380:, January 2002, p. 91. 1336: 1305:but was vetoed by governor 555: 486:United States Supreme Court 467:was founded around 1905 by 262:, discuss the issue on the 203:the claims made and adding 10: 3470: 2754:. North Carolina Statutes. 1894:Journal of Urban Economics 1451:leginfo.legislature.ca.gov 765:For real estate developers 708:Journal of Labor Economics 701: 454: 3454:Neighborhood associations 3444:Condominium organizations 3176:. Yale University Press. 3102:. John Wiley & Sons. 1906:10.1016/j.jue.2019.05.001 1261:Supreme Court of Virginia 812: 664: 430:planned unit developments 3407:Journal of Social Issues 3197:. Urban Land Institute. 3060:. Taylor & Francis. 3057:Encyclopedia of the City 1584:University of Washington 1161: 1001:to mitigate homeowners' 971:University of Washington 917:New Jersey Supreme Court 725:California Supreme Court 3346:Weiss, Marc A. (2002). 3310:. Bloomsbury Academic. 3241:Plotkin, Wendy (2001). 2953:The News & Observer 2587:www.merriam-webster.com 2435:"Texas Foreclosure Law" 2309: N.J. Supreme Court 1426:The Florida Legislature 526:Veterans Administration 522:Office of Civil Defense 390:non-profit corporations 356:residential subdivision 110:"Homeowner association" 3390:. The Urban Insitute. 2942:"Rigid Rules on Lawns" 1956:33 Cal. Rptr.2d 63 1875:Orange County Register 1863:"Educating Homeowners" 1557:, pp. 3–4, 11–12. 1293:, state law prohibits 1228: 1222: 1217: 1078:The HOA association's 762: 740:enforcement of rules. 733: 649:Association management 3191:Mields, Hugh (1973). 2607:"Contents of by-laws" 2583:"Definition of AUDIT" 2513:Pacific Business News 2437:. StopForeclosure.com 1629:, p. Title page. 1223: 1218: 1213: 1055:analytical procedures 887:, declined to extend 793:Independent Institute 758: 756:As the study noted, 729: 318:homeowner association 2890:St. Petersburg Times 2470:on October 27, 2007. 2393:on December 31, 2013 2117:Becker-Poliakoff.com 2053:Cheung, Ron (2009). 744:For the municipality 506:Urban Land Institute 442:housing cooperatives 268:create a new article 260:improve this article 250:may not represent a 95:improve this article 3378:The Colorado Lawyer 2928:Rocky Mountain News 2823:The Washington Post 2559:. January 30, 2020. 2330:on October 25, 2007 1940:, pp. 238–253. 1938:Goodwin et al. 2020 1832:on January 25, 2015 1646:, pp. 373–374. 1313:Alternative to CIDs 1181:—although they are 955:Other states, like 801:Randall G. Holcombe 797:Donald J. Boudreaux 788:, published by the 591:"run with the land" 482:Seattle, Washington 434:single-family homes 2947:2009-05-19 at the 2865:. State of Florida 2863:The Florida Senate 2772:2010-02-03 at the 2766:Davis Stirling Act 2259:www.britannica.com 2255:"Britannica Money" 2005:on January 2, 2021 1868:2009-01-16 at the 1759:. Washington State 1263:ruled in the case 1259:In June 2012, the 1027:good rule of thumb 1025:is deemed to be a 840:In some HOAs, the 835:absentee landlords 785:The Voluntary City 622:board of directors 616:Board of directors 491:Shelley v. Kraemer 461:Los Angeles County 188:possibly contains 3397:978-0-87766-751-3 3359:978-1-58798-152-4 3338:978-0-472-08837-9 3317:978-0-313-31571-8 3296:978-0-87772-359-2 3204:978-0-608-11924-3 3183:978-0-300-06638-8 3162:978-0-472-08837-9 3141:978-0-252-05222-4 3109:978-1-119-65262-5 3088:978-1-78168-430-6 3067:978-0-415-25225-6 3046:978-0-87420-050-8 3024:978-0-472-08837-9 3003:978-0-87772-359-2 2982:978-0-87772-359-2 1879:12 November 2006. 1627:Hanke et al. 1970 1569:, pp. 39–69. 1331:residual claimant 847:residual claimant 640:directors have a 449:trade association 340:owner-occupancies 314: 313: 306: 296: 295: 288: 270:, as appropriate. 233: 232: 225: 190:original research 171: 170: 163: 145: 68: 16:(Redirected from 3461: 3430: 3401: 3363: 3342: 3321: 3300: 3279: 3262: 3237: 3208: 3187: 3166: 3145: 3124: 3113: 3092: 3071: 3050: 3028: 3007: 2986: 2957: 2938: 2932: 2919: 2913: 2900: 2894: 2881: 2875: 2874: 2872: 2870: 2855: 2849: 2848: 2837: 2828: 2827: 2814: 2808: 2807: 2805: 2797: 2791: 2785: 2776: 2762: 2756: 2755: 2748: 2742: 2741: 2730: 2724: 2718: 2712: 2706: 2700: 2694: 2688: 2687: 2685: 2684: 2670: 2664: 2663: 2661: 2660: 2654:www.cfo.pitt.edu 2646: 2640: 2639: 2628: 2622: 2621: 2619: 2618: 2603: 2597: 2596: 2594: 2593: 2579: 2573: 2567: 2561: 2560: 2549: 2543: 2542: 2531: 2525: 2524: 2522: 2520: 2504: 2498: 2497: 2495: 2493: 2478: 2472: 2471: 2469: 2463:. 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