Wednesday, July 2, 2014

Management Co. of HOA incorrectly citing ORS to justify monetary fees...

RE: Request to examine the HOA's financial records, receipts, and other association documents under ORS 94.670(9)(a)

Dear Fellow Homeowners:

Approximately 8 days ago I made a formal written request to examine the financial records, receipts and all other records of the association, here is the response I got:


Here is my response via email this afternoon:


Angela,

 
Thank you for your letter providing the days and times being made available for my visit to “review,” however, you are  (or some attorney from Vial Fotheringham is advising you) incorrectly citing ORS 65.774 and 65.771 as a justification for charging me $110 per hour for “prep and oversight of the review.”

 
First off, the Homeowners Association and the Association board of directors are only subject to the following subsections of ORS Chapter 65:

 
Per ORS 94.640: “In the performance of their duties, officers and members of the board of directors are governed by this section and the applicable provisions of ORS 65.357, 65.361, 65.367, 65.369 and 65.377…”

(i.e. standards, conflict of interest, liability, etc.)
 

Per ORS 94.626(2): “A separate association is not created when an association is reinstated after administrative dissolution under ORS 65.654 or again incorporated following dissolution. The association automatically continues without any further action by incorporators, directors or officers that may otherwise be required under ORS chapter 65.” (i.e. dissolution)
 

Per ORS 94..670(1): “A homeowners association shall retain within this state the documents, information and records delivered to the association under ORS 94.616 and all other records of the association for not less than the period specified for the record in ORS 65.771 or any other applicable law…” (i.e. records retention)
 

Second, ORS 65.774 and 65.771 do not apply to a Homeowners Association as homeowners are not a “member” of the non-profit corporation. As defined under 65.001 Definitions. As used in this chapter: 

(26)(a) “Member” means a person that is entitled, under a domestic or foreign corporation’s articles or bylaws, without regard to what the person is called in the articles or bylaws, to vote on more than one occasion to elect a director or directors.

 
Under the Bylaws of Oak Knoll Homeowners’ Association, Article 1 Plan of Ownership, Membership is defined, in part, as follows:
 
(6) Membership: “Every person or entity who is a record owner of a fee or undivided fee interest in any Lot shall be a proprietary member of the Association…Associate membership shall carry all the rights and privileges and shall be subject to all obligations and responsibilities of proprietary membership, except the right to vote.”
 
[Emphasis mine]

Therefore, neither ORS 65.774  or 65.771 are applicable to my request for “examination” of the associations records. As such, you have no right to charge me for any examination of the association records.
 
Again, under ORS 94.670 Association duty to keep documents and records; deposit of assessments; payment of association expenses; review of financial statement by certified public accountant; examination of records by owner…
 
(9)(a) Except as provided in paragraph (b) of this subsection, the association shall make the documents, information and records described in subsections (1) and (4) of this section and all other records of the association reasonably available for examination and, upon written request, available for duplication by an owner and any mortgagee of a lot that makes the request in good faith for a proper purpose.

Third, your citing Article VI Records and Audit is inaccurate, and I admit I incorrectly used it as well given the fact that (A) I am not a CPA, therefore I cannot “audit or inspect” the books and records of the association under the common law definition of an audit or inspection as clearly meant given the context in which that phrase was used not once, but twice in that Article. It is clear upon second reading that “audit or inspect” juxtaposed to the reference “at the expense of” either the Association or the member requesting it means a financial audit by a CPA. Therefore you have no basis to charge me a fee for the “examination” of the association records.

In addition to ORS 94.670 there is Subsection (12) which states the following:

(12) The board of directors, by resolution, may adopt reasonable rules governing the frequency, time, location, notice and manner of examination and duplication of association records and the imposition of a reasonable fee for furnishing copies of any documents, information or records described in this section. The fee may include reasonable personnel costs for furnishing the documents, information or records.

To date the Board of Directors has not voted a resolution to accomplish the above, as such, again, neither the Board of Directors OR by its managing agent, Superior Community Management, has any right to assess monetary fees for my legal right under ORS 94.670(9)(a) for the examination of the Association documents requested to be examined.

Unless you can produce this unseen, unpublished and unfiled (with the County Clerk) resolution to the CC&Rs, neither you (Super Community Management) or the Homeowners Association (Board of Directors) have any legal basis to assess any fees for my “examination” of the association records.

When I choose the date and time given and establish that appointment, the Association via Superior Community Management shall make the documents, information and records described in subsections (1) and (4) of this section and all other records of the association reasonably available for examination and, upon written request, available for duplication by an owner and any mortgagee of a lot that makes the request in good faith for a proper purpose.

I will be in touch on which date and time is to be selected once I review my work scheduled and make arrangements for said date and time.


Very Truly Yours

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