What people actually complain about

The Center coded 2025 complaints into twenty-four categories. The top of the list, with counts:

Communication with homeowners or the board — 225. Not performing maintenance, repairs or construction defects — 133. Excessive assessments, fees or fines, collections and foreclosure — 117. Accounting and finances — 100. Harassment, retaliation or intimidation — 86. Improper or selective enforcement of covenants — 82. Not following governing documents — 74. Health, safety and security — 71. Failure to produce records — 67. Meetings — 58. Regulatory compliance and registration — 52. Elections and voting — 51. Diversion, theft, fraud or misappropriation — 37. Discrimination — 28. Conflicts of interest — 28. Xeriscaping and landscaping — 23. Insurance — 19. Reserves — 17. Parking — 16.

Two structural facts sit alongside those counts. 76% of complaint categories were lodged against the board, 24% against a specific manager or management company. And 51 complainants (14%) filed anonymously — the report ties that to “concerns about retaliation.”

Separately from complaints, the Center fielded 3,791 inquiries, roughly flat since 2020. The top identifiable inquiry topic, again, was records requests under C.R.S. 38-33.3-317 — 111 of them. “File a Complaint” was third largest.

The regulator's own list of what is broken

Section 7 of the report is headed “Possible Statutory Gaps,” and it is the most useful page in the document because it is a preview of what gets introduced next session.

C.R.S. 38-33.3-209.5 — the resetting cure period. The thirty-day cure window restarts every time an owner briefly cures, which the Center says produces “enforcement fatigue”: “the offending unit owner simply moves their vehicle back to the original spot, thereby once again in violation.”

C.R.S. 38-33.3-317(2)(l) against (3)(b) — undefined contract terms. “Current written contracts” must be produced but contracts “currently in or under negotiation” may be withheld, and neither term is defined.

C.R.S. 38-33.3-317(2)(h) — boards routing all owner contact through managers or counsel instead of giving board and officer information.

C.R.S. 38-33.3-303 — no mid-year budget amendment procedure. There is no clear statutory route to amend an adopted budget mid-cycle, which is what a mid-year assessment increase or a special assessment requires. “The implied procedure is to undergo the budget process again and call a Special Meeting … however, in practice, this commonly does not take place.”

C.R.S. 38-33.3-116 — the $400 limited-expense threshold is still indexed to the retired “Denver-Boulder consolidated metropolitan statistical area” CPI, which the Bureau of Labor Statistics replaced with “Denver-Aurora-Lakewood” in January 2018.

What this means for a board

Communication is the recurring finding, and it is a governance problem the state has now documented six times. With 225 complaints in that category and 76% of complaints aimed at boards rather than managers, the pattern is not a manager problem an association can outsource.

Records requests are what people call the state about. 111 inquiries and 67 complaints on failure to produce. An association whose records policy is current, and whose seven-business-day and other statutory clocks are actually diarised, removes itself from the largest single source of contact with the regulator.

And the regulator cannot help either side. This bears repeating because owners routinely assume otherwise: the HOA Information and Resource Center registers, educates and reports. It has no enforcement jurisdiction over an association, and the Division states plainly that it does “not have any jurisdiction to enforce the registration requirement.” The only lever CCIOA attaches is in C.R.S. 38-33.3-401(3), which suspends an unregistered association's right to impose or enforce an assessment lien until it is validly registered. The Center adds that it “presumes that there are a significant number of HOAs that do not comply with the registration process.”

Two footnotes on using the report

The document contains at least two internal artifacts worth avoiding. Figures 6.7.1 and 6.8.1 are captioned “2022” in a 2025 report, and one registration total appears as both 11,733 and 11,773 in the management-type discussion. The clean figures are 11,767 total, 8,615 active, 3,152 expired.

On the institutional side, the office is secure for now: SB25-184, signed May 24, 2025, continued the Center for five years with no substantive change to its powers, repealing it September 1, 2030 unless the legislature acts. The state's regulatory-review office has the Center scheduled for its next sunset review in the 2029 cycle.