Connecticut managers must now disclose vendor interests and what construction oversight costs
Connecticut managers must now disclose vendor interests and what construction oversight costs
2026-09-09 · Connecticut · Compliance
A Connecticut community association manager signing a management contract must now disclose, clearly and in writing, whether they hold an interest in any business that sells to the association — and what they will charge for construction oversight that falls outside the contract. The duty is § 20-457(g), added by Public Act 25-111, effective October 1, 2025.1
The same act also narrowed the exemption that let some paid professionals manage associations without registering at all.
The disclosure duty, in full
“Each community association manager who enters into a contract with an association for the purpose of providing association management services shall disclose to the association:
(A) Whether the community association manager has any ownership or managerial interest in any entity that solicits business from the association or the community association manager; and
(B) If the community association manager is required to provide any construction oversight or project coordination services to the association that are not included in the scope of the general association management services… any amount the community association manager will charge to provide such construction oversight or project coordination services.”1
And the form requirement: “Each disclosure made pursuant to this subsection shall be clear, conspicuous and in writing.”
Both limbs answer a real complaint
The first reaches vendor self-dealing — the manager who also has an interest in the landscaping, roofing or restoration company bidding for the association's work. Note it runs both ways: an interest in an entity soliciting business from the association or from the manager.
The second reaches the charge that appears after a capital project is underway. Construction oversight is often outside the base management fee, and the act requires the number to be on the table when the contract is signed rather than when the invoice arrives.
Connecticut's Department of Consumer Protection names both problems in its own March 2026 guidance on the most common complaints it receives about associations: undisclosed conflicts of interest and self-dealing with vendors, and managers overstepping their authority.3
Who no longer escapes registration
Section 11 rewrote the definitions in § 20-450 and Section 12 rewrote the exemptions in § 20-452. The result is a tighter list.
The professional exemption now reads as covering “[a]ny person, including, but not limited to, any attorney admitted to practice law in this state, any certified public accountant licensed under chapter 389 or any insurance producer licensed under chapter 701a, who provides to an association professional services, for which such person is licensed or admitted, for remuneration.”1
The operative words are “for which such person is licensed or admitted.” The former language exempted any licensed person providing the services for which they were licensed; the rewrite ties the exemption to professional services within the licence. A licensed professional who is in substance running the association — controlling funds, preparing budgets, supervising operations — is not providing services for which they are licensed, and is not exempt.
Two other exemptions were clarified. A director, officer or member managing their own association remains exempt “unless such director, officer or other member owns or controls more than two-thirds but less than all of the votes in such association.” And a new third category confirms that administrative support staff working for a registered manager need not register in their own right.
The enforcement teeth, and what got removed
Section 13 also made a change worth noticing. The penalty provision in § 20-457(b) previously applied “after an administrative hearing” — and that phrase was struck.1
What remains is a fine of not more than one thousand dollars, imprisonment for not more than one year, or both, for offences including offering to provide association management services without a current certificate. And a provision that already existed but is easy to underestimate:
“A violation of any of the provisions of sections 20-450 to 20-462, inclusive… shall be deemed an unfair or deceptive trade practice under subsection (a) of section 42-110b.”
That is CUTPA. A registration or disclosure failure is not merely a licensing matter — it is a statutory unfair trade practice, with the private right of action and remedies that carries.
What this means for a board
Ask for the disclosure at renewal, not just at signing. The duty attaches to entering into a contract. Associations renewing an existing arrangement should be requesting the written disclosure as part of that process.
Get the construction oversight number before the project, not during it. The disclosure is required where oversight services are outside the scope of the management contract. The practical question for a board is which of the two it is — and that is a question about the contract's scope language, which the board controls.
Check registration. Registration is through the Department of Consumer Protection, certificates expire annually on January 31, initial application is sixty dollars plus a one-hundred-dollar registration fee, and renewal is two hundred dollars. A manager must exhibit the certificate on request by any interested party and include the registration number in advertising.1
Understand the trainee category's hard limit. A trainee certificate expires six months from issuance and is not renewable.
The gap this does not close
DCP credentials managers. It does not credential boards, and its Real Estate Unit does not hold hearings on condominium complaints.4 So the disclosure duty is enforceable against the paid professional through a regulator and through CUTPA, while an equivalent conflict on the volunteer board side has no administrative route at all.
That asymmetry is what House Bill 5433 would have addressed in the 2026 session by capping gifts to board members and barring managing agents and vendors from campaigning in association elections. It died in the Judiciary Committee without a vote.5
What to watch next
No published DCP disciplinary action against a Connecticut community association manager surfaced for 2025 or 2026. The disclosure duty is a year old, and its first real test will be a complaint that turns on it.
The other thing to watch is scope drafting. Where a management contract defines “general association management services” broadly enough to swallow construction oversight, limb (B) of the disclosure never engages — which is a drafting response available to managers and worth boards reading for.
Related Connecticut HOA Topics
- Public Act No. 25-111 (Substitute Senate Bill No. 1357), §§ 11-13 — amending Conn. Gen. Stat. §§ 20-450, 20-452 and 20-457 ↩
- 2025 Acts Affecting Housing and Real Estate, OLR Report 2025-R-0113 (July 31, 2025) ↩
- Most Common Homeowners Association (HOA) Complaints, Connecticut Department of Consumer Protection (March 11, 2026) ↩
- Community Association Manager registration, Connecticut Department of Consumer Protection ↩
- HB 5433 (2026), limitations on gifts to executive board members — died in committee ↩
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