The Real Estate Commission: no manager rule, and a seam

Georgia is one of the minority of states that licenses community association managers, through the Georgia Real Estate Commission under O.C.G.A. Chapter 43-40. In a biennium in which the legislature built an entire new regulatory chapter over associations, GREC made no manager-specific rule change at all.

GREC's legislation page lists exactly two adopted rules for the period, both broker continuing education and both effective 1 July 2025: Rule 520-1-.05(1)(f) and Rule 520-2-.04(6)(g). The “Proposed” and “Pending” sections are empty.³

On discipline, GREC publishes two rolling PDFs — current suspensions and current revocations — with no date-stamped case list and no manager filter. We could not retrieve either document, so whether GREC has disciplined any community-association manager in 2025-2026 is unverified, and the agency does not publish it in a form that would let anyone answer the question without an open-records request.

That produces a genuine regulatory seam, and it is worth stating precisely.

Georgia's new Chapter 43-17A regulates the association, not the manager. It contains no manager licensing provision, no manager registration and no coordination clause with GREC. But it reaches management companies incidentally in two places: § 43-17A-2(g) provides that “[t]he property owners' association or property management company shall notify the Secretary of State of the address of the office at which such records are kept,” and § 43-17A-2(a)(2)(A) bars an association “or its agent” from collecting fines or fees when unregistered.⁴

So from January a licensed Georgia manager will be executing a state registration regime enforced against their client by an agency that does not license them, while their own licensing agency has issued no guidance about it.

What the silence means in practice

Three consequences for Georgia associations, in descending order of immediacy.

There is no interpretive backstop for Chapter 17A. When the Secretary of State begins construing the new chapter in 2027 — deciding, for instance, what the “nonregistered owners' association” election in § 43-17A-2(a)(2)(B) actually forfeits, or whether the records right in § 43-17A-7(1) overrides a contrary declaration — there is no Georgia Attorney General opinion of any vintage to build on. Georgia is starting from a blank page on a statute that switches on in under four months.

Insurance guidance is coming from Washington, not Atlanta. The two forces actually reshaping Georgia condominium insurance in this period are Fannie Mae and Freddie Mac, whose aligned March 2026 rules cap the per-unit master-policy deductible at $50,000 from 1 July 2026 and raise minimum reserves to 15% from 4 January 2027. Those are private secondary-market underwriters. Georgia's own elected insurance regulator has said nothing.

Meanwhile the state legislature declined to act on the one insurance measure before it: SB 230, which would have lifted the $5,000 cap on the deductible a Georgia condominium may charge one unit owner under O.C.G.A. § 44-3-107, passed the Senate and died without a House vote.

Nobody is telling volunteer boards what to do. Georgia is imposing a registration, a ten-year records duty, a mandatory payment-application order and a prohibition on accelerating assessments — on unpaid volunteers, with no training requirement (SB 393 was tabled on Crossover Day), no agency guidance, and no rules yet proposed.

What would change this

One request. From 1 January 2027, the Secretary of State is the head of an executive department with jurisdiction over community associations, and can therefore ask the Attorney General for an Official Opinion.

The first such request would produce Georgia's first authoritative statement on any community-association question, ever. It is the single most useful thing that could happen to Georgia association law in 2027, and it costs nothing.

What to watch next

Three specific things, each cheap to check and each currently absent: a notice of proposed rulemaking from the Secretary of State under Chapter 43-17A; the first Official Opinion request from that office; and any property-lines bulletin from the Office of Insurance and Safety Fire Commissioner. Commissioner John King faces election on 3 November 2026, which makes the silence on condominium insurance a fair question to put to both candidates.