What a board can do with this

The rule creates duties for the licensee, not for the association — but it describes exactly the paper trail an association is entitled to expect, and that makes it a checklist:

• Ask where the money is. An insured Montana financial institution, in an account identified as a trust account. Not a sweep product. Not a CD. Not anything that “places funds at risk.” A management company that has been earning yield on association reserves in an instrument the rule prohibits is a conversation to have now.
• Ask for the monthly reconciliation. The rule requires reconciliation each month having activity. A reconciliation that exists is a reconciliation you can ask for.
• Ask for the running balance. The record has to be chronological, identify every party and amount, and be kept “to facilitate auditing.” That is the document an association needs when it changes managers — and the moment a gap becomes visible.
• Check the deposit lag. Three business days. An association whose assessment receipts appear in the trust account a fortnight after members paid them has a question to ask.

Time the review to the agreement. A management agreement signed or renewed after February 21, 2026 should be read against ARM 24.210.427, not the repealed 24.210.426. Any agreement or policy that cites the old rule number by reference is citing a rule that no longer exists.

The limits, stated honestly

Two, and they matter.

The rule text says “Brokers” throughout. Montana property managers are licensed by this same board and § 37-1-319 is the shared trust-account statute, but the rule as adopted does not use the words “property manager,” “community association” or “HOA” anywhere. Its application to association funds held by a licensed manager is an inference from the licensing scheme, not something the rule states. That is a real qualification, not a hedge.

It governs the licensee's handling of money, not the association's own bank accounts. A self-managed board holding its own reserves is outside it entirely, and the rule creates no association audit right by itself.

The two other rules in the same package

• New Rule 1, ARM 24.210.612, SUBSTANTIAL EQUIVALENCY — implements House Bill 246 of 2025 (signed April 3, 2025, effective October 1, 2025), incorporating the board's approved list of states with substantially equivalent licensing standards, published on the board's website and reviewed annually.
• New Rule 3, ARM 24.210.607, SALESPERSON SUPERVISION — replaces the repealed ARM 24.210.601. On termination of supervision the salesperson must notify the board of a new supervising broker or go inactive, within ten days of board notice where the broker terminated; the supervising broker must act within five calendar days. Comments asked the board to require the supervising broker's signature on listing and buyer-representation agreements — commenters noted 37 other states do not require it — and the board adopted as proposed, saying it may revisit.

ARM 24.210.420 on applicants with criminal convictions was also amended as proposed, treating first-offence nonviolent misdemeanour DUI convictions as routine.

The bigger gap this rule sits inside

Montana has no licensing category for a community association manager. Nothing in the state's rules creates or regulates the role as such; the closest reach is this trust-account scheme, and it gets there through the broker and rental-property-manager licence rather than through anything HOA-specific.³

Whether that should change is under interim study — House Joint Resolution 55, on property management licensing, which we cover separately. The short version is that Montana's licence is built around rental property management, and whether community-association management falls inside it is the live question the study was meant to answer.²