The line that actually matters: rents versus assessments

The absence of a CAM licence does not mean a manager is outside licensing law altogether. RSA 331-A:2 sweeps in anyone who "collects, offers, attempts or agrees to collect rent for the use of real estate."

So the operative distinction for a New Hampshire association is what the manager collects:

Assessments only — common charges, special assessments, late fees, fines — and the manager is outside broker licensing. That is the ordinary community-management arrangement and it requires no credential of any kind.

Rents — collecting from tenants on behalf of unit owners who lease their units — and the manager may be inside broker licensing, because collecting rent for the use of real estate is a licensed activity on the face of the statute.

A great many New Hampshire management companies do both, particularly in the lake and ski regions where a single firm runs the association and also handles owners' rental programmes. Whether that firm holds a broker licence is a question a board can answer in a minute by checking the Commission's licensee lookup, and it is worth answering before signing.

What the gap means when things go wrong

This is the part boards discover at the worst time. If an unlicensed community manager misapplies association funds, there is no licensing board to complain to, no disciplinary process, no bond or recovery fund, and no professional-conduct standard to measure the conduct against. The remedies are the ordinary ones: the management contract, a civil action, and — if the conduct fits an unfair or deceptive practice — a consumer complaint to the Attorney General under RSA 358-A, which the Attorney General is not obliged to take up.

Where the manager is a licensed broker, there is a route: Rea 204, the Commission's complaint procedure, as replaced in the March 2025 rewrite. But it reaches the licensed conduct, not everything the firm does.

What a board can put in the contract

Because the state supplies no floor, the contract is the floor. The provisions that do the work are unglamorous: which bank accounts association funds sit in and in whose name; whether the manager may sign cheques alone and above what amount; monthly reporting with bank statements attached rather than summaries; fidelity bond or crime coverage naming the association, at a limit tied to the funds actually held; a right to audit; and a termination clause that returns records in a usable form within a stated number of days.

Records retention deserves particular attention in New Hampshire, because the manager typically holds what the association is obliged to keep. A management transition that loses the minute book and the financial history takes with it the association's ability to answer a lender questionnaire, defend a lien, or establish when a covenant was last enforced.

What to watch next

No bill creating a manager credential is on New Hampshire's 2027 legislative service request list as filed. If pressure for one emerges, the likeliest vehicle is the Condominium Act review that the 2026 session put in motion rather than a standalone licensing bill.

Watch, too, whether the Commission's 2025 rewrite of Rea 200 changes how complaints against dual-role firms are handled in practice. The rules of practice are new; how the Commission applies them to a broker who is also managing an association is not yet on the record.