I recently interviewed with an association for professional management services, this association has been self-managed for years and with that (not due to negligence) but just not being aware have never established a complaint process nor was aware that it was actually mandated and required by the CIC.  There should be some allowances for these types of situations, maybe the board should require that proof be provided of the established policy at the time of renewal, and if one has not been established then allow a certain period of time (30 days) that a policy must be established.