The proposed regulations are reasonable for large HOAs, most of which have professional staff (either in-house or via professional management companies).  However, for small associations, the regulations are an undue burden.  The HOA of which I am president has 11 members (and there are smaller HOAs in our area).  We have no professional or legal staff, no standing committees (other then the Board of Directors), no shared assets, and minimal architectural controls (which is likely the cause of most issues such as those contemplated by this regulation). 

Establishing and maintaining a process such as described in this regulation would require substantial effort and expense - probably doubling our annual expenses.  The additional burden would likely cause us to disolve the association.

I suggest that the regulations be modified to exempt small HOAs - perhaps those smaller than 25 homes.