Research · Forty Years, No Measurement (2 of 6)
The Only Experiment America Ever Ran: Colorado, 2015–2019
For four years, one state licensed community association managers, collected complaints against them, and wrote the numbers down. Then the program ended, and the record of what happened afterward was destroyed on an ordinary filing schedule. The experiment ran. Neither end was instrumented.
Why Colorado Matters More Than Any Other State
Eight states license community association managers today. Comparing them to the other forty-two is confounded by everything that makes states different from one another — size, market maturity, housing stock, statutory framework, enforcement culture.
Colorado is the only state that has been both. It licensed managers, then stopped, which means the cleanest available comparison is Colorado against itself.
That is as close to a controlled trial as this industry has ever come, and the story of what the state did and did not measure is the most useful document in the field.
The Program
House Bill 13-1277, enacted in 2013, made it unlawful as of July 1, 2015 to engage in the business of community association management without a license. The scheme included an examination, insurance requirements, standards of conduct, and a regulator — the Division of Real Estate, within the Department of Regulatory Agencies.
By fiscal year 2016–17 the state had licensed 1,413 managers, 70 apprentices, and 471 management companies.
For the first time anywhere in the country, the field had a complaint window with a government office writing things down.
What the State Actually Measured
The 2017 sunset review, dated October 13, 2017, reports two fiscal years of data. This is the only real mid-stream measurement in the industry's history, so it is worth stating precisely.
- Complaints against individual managers: 146, then 129.
- Complaints against management companies: 142, then 132.
- Complaints for "demonstrating unworthiness or incompetency" — the statute's own category — rose from 10 to 37 against individuals, and ran at 73 in both years against companies, holding steady even as unlicensed-activity complaints fell away.
- Discipline: 7 actions in year one, 31 in year two.
- Revocations on record were theft or criminal-conviction cases.
- All cease-and-desist orders addressed unlicensed activity.
- Fines in year two totaled $5,750 statewide.
- The Division's audit authority was never once used.
That last line deserves a moment. The regulator was granted the power to examine the books of the people holding association money, and in four years of operation it never exercised it.
The Regulator's Own Verdict on Its Own Data
The sunset review is unusually candid, and its assessment is the single most important passage in this entire body of research:
"The licensing program has only been in place for a few years, so there is little data to rely on in determining how much harm related to management activities exists. In fact, the majority of enforcement actions have been related to unlicensed activity, which is not, in and of itself, a compelling reason to regulate an occupation or industry."
Read that carefully, because it is easy to misuse in both directions.
The regulator did not find that licensing failed. It found that not enough time had passed to tell, and that most of what the program had caught so far was people practicing without a license — which proves the license exists, not that the license helps.
Its recommendation was the scientific one: continue the program five more years, to 2023, and let the data mature.
What Happened Instead
The continuation bill, HB 18-1175, was postponed indefinitely in Senate Finance in April 2018. The repeal took effect on schedule and the program wound up on June 30, 2019.
The following year the legislature voted licensing back. HB 19-1212 passed both chambers. The governor vetoed it on May 31, 2019 — per the Department's own report, "because the bill, among other things, did not include the recommendations in the 2017 CAM sunset review."
A 2021 state sunrise review recommended regulating managers again. The resulting bill, HB 22-1239, was postponed indefinitely in 2022.
No Colorado license exists today.
The Four-Year Totals
The Division's closing report is the only full accounting ever published of a licensing program in this industry, start to finish. From July 1, 2015 through June 30, 2019:
- 1,041 complaints — 630 against managers, 411 against companies.
- 89% dismissed with no action.
- 77 diversionary resolutions.
- 18 formal disciplines.
An exit survey of more than 70,000 stakeholders found more than 75% of respondents agreeing that the public could benefit from the regulation — including 69% of the licensed managers themselves.
That figure is worth sitting with. The people carrying the license, who paid for it and sat the exam and bore its costs, said by a wide margin that the public benefited from it. That is not what an industry protecting itself from regulation sounds like.
The Shredder
Here is where the story stops being a policy history and becomes a lesson about record-keeping.
When the 2021 sunrise team asked the Division for post-sunset complaint data — the "after" of the natural experiment, the second half of the only controlled comparison this field will ever get for free — the answer, verbatim from the sunrise review, was:
"Division staff stated that per their record retention policy, they destroy all of the complaints received in February each year. Therefore, Division staff were unable to provide any complaint information related to CAMs."
The same review notes that the application before it "contained the same examples of harm that were included in the 2011 sunrise application" — decade-old anecdotes, recycled, because nothing newer survived on file.
Nobody did anything wrong. A retention policy is an ordinary administrative instrument, adopted for ordinary reasons, applied uniformly. It was not aimed at this question and nobody at the Division was thinking about the industry's forty-year evidentiary gap when they wrote it.
That is exactly the point. The data was not suppressed. It was not valued by anyone in a position to save it, because nobody had told the filing clerk that the second half of the only experiment in American history was sitting in the cabinet.
What Colorado Proves, and What It Does Not
The summary is uncomfortable in both directions, and any honest account has to carry both halves.
Nothing in the Colorado record proves licensing worked. Two years of complaint tables and eighteen disciplines cannot carry that weight, and the program's own reviewer said so plainly.
Nothing in the Colorado record proves licensing failed. The program was never evaluated and never defeated on the merits. It died of a committee calendar. Its revival died of a veto pen. And its data died of a filing-cabinet policy.
The only experiment ever run was, at both ends, uninstrumented.
The Lesson That Transfers
Colorado's real contribution to this field is not an answer about licensing. It is a warning about timing.
Evaluation windows close fast, and they close quietly. The moment a jurisdiction enacts or repeals a competence requirement, it creates cohorts — people trained and untrained, periods regulated and unregulated — and those cohorts are only comparable while the records exist. Nobody announces the day the records stop existing.
Which is why the most urgent item on this field's research agenda is not a study of the past. It is instrumenting the present, in the one state that currently has a mandate running, before that state's baseline evaporates the same way Colorado's did.
That is Part 6 of this series, and it is the part with a deadline on it.
Related CIC-SC Resources
- Governance Standard EDU-001 — Manager Competence Measurement
- The Industry Asked to Be Regulated — and the Legislatures Said No (Part 1)
- The Bill That Passed Both Houses and Died of Silence (Part 3)
- Florida Mandated the Education — and Nobody Is Measuring It (Part 6)
A Note on Sources
Figures and quotations in this article are drawn from Colorado's 2017 sunset review, its 2021 sunrise review, the Division of Real Estate's closing program report, and the legislative histories of HB 13-1277, HB 18-1175, HB 19-1212, and HB 22-1239, as retrieved and cited in the working paper Forty Years, No Measurement. Readers relying on any statute or regulatory record for any purpose should consult the current text directly and take its application from counsel.
CICSC provides educational resources and governance standards. CICSC does not provide legal, accounting, tax, engineering, insurance, or reserve study services. Boards should consult qualified professionals for matters requiring professional judgment.