← BLOG

Connecticut required community association manager registration in 1991. New York still doesn't.

Connecticut built a credentialing system for condo and co-op managers across thirty-five years. New York has never started. Companion to S.71 and the managing-agent licensure gap.

Connecticut General Assembly Public Act 90-306, effective July 1, 1991, required every community association manager in the state to register with the Department of Consumer Protection. The statute — now codified as Chapter 400b of the Connecticut General Statutes, Sections 20-450 through 20-462 — predates the Virginia licensing law by seventeen years, Nevada's certification requirement by fourteen years, and Illinois's licensing act by nineteen years. New York has no equivalent. Senate Bill S.71, the managing-agent registration bill sponsored by Sen. Brian Kavanagh, did not receive a committee hearing in the session that ended June 18, 2026: the tenth consecutive session in which it did not advance.

What Connecticut enacted in 1991.

Public Act 90-306 was minimal by design. It required any person providing management services to a common-interest community in Connecticut to register with the Department of Consumer Protection, disclose a business name and address, and maintain a fidelity bond. The registration fee was set at $100. Annual renewal ran by January 31 each year. The DCP published the registry, which meant that a board or a prospective buyer could look up whether their manager was on record before signing a contract.

The fidelity bond requirement was the provision with real teeth. If a manager misappropriated reserve funds, there was an insurance backstop behind the loss. That backstop does not appear anywhere in New York law. A cleanup act in the following session, P.A. 91-341, adjusted the fee structure and required the Department to refund the registration fee if it refused to issue a certificate.

Connecticut's position in 1991 was that a census of practitioners, combined with a bond and a public record, was a minimum floor. The state did not attempt to set educational requirements or require an examination at that stage. It started with the question: who is practicing, and is there insurance if they steal? Those two questions alone put Connecticut ahead of every standard New York applies today.

The 2012 overhaul added an examination requirement.

The 1991 registration scheme told owners who was practicing. It did not tell them whether that person had cleared any competency threshold. Connecticut addressed that gap in 2012. Effective October 1, 2012, any manager who received an initial registration after that date was required to pass a written examination before the DCP would issue a certificate. The statute designated the Community Association Managers International Certification Board's CMCA exam as an approved test. The Community Associations Institute's M-100 course, "The Essentials of Community Association Management," satisfies the required pre-exam education.

The result is a two-track system still in effect today. Managers who received their initial registration before October 1, 2012, and have held it continuously for more than ten years, are exempt from the exam requirement. All new entrants must pass the CMCA and satisfy the pre-exam education. Annual renewal costs $200, still due by January 31. The DCP can revoke or suspend a certificate of registration for violations of the statute, giving Connecticut owners a regulatory body they can file a complaint with.

The Connecticut DCP's registration page at portal.ct.gov lists current requirements and includes a license-lookup tool. A board or buyer can verify a manager's standing in under two minutes. That lookup tool does not exist in New York because there is nothing to look up.

Where Connecticut fits relative to the states in this series.

State Year enacted Requirement Oversight body Owner recourse
Connecticut 1991 (exam added 2012) DCP registration + fidelity bond; CMCA exam for new entrants CT Dept. of Consumer Protection DCP can investigate and revoke; public registry
Nevada 2005 60 hrs education, exam, fingerprint background check; fiduciary duty codified NV Real Estate Division State ombudsman operating since 1997
Virginia 2008 License; E&O insurance required; DPOR oversight VA DPOR State ombudsman; 5,391 owner contacts in most recent reported year
Illinois 2010 (extended through 2032) 20 hrs pre-license education; state exam; IDFPR oversight IL IDFPR License revocation; disciplinary board
New York None. No registration, no exam, no bond requirement. None Civil litigation only

What registration actually catches that New York misses.

The CCNYC originating post, Why We Built CondosCoopsNYC, put the licensure gap this way: a barber needs a state license; the person managing your $200 million residential building needs nothing. Connecticut's 1991 statute sharpens that comparison. What the law actually addressed was not competency first, but accountability: you cannot investigate a practitioner, revoke their standing, or claim against a bond if they are not on record anywhere.

In New York, a managing agent can operate without registering with any state or city agency, without posting any bond, and without appearing in any searchable database. When a board in New York hires a managing agent, the only due-diligence tool available is calling references and reading the management agreement. If the agent misappropriates reserve funds, the board's remedy is a civil lawsuit against a party that may have already dissolved the operating entity or transferred assets. Connecticut's fidelity bond requirement means there is insurance behind the loss, win or lose in court.

New York's Local Law 2026/058, which set co-op application timelines and named the managing agent as a defined party subject to HPD enforcement, did not impose any credential requirement on that party. As the CCNYC post on Local Law 58 and the managing-agent liability gap documented, New York now holds managing agents to statutory timelines and financial penalties without requiring them to demonstrate any qualification to be in that role.

Ten sessions in Albany without a hearing.

New York Senate Bill S.71, sponsored by Senator Brian Kavanagh, would require managing agents of residential condominium and cooperative buildings to file a registration statement with the Secretary of State and to hold a certification from an approved organization. The bill is a narrower ask than Connecticut's current system: it mirrors Connecticut's 1991 starting point, not the 2012 exam-strengthened version.

The bill has been introduced in ten consecutive sessions. It has not received a committee hearing in any of them. As CCNYC documented in New York's condo reform record, the mechanism that has stopped it is committee referral without a scheduled hearing, session after session. The June 18, 2026 Albany adjournment left S.71 in the same position it has occupied for a decade.

David Kuperberg, principal at Cooper Square Realty, called the current New York regime "dinosaur age" in the CCNYC interview cited in the S.71 post. That characterization came from inside the industry. Connecticut's neighbor to the west has been operating without a census of its community managers since 1991, when Connecticut decided that a registry, a bond, and a public lookup tool were the minimum a state owed its condo and co-op owners.

Bottom line.

Connecticut did not wait for a reserve-fund collapse or a managing-agent fraud case to generate political pressure. It required registration in 1991 because registration is the floor beneath any accountability system: you cannot investigate a person who is not on record with a state agency. By 2012, Connecticut had added an exam requirement. New York's S.71 proposes nothing beyond Connecticut's 1991 starting point, and it has not reached a committee hearing in ten sessions. The Community Associations Institute identifies seven states with mandatory licensing or registration for community association managers; New York is not among them. The state has 14,062 condo and co-op buildings and more than 1.2 million unit owners, and no registry of the people managing those properties.

Primary sources: Conn. Gen. Stat. § 20-451 (registration required; Justia); CT Department of Consumer Protection, Community Association Manager registration; NY Senate S.71, 2025–2026 session; CAI, Current and Forecasted Legislation on Community Association Manager Licensing.

Companion resources: S.71 and the NY licensure gap · Virginia licensed condo managers in 2008 · Nevada certified managers in 2005 · Illinois licensed managers in 2010 · NY’s condo reform record · Albany 2026 adjournment · Write your Albany representative · Managing agent profiles