Washington D.C. licensed property managers in 1999 and codified their fiduciary duty. New York’s bill has never had a committee hearing.

D.C. Law 12-261, enacted April 20, 1999, added a property manager licensing framework to D.C. Code Title 47, Chapter 28. The law requires anyone who manages real property in the District of Columbia for compensation, including condominium associations, cooperative associations, and homeowners associations, to hold a license issued by the D.C. Real Estate Commission. D.C. Code § 47-2853.195 imposes a statutory fiduciary duty on every licensed manager. New York has no equivalent statute. The managing agent of a $200 million Manhattan condominium holds no state license and faces no state-law fiduciary standard.

What D.C. enacted in 1999.

The District of Columbia is not a state. It cannot enter interstate license-reciprocity agreements the way Virginia or Nevada can. It enacted a property manager license requirement regardless.

D.C. Law 12-261 took effect April 20, 1999, inserting Part K titled “Property Managers” (D.C. Code § 47-2853.141 et seq.) into the District’s occupational licensing code. The law placed property managers under the authority of the D.C. Department of Licensing and Consumer Protection (DLCP) and its Real Estate Commission, the same body that already regulated real estate brokers, salespersons, auctioneers, and appraisers in the District. Adding property managers to that jurisdiction extended an existing regulatory infrastructure. It did not require a new agency or a new appropriation.

D.C. Code § 47-2853.141 defines the scope of practice: a licensed property manager is a person who, for compensation, manages or operates real property for or on behalf of the owner, including administrative and maintenance functions. The DLCP has confirmed that community association managers, the firms and individuals managing condominiums, co-ops, and HOAs in the District, fall within that definition. Practicing property management without a license in the District carries civil and criminal penalties under the occupational licensing code.

New York’s current regime permits the same work to proceed without a license, without an exam, and without a regulatory body that can investigate a complaint or revoke a credential.

What the D.C. license requires.

To obtain a property manager license from the DLCP, a candidate must pass a written examination with two components: a national portion covering property management law, financial administration, maintenance management, leasing, and professional ethics, and a D.C.-specific portion covering the District’s landlord-tenant statutes, the D.C. Condominium Act, and the District’s occupational licensing requirements. Both portions must be passed before a license issues. (D.C. Code § 47-2853.142; DLCP Property Manager Study Guide.)

The District does not require pre-license education hours before sitting the exam. That sets a lower bar than Florida’s 40-hour requirement or Nevada’s 60-hour requirement. But the exam tests substantive knowledge of law and financial practice. A manager who passes has demonstrated working familiarity with the statutes governing every building on their portfolio.

After licensure, DC property managers must complete 15 hours of continuing education per two-year renewal cycle. Required topics include fair housing law and the D.C. Human Rights Act, professional ethics, legislative and regulatory updates affecting property management, and general property management practice. A manager who first passed the exam in 2002 must show, at each renewal, that they have kept pace with statutory changes across those years.

The DLCP can suspend or revoke a license for fraud, misrepresentation, commingling of client funds, unauthorized withdrawal from reserve accounts, or breach of trust. Suspension and revocation actions are public records. A condo board, a prospective buyer, or a unit owner can check a D.C. manager’s license status through the DLCP’s online portal. That check has been available since 1999.

Fiduciary duty written into statute.

The most consequential provision in D.C.’s framework is not the exam. It is D.C. Code § 47-2853.195, titled “Fiduciary duties of a property manager.”

The section requires that a licensed property manager act as a fiduciary to the principal, the board, association, or owner who retained them. The statute obligates the manager to put the principal’s interests above their own, to avoid self-dealing, and to protect confidential information relating to the principal’s affairs. A D.C. manager who routes maintenance contracts to an affiliated vendor at above-market rates, without disclosure and board consent, has violated a statutory standard — not merely a contract term. The DLCP can investigate that conduct and revoke the license. The principal does not need to prove breach of contract; they need to prove breach of the statutory duty.

In New York, a managing agent’s duty to the board runs entirely from the management agreement. If the agreement fails to address a specific conflict, the board’s remedy is a breach-of-contract action. The board must prove the contract was violated, not that the agent placed its own interests ahead of the building’s. There is no state-law background standard. A self-dealing managing agent who technically stayed within the contract’s text has no state licensing board to answer to.

The practical gap is widest at NYC buildings where the management agreement was drafted by the managing agent’s own attorneys. Those agreements are typically silent on vendor affiliation disclosures and competitive bidding procedures. A statutory fiduciary duty applies regardless of what the contract says. It cannot be waived by a boilerplate form. It gives unit owners and boards a legal standard that exists independently of the instrument the managing agent helped write.

New York Senate Bill S.71 does not propose codifying a fiduciary duty for managing agents. The bill would require registration with the Department of State and disclosure of vendor affiliations. Those are steps toward accountability. They do not reach what the District of Columbia enacted 27 years ago.

Where D.C. fits among the jurisdictions that have acted.

The Community Associations Institute identifies seven states with mandatory community association manager licensing: Alaska, Connecticut, Florida, Georgia, Illinois, Nevada, and Virginia. (CAI, “Manager Licensing & Model Legislation.”) The District of Columbia is not counted in that group because it is not a state. Its property manager licensing statute covers the same scope of work. The table below places D.C. alongside the five states CCNYC has covered in this series, plus New York.

No jurisdiction in the table has repealed its licensing requirement. Illinois extended its licensing act through 2032 over industry opposition in the 2026 legislative session. Connecticut added an examination requirement in 2012, twenty-one years after the initial registration law, showing that programs can be strengthened over time. The licensing frameworks in each jurisdiction have coexisted with voluntary certification programs, specifically the CMCA credential administered by the Community Association Managers International Certification Board, without one canceling the other out.

What S.71 proposes, and the record in Albany.

Senate Bill S.71 (Kavanagh, SD-27), assigned to the Senate Judiciary Committee, would require managing agents of residential condominium and cooperative buildings to file a registration statement with the Secretary of State and hold a certification from an approved organization. The bill proposes registration, not a license with substantive competency standards. There is no state examination in the current draft, no pre-license education requirement, no background check, and no fiduciary duty provision. D.C.’s 1999 statute is more demanding on each point than what S.71 asks of New York.

The 2026 Albany session closed June 18 with S.71 in committee and no hearing scheduled. There is no Assembly same-as companion bill in the current session. As CCNYC documented in New York’s condo reform record, the mechanism that has stopped S.71 is committee referral without a scheduled hearing, session after session. The bill has not received a recorded vote in either chamber. The D.C. Council enacted D.C. Law 12-261 in 1999. Since that date, S.71 and its predecessors have been introduced in New York for ten consecutive sessions without advancing to a committee vote.

The practical consequence sits across the 14,062-building NYC condo and co-op universe. The person holding the reserve fund, vendor contracts, and maintenance operations for a 300-unit Queens co-op holds no credential New York can revoke. No state agency can suspend their ability to manage the next building if they misappropriate funds. No statutory fiduciary duty establishes a legal standard that the management agreement did not reach. The District of Columbia built those safeguards — exam, continuing education, fiduciary duty, revocable license — before the first iPhone, before the 2003 Columbia shuttle disaster, and before most of the NYC condo buildings currently managed by licensed-nowhere agents were built.

Bottom line.

D.C. Code § 47-2853.195 gives property owners in the District of Columbia a statutory fiduciary standard against which to measure their manager’s conduct. The DLCP can investigate a complaint and revoke a license. In New York, the board that suspects its managing agent of self-dealing must hire an attorney, file a lawsuit, and prove a contract was breached. The D.C. framework is 27 years old. New York’s managing-agent bill has not had a committee hearing. The gap is not a gap in available models. It is a record of sessions in which the legislation was introduced, assigned to committee, and not scheduled for a hearing.

Primary sources: D.C. Code Title 47, Ch. 28, Subch. I-B, Part K — Property Managers (full text); D.C. Code § 47-2853.141, Scope of practice; D.C. Code § 47-2853.142, Eligibility requirements; D.C. Code § 47-2853.195, Fiduciary duties of a property manager; D.C. Law 12-261, enacted April 20, 1999, 46 DCR 3142; DLCP Real Estate Commission; NY Senate S.71, 2025–2026 session; CAI, Manager Licensing & Model Legislation.

Companion resources: S.71 and the NY licensure gap · Georgia required CAM licensing in 1997 · Connecticut required CAM registration in 1991 · Nevada certified managers in 2005 · Virginia licensed managers in 2008 · Illinois licensed managers in 2010 · NY’s condo reform record · Albany 2026 adjournment · Why we built this · Write your Albany representative · Managing agent profiles