Commerical Use Policy Update - New Thread!

[Cyberc1978]

This relates to an HOA and we are a COA…so honestly, not sure.

from what I can find online for COA the same applies. Rules need to be clear as unclear rules often causes problems.

We remind our clients that selective enforcement or unclear rules often cause more harm than the initial violation. If rules are not applied equally to all residents, legal challenges may follow.

https://www.tampalitigator.com/blog/understanding-the-legal-responsibilities-of-condo-associations/

IMO I don’t think we will see any update to the commercial use policy because as we have spoken about before any limitation to renting requires a vote - DVC knows that it will be pointless asking for a vote. Therefore they will keep the policy as is even if it’s unclear and enforce from there(if they enforce)

I’m pretty sure if the BOD is asked about enforcement they will claim they have done so, regardless of how little or how much enforcement they’ve done. We won’t be able to see any difference but that doesn’t mean enforcement haven’t been done. As members we won’t be able to proof either way - except something has been done.

 

[MICKIMINI]

"With friends" is different than "for friends", and "in villas with friends" is different than "at home" while a friend is in your villa. I think if you look at a timeshare like DVC logically, it's meant to be used as a personal use product for your family and friends who are vacationing with you at the same time. I don't think there's a person in the world who cares that you rent a 3BR grand villa and go with 5 of your family and 6 of your friends, or that you rent three 1 BR villa's and you're in one, and friends are in the other one. It's the people who have a product they almost never personally use, and suddenly their 12 aunts and 45 friends are basically the owners of the timeshare points that's questionable.

After covid, we let our son and DIL use points at Aulani, Poly, BWV and BLT. DH and I were caring for ourselves (a close colleague of DH's and his wife passed of covid so we were one breath away so to speak) as we both were sick though not hospitalized and caring for elderly parents that were sick as well (one went to ER). I don't even remember how many points we gifted them and no one seemed to care that we weren't there with them. If the policy of 2011 sticks, well there it is. We always gift them.

Sandi's point that the CM's are being put in a difficult position is valid. Totally unfair that the upper crust sit back and watch the mayhem as the front line people take the heat!

 

[Tatebeck]

I found this online.

I assume that this applies to DVC, but my legal knowledge in this area is none existent

If it does the rules that we members need to adhere to needs to be easy to understand. At best our updated terms and conditions is anything but easy to understand. We all understand the words but the context the should be understood with is very unclear. I’m referring to “frequent and regularly” renting is not allowed. We all have our own and different understanding what it means - that does not comply with the text below.

It states that HOA rules :To be enforceable, HOA rules should align with the association’s governing documents, comply with state and federal laws, follow the proper approval process, and be written in a way that is easy to understand and apply consistently.

Source: https://www.fsresidential.com/florida/news-events/articles/unenforceable-hoa-rules-in-florida/

Thoughts?

The rules are written in a way that is easy to understand. It is just that the rules themselves give DVC sole subjective control over what constitutes a pattern of commercial rental activity.

The rule boils down to: don't engage in any rental or rental-related activities that DVC thinks/feels is a commercial pattern.

So the rule itself is easy enough to understand. It's just that we don't know at what point DVC will feel a member is acting commercially, which gives them enormous power if they wish to use it. Probably by design and why they don't want to put in writing any hard limits on point number or percentage of points that can be rented.

 

[VGCgroupie]

The rules are written in a way that is easy to understand. It is just that the rules themselves give DVC sole subjective control over what constitutes a pattern of commercial rental activity.

The rule boils down to: don't engage in any rental or rental-related activities that DVC thinks/feels is a commercial pattern.

So the rule itself is easy enough to understand. It's just that we don't know at what point DVC will feel a member is acting commercially, which gives them enormous power if they wish to use it. Probably by design and why they don't want to put in writing any hard limits on point number or percentage of points that can be rented.

I used to think this. But reading the 2008/2011 update the way they define personal use, has me thinking its not as clear cut as it once was, it's as if it was written with two different policies imo. But it's just that, my opinion.

DVC Members may make as many reservations as they desire. However, if, in any 12-month period, a DVC Member desires to make more than 20 reservations, the DVC Member shall be required to establish, to the satisfaction of the Board, that all of the reservations made by the DVC Member in such 12-month period are for the use of accommodations by the DVC Member, the DVC Member’s family and/or the DVC Member’s friends (collectively, “Personal Use”), and not for commercial purposes. If, in any 12-month period in which a DVC Member attempts to make more than 20 reservations but is unable to establish, to the satisfaction of the Board, that all such reservations are for Personal Use and not for commercial purposes, all reservations in excess of the first 20 reservations shall be presumed to be the use of Vacation Accommodations for commercial purposes in violation of the Declaration and the Membership Agreement (the “Multiple Reservation Rule”).

 

[Tatebeck]

I used to think this. But reading the 2008/2011 update the way they define personal use, has me thinking its not as clear cut as it once was, it's as if it was written with two different policies imo. But it's just that, my opinion.

DVC Members may make as many reservations as they desire. However, if, in any 12-month period, a DVC Member desires to make more than 20 reservations, the DVC Member shall be required to establish, to the satisfaction of the Board, that all of the reservations made by the DVC Member in such 12-month period are for the use of accommodations by the DVC Member, the DVC Member’s family and/or the DVC Member’s friends (collectively, “Personal Use”), and not for commercial purposes. If, in any 12-month period in which a DVC Member attempts to make more than 20 reservations but is unable to establish, to the satisfaction of the Board, that all such reservations are for Personal Use and not for commercial purposes, all reservations in excess of the first 20 reservations shall be presumed to be the use of Vacation Accommodations for commercial purposes in violation of the Declaration and the Membership Agreement (the “Multiple Reservation Rule”).

What exactly about the different wordings do you feel makes them not mesh well together? I've looked at them all before but nothing jumped out at me as being crazy different.

 

[Sandisw]

The rules are written in a way that is easy to understand. It is just that the rules themselves give DVC sole subjective control over what constitutes a pattern of commercial rental activity.

The rule boils down to: don't engage in any rental or rental-related activities that DVC thinks/feels is a commercial pattern.

So the rule itself is easy enough to understand. It's just that we don't know at what point DVC will feel a member is acting commercially, which gives them enormous power if they wish to use it. Probably by design and why they don't want to put in writing any hard limits on point number or percentage of points that can be rented.

The rules that you can’t rent for commercial purposes is clear but if DVC doesn’t let owners know what that is, then how on earth are owners supposed to know what level of renting is and is not okay?

They have sole discretion to define and change it but that is not the same as saying they don’t have to adopt a policy to deal with it.

The only policy we have that defines it is the 2011 one and that really only discusses what happens if you exceed 20 reservations in a rolling 12 months.

I get that DVC may want it to be a moving target but as long as they keep secret from owners how they plan to define and enforce what frequently or regularly or occasionally renting looks like, outside of the official policy, then owners are forced to decide on their own what level of renting is okay.

And as long as individual owners are the ones defining it, then we are going to continue to see people doing all the same things.

I would think most members want DVC to be transparent with the rules so we can use our memberships, which includes being able to rent, appropriately.

ETA: Even owners that may want to see DVC crack down hard and/ or define it really narrowly should be expecting the same thing…be clear to owners if you want behaviors to stop.

 

[Sandisw]

I used to think this. But reading the 2008/2011 update the way they define personal use, has me thinking its not as clear cut as it once was, it's as if it was written with two different policies imo. But it's just that, my opinion.

DVC Members may make as many reservations as they desire. However, if, in any 12-month period, a DVC Member desires to make more than 20 reservations, the DVC Member shall be required to establish, to the satisfaction of the Board, that all of the reservations made by the DVC Member in such 12-month period are for the use of accommodations by the DVC Member, the DVC Member’s family and/or the DVC Member’s friends (collectively, “Personal Use”), and not for commercial purposes. If, in any 12-month period in which a DVC Member attempts to make more than 20 reservations but is unable to establish, to the satisfaction of the Board, that all such reservations are for Personal Use and not for commercial purposes, all reservations in excess of the first 20 reservations shall be presumed to be the use of Vacation Accommodations for commercial purposes in violation of the Declaration and the Membership Agreement (the “Multiple Reservation Rule”).

I posted the response earlier they gave me about this…that is there just as an example of what is appropriate under “personal use”. Meaning “family and friends” count as personal use,

The clause is also talking about what an owner needs to prove in order to book more than 20 and to distinguish it against the multiple reservations rule, which are the ones above 20.

But it got me thinking…and reading things again…and the point you brought to light the other day in how they use some of the same terms to mean slightly different things depending on the context it is being used.

For example, they use “commercial purpose” to define both what you can do while staying in the villa and to define what level of renting you are doing with your membership.

Same verbiage, but two different contexts and two different limitations.

 

[VGCgroupie]

What exactly about the different wordings do you feel makes them not mesh well together? I've looked at them all before but nothing jumped out at me as being crazy different.

I have read this before and it didn't really hit me, but when I read it again while comparing the 2008 to 2011 I realized this is the only instance I have seen personal use actually defined in any way. Has it been defined in any other documents that Im not remembering or haven't seen?

 

[Tatebeck]

The rules that you can’t rent for commercial purposes is clear but if DVC doesn’t let owners know what that is, then how on earth are owners supposed to know what level of renting is and is not okay?

They have sole discretion to define and change it but that is not the same as saying they don’t have to adopt a policy to deal with it.

The only policy we have that defines it is the 2011 one and that really only discusses what happens if you exceed 20 reservations in a rolling 12 months.

I get that DVC may want it to be a moving target but as long as they keep secret from owners how they plan to define and enforce what frequently or regularly or occasionally renting looks like, outside of the official policy, then owners are forced to decide on their own what level of renting is okay.

And as long as individual owners are the ones defining it, then we are going to continue to see people doing all the same things.

I would think most members want DVC to be transparent with the rules so we can use our memberships, which includes being able to rent, appropriately.

ETA: Even owners that may want to see DVC crack down hard and/ or define it really narrowly should be expecting the same thing…be clear to owners if you want behaviors to stop.

Considering how often DVC says it is supposed to be for personal use and not for making money, there are a couple easy answers, one stricter than the other.

The easiest answer would be to rent "as little as possible" or "only as absolutely necessary." The amount would then depend on the owner and their situation but could be rather restrictive.

A more lenient answer would actually mirror what your MS supervisor mentioned a while back, which could be as long as you aren't renting for more than dues and still using the vast majority of your membership for personal/family stays then you likely wouldn't have been joining DVC for income/profit as a commercial entity.

From POS documents:
"Ownership Interests are offered for personal use and enjoyment only and should not be purchased by any Purchaser for resale or as an investment opportunity or with any expectation of achieving rental income,"

 

[Cyberc1978]

The rules are written in a way that is easy to understand. It is just that the rules themselves give DVC sole subjective control over what constitutes a pattern of commercial rental activity.

The rule boils down to: don't engage in any rental or rental-related activities that DVC thinks/feels is a commercial pattern.

So the rule itself is easy enough to understand. It's just that we don't know at what point DVC will feel a member is acting commercially, which gives them enormous power if they wish to use it. Probably by design and why they don't want to put in writing any hard limits on point number or percentage of points that can be rented.

if you feel that the rules are easy to read and understand, please explain to me like i'm 6 yo how I should understand the following from the T&C: Additionally, personal use means that the member does not regularly or frequently rent/sell reservations booked using their membership.

According to the link I provided, subjective or unclear rules without specific criteria for compliance it increases the risk for disputes and makes it more difficult for the HOA to uphold the authority.

IF, DVC have the subjective right to determine the level that I can rent and what level you can rent, then my understanding after reading the text that it could potentially cause more headaches than the good it could bring.

It only takes 1 member to take legal actions against DVC to bring down the fort. Thats why I dont think DVC will do any enforcement when the policy is this vague. But if the policy can get some owners to think twice before renting or not rent at all, then maybe their mission is accomplished. The 20 reservations rule is more clear cut and maybe most of all clear to understand - both you and I understand what I would mean to make 20 reservations or more.

Remember that no matter what rule or policy DVC imposes on the membership, it has to be for the good of the membership as a whole. A policy which is unclear how can that be any good for anyone - except for the one who writes it?

I understand that DVC wanted to make this as vague as possible, but IMO they will have a hard time enforcing it on the regular members like you and me. However enforcement on the LLC's is a totally different ballgame, as they are not allowed to rent at all.

Moreover I think the sole reason why DVC haven't updated their commercial use policy is because of the FL statutes 718.110. If they updated the policy, to say each member is allowed to rent 10 reservations per year. Then that would be seen as a limitation compared to the current policy, which just says that you are not allowed to do it commercially.
Any enforcement would have to be based on the current policy and their judgement has to be reasonable as to what they think is commercially.

 

[mkatsy]

From POS documents:
"Ownership Interests are offered for personal use and enjoyment only and should not be purchased by any Purchaser for resale or as an investment opportunity or with any expectation of achieving rental income,"

wait a minute ... what is this " should not be purchased by any purchaser for resale" ... as of now, I've only seen discussion focused on renting your ownership interest but to me this clearly reads that you are not to purchase with the intent to SELL your ownership interest. (presumably for a profit) This would be the "flipping" part of the equation. This is incredibly simple to prove as the Orange County Comptroller provides a "print" button, and you can pull up an LLC's entire buy/sell history. Why isn't this being enforced? Some of these brokers own tens of thousands of their own points. They are NOT just matchmakers for other members. Add it to the list for the September meeting. Better yet ... I'll just bring the print outs with me to the meeting. I have one here on my desk, 428 buy/sell transactions ... in nobody's world is this personal use.

 

[Cyberc1978]

wait a minute ... what is this " should not be purchased by any purchaser for resale" ... as of now, I've only seen discussion focused on renting your ownership interest but to me this clearly reads that you are not to purchase with the intent to SELL your ownership interest. (presumably for a profit) This would be the "flipping" part of the equation. This is incredibly simple to prove as the Orange County Comptroller provides a "print" button, and you can pull up an LLC's entire buy/sell history. Why isn't this being enforced? Some of these brokers own tens of thousands of their own points. They are NOT just matchmakers for other members. Add it to the list for the September meeting. Better yet ... I'll just bring the print outs with me to the meeting. I have one here on my desk, 428 buy/sell transactions ... in nobody's world is this personal use.

First off. It’s not that I disagree.

But wouldn’t any LLC claim that just because you “shouldn’t” does not mean mean that you “couldn’t” ?

I know it’s a matter of words but it your weren’t allowed to do it shouldn’t the wording have been you can’t/not allowed to etc?

 

[mkatsy]

First off. It’s not that I disagree.

But wouldn’t any LLC claim that just because you “shouldn’t” does not mean mean that you “couldn’t” ?

I know it’s a matter of words but it your weren’t allowed to do it shouldn’t the wording have been you can’t/not allowed to etc?

Well, they have a team of lawyers so I’m sure they have themselves covered. My point to DVC is more, if you are going to turn a blind eye to this egregious cash grab by the LLC’s (some of the contracts they hold are marked up $10,000 on resale), don’t even think of coming at “me” (in the colloquial sense, I use all my points and more) because I’m the low hanging fruit. The rules should be enforced fairly, the determining factor shouldn’t be (but I suspect it is) whether you have a legal team at your disposal.

 

[Sandisw]

Considering how often DVC says it is supposed to be for personal use and not for making money, there are a couple easy answers, one stricter than the other.

The easiest answer would be to rent "as little as possible" or "only as absolutely necessary." The amount would then depend on the owner and their situation but could be rather restrictive.

A more lenient answer would actually mirror what your MS supervisor mentioned a while back, which could be as long as you aren't renting for more than dues and still using the vast majority of your membership for personal/family stays then you likely wouldn't have been joining DVC for income/profit as a commercial entity.

From POS documents:
"Ownership Interests are offered for personal use and enjoyment only and should not be purchased by any Purchaser for resale or as an investment opportunity or with any expectation of achieving rental income,"

That’s the thing…the law gives us the right to rent and DVC can use the terms personal use as much as they want.

But the contract uses the word leasee when it talks about personal use.

So, it doesn’t mesh that personal use doesn’t include renters…and the updated T and C actually support it because it reminds owners frequeny or regularly renting is what isn’t allowed under personal use, not all renting.

People are expecting DVC to do things to stop behaviors that they see as commercial renting, so not sure why anyone would not want to see DVC actually define it so it can be enforced.

On the other hand, this may be the very take that DVC wants…frighten people into thinking they can no longer rent without actually having to stop a thing.

The notion though that because DVC has sole discretion to make the rules means they don’t have to actually communicate actual rules to owners when it comes to renting because it says what that says above?

The answers from DVC management I have gotten seem to support that owners will know the policies in place, including being notified in some way when they are updated or changed.

We shall see!

 

[Tatebeck]

That’s the thing…the law gives us the right to rent and DVC can use the terms personal use as much as they want.

But the contract uses the word leasee when it talks about personal use.

So, it just doesn’t mesh that personal use doesn’t include renters…and the new T and C actually support it because it reminds owners frequent or regularly is what isn’t allowed under personal use, not all renting.

People are expecting DVC to do things to stop behaviors that they see as commercial renting, so not sure why anyone would not want to see DVC actually define it so it can be enforced.

On the other hand, this may be the very take that DVC wants…frighten people into thinking they can no longer rent without actually having to stop a thing.

The notion though that because DVC has sole discretion to make the rules means they don’t have to actually communicate actual rules to owners when it comes to renting because it says what that says above?

The answers from DVC management I have gotten seem to support that owners will know the policies in place, including being notified in some when they are updated or changed.

We shall see!

That is true, they did give us the right to rent sometimes as long as is a small amount and it doesn't make DVC think that we are acting commercially. So personal use can definitely include renters, but only up to a point that DVC allows and gets to subjectively decide (before they feel it is commercial)

DVC (and maybe some members) do not want a strict definition on the number or rentals, points rented, percentage of points rented etc, because then commercial renters have something concrete that they can try to workaround/skirt. (IE if the limit is 1000 points rented per year, there will be a ton of renters renting 999, with their wife renting 999, kids renting 999, etc. Even if it would require some retitling, etc). And it could possibly tie DVC's hands to certain situations. So I do think it is in a way "smart" for DVC to let it be vague and say that they can decide on a case by case basis if and when they decide they see commercial activity. It gives them more power but makes it murkier for the members.

It would 100% make my membership easier to use with more defined limits, but I understand that that would have negatives as well.

They have communicated the actual rules to members, they are in our documents already (or the last rule that some have requested and have ben granted). The rules just give them subjective authority to decide for each member.

 

[tx911]

That is true, they did give us the right to rent sometimes as long as is a small amount and it doesn't make DVC think that we are acting commercially. So personal use can definitely include renters, but only up to a point that DVC allows and gets to subjectively decide (before they feel it is commercial)

DVC (and maybe some members) do not want a strict definition on the number or rentals, points rented, percentage of points rented etc, because then commercial renters have something concrete that they can try to workaround/skirt. (IE if the limit is 1000 points rented per year, there will be a ton of renters renting 999, with their wife renting 999, kids renting 999, etc. Even if it would require some retitling, etc). And it could possibly tie DVC's hands to certain situations. So I do think it is in a way "smart" for DVC to let it be vague and say that they can decide on a case by case basis if and when they decide they see commercial activity. It gives them more power but makes it murkier for the members.

It would 100% make my membership easier to use with more defined limits, but I understand that that would have negatives as well.

They have communicated the actual rules to members, they are in our documents already (or the last rule that some have requested and have ben granted). The rules just give them subjective authority to decide for each member.

If they came out and said we can rent no more than enough to cover dues every year (or maybe an average of that much every 3 years), no one could make any money by renting, right?

 

[Tatebeck]

if you feel that the rules are easy to read and understand, please explain to me like i'm 6 yo how I should understand the following from the T&C: Additionally, personal use means that the member does not regularly or frequently rent/sell reservations booked using their membership.

My post just before yours basically answered this.

The easiest answer would be to rent "as little as possible" or "only as absolutely necessary." The amount would then depend on the owner and their situation but could be rather restrictive.

A more lenient answer would actually mirror what your MS supervisor mentioned a while back, which could be as long as you aren't renting for more than dues and still using the vast majority of your membership for personal/family stays then you likely wouldn't have been joining DVC for income/profit as a commercial entity.
Use your points, rent as little as possible or rent only when you have to. So don't do it often.

First off. It’s not that I disagree.

But wouldn’t any LLC claim that just because you “shouldn’t” does not mean mean that you “couldn’t” ?

I know it’s a matter of words but it your weren’t allowed to do it shouldn’t the wording have been you can’t/not allowed to etc?

You have to look at the first part as well (and everywhere else in the rules where it's mentioned) where it says it is ONLY for personal use. Buying specifically to flip would certainly seem to be outside personal use.

"for personal use and enjoyment only"

 

[Tatebeck]

If they came out and said we can rent no more than enough to cover dues every year (or maybe an average of that much every 3 years), no one could make any money by renting, right?

Too wide of a spread for what people charge for rentals to easily do this. $10 for points in distress to $35/40 for spec reservations in hard to get rooms.

The easiest way to try that would be that they could assume like $20 per point, require notifying MS of each reservation that is a rental (as the rules are supposed to already), then look at suspicious members individually after that

 

[Sandisw]

if you feel that the rules are easy to read and understand, please explain to me like i'm 6 yo how I should understand the following from the T&C: Additionally, personal use means that the member does not regularly or frequently rent/sell reservations booked using their membership.

According to the link I provided, subjective or unclear rules without specific criteria for compliance it increases the risk for disputes and makes it more difficult for the HOA to uphold the authority.

IF, DVC have the subjective right to determine the level that I can rent and what level you can rent, then my understanding after reading the text that it could potentially cause more headaches than the good it could bring.

It only takes 1 member to take legal actions against DVC to bring down the fort. Thats why I dont think DVC will do any enforcement when the policy is this vague. But if the policy can get some owners to think twice before renting or not rent at all, then maybe their mission is accomplished. The 20 reservations rule is more clear cut and maybe most of all clear to understand - both you and I understand what I would mean to make 20 reservations or more.

Remember that no matter what rule or policy DVC imposes on the membership, it has to be for the good of the membership as a whole. A policy which is unclear how can that be any good for anyone - except for the one who writes it?

I understand that DVC wanted to make this as vague as possible, but IMO they will have a hard time enforcing it on the regular members like you and me. However enforcement on the LLC's is a totally different ballgame, as they are not allowed to rent at all.

Moreover I think the sole reason why DVC haven't updated their commercial use policy is because of the FL statutes 718.110. If they updated the policy, to say each member is allowed to rent 10 reservations per year. Then that would be seen as a limitation compared to the current policy, which just says that you are not allowed to do it commercially.
Any enforcement would have to be based on the current policy and their judgement has to be reasonable as to what they think is commercially.

I don’t even think it takes a lawsuit.

I think it just takes well informed owners who ask DVC for clarification and can provide them with things like the law and what you posted to support why they are confused.

In all my years of owning, when DVC has felt they were completely in the right, they have not wavered at all in their position, even when questioned.

But, when they weren’t sure? They reversed things…like what happened with the 2020 charts…

As you have mentioned, enforcement against LLCs should not be hard because the contract is extremely clear on who those owners can have using their memberships.

 

[Sandisw]

That is true, they did give us the right to rent sometimes as long as is a small amount and it doesn't make DVC think that we are acting commercially. So personal use can definitely include renters, but only up to a point that DVC allows and gets to subjectively decide (before they feel it is commercial)

DVC (and maybe some members) do not want a strict definition on the number or rentals, points rented, percentage of points rented etc, because then commercial renters have something concrete that they can try to workaround/skirt. (IE if the limit is 1000 points rented per year, there will be a ton of renters renting 999, with their wife renting 999, kids renting 999, etc. Even if it would require some retitling, etc). And it could possibly tie DVC's hands to certain situations. So I do think it is in a way "smart" for DVC to let it be vague and say that they can decide on a case by case basis if and when they decide they see commercial activity. It gives them more power but makes it murkier for the members.

It would 100% make my membership easier to use with more defined limits, but I understand that that would have negatives as well.

They have communicated the actual rules to members, they are in our documents already (or the last rule that some have requested and have ben granted). The rules just give them subjective authority to decide for each member.

If this is true, then everyone’s interpretation of what frequently and regularly renting looks like is correct.

Everyone’s interpretation of the 2011 offical and current policy would be correct as well,,,

If DVC doesn’t actually identity actions that are out of bounds, then what do they enforce?

Take spec renting of hard to get rooms, if DVC doesn’t identify that as a pattern of rentals that meets the commercial purpose standard, then owners are left to interpret aspects of the contract language to decide if it’s allowed or not.

Sure, there is language that makes it seem like it should be but other language that make it seem like it’s not…and the only one who can say which interpretation is right is DVC…

Right now, DVC has done nothing to change the rules or policy in place…and when pushed about who we can rent to, they admitted it’s to anyone, not family and friends.

Even your words that you can rent “a small amount” is your interpretation of what level of renting should be appropriate, isn’t it?

All we know for sure is that DVC has identified clearly two actions by owners that count as of bounds…more than 20 reservations in a rolling 12 months and using transferred points in a way that looks commercial. .

So, we are stuck waiting to see if DVC decides to penalize an owner for other things.

If they do, then everyone, will know what they are thinking…which is why I believe the info they gave me…we will know when and if rules are updated.

IMO, owners deserve better from DVC.