DVC plans to target commercial renters

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It is just one or two variables out of many. Just renting a high value room doesn't necessarily have to put you up for "review"

A member renting 100% of their 1000 points almost every year at SSR may be more of a "commercial enterprise" target than a BWV member who rents 10% or 100 out of their 1000 points almost every year, even if they usually rent out the valuable SV studios.

It just ticks a possible box or adds a bit to the equation for them to look at.

Ex.
% of points rented this year + # of points rented this year + room type rented + number of years with rentals in the last 5 years + # of DVC "High season" rentals in the last 5 years, + etc...

See I think we are closer than we think. The type of rooms is part of the picture but it would be hard for me to beleive that DVC can legally penalize one BWV owner for running a business and not the other when the ONLY difference is the room type.

Reason being is that view aside, they are all condos under the same structure.

It would be like saying that someone who owns a condo at the beach and has oceanfront can be held to a different standard then one who is not when the units are in the same building.

And, if I am understanding that new 2021 condo law, DVC using room type as a clarifier might be seen as a new restriction and thus can’t be included without a vote and even then, owners don’t have to abide.

But, not confident in that thinking.
 
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Monkeypods and Costco help with AUL :)

Yes, 7m availability is just bonkers and will continue to do so since the system is so much larger now and can shift to any month at any time.
Haven’t been to Monkeypod yet. We’ve got a kiddo with a pretty serious sesame allergy, so we usually eat on property, next door at the four seasons, or with food we purchase from Foodland Farms.

Shout out to a Longhi’s brunch as well.
 
See I think we are closer than we think. The type of rooms is part of the picture but it would be hard for me to beleive that DVC can legally penalize one BWV owner for running a business and not the other when the only difference is the room type.

Reason being is that view aside, they are all condos under the same structure.

It would be like saying that someone who owns a condo at the beach and has oceanfront can be held to a different standard then one who is not when the units are in the same building.
It does sound like we a closer than it first seemed. But the crucial part is that as long as it is part of the picture/equation then it does matter and it could make the difference between someone being considered within the rules or not.

Say whichever equation/score they end up using has a threshold of 10. They check your membership against a bunch of different questions, tick boxes, and count the number of positive values.

9 ticks and under you are considered as using it as personal use, 10 or more then you are considered as a commercial enterprise and they will contact you for more formal review.

If the only difference is one member has their box ticked for "rented 5 or more very high value room reservations in the last 5 years" and the other member doesn't, then that could make the difference. One ticks 9 and one ticks 10 and is reviewed.
 
And, if I am understanding that new 2021 condo law, DVC using room type as a clarifier might be seen as a new restriction and thus can’t be included without a vote and even then, owners don’t have to abide.

But, not confident in that thinking.
It wouldn't be a new restriction if they could argue that it does indeed point toward "commercial enterprise" being more likely, which is what the old rules need. I think they could easily argue that heavily renting the rooms that bring in more money can lead to more suspicion of "commercial enterprise" happening

Also one more thing that might help you see it: I think that you may need to think about it in a reverse way as well.

You keep saying that you think room type can be used as part of the initial phase of choosing a member to look at, but not as a determining factor in the end.

So in your equation they would look at determining factors (including room types usually rented) -> then move to only other factors to determine if final commercial enterprise is likely

But there will be members who look VERY similar, almost identical in that first phase, with the only difference being that one factor of room types rented

So some members would be passed over on the first phase and not heavily reviewed simply because they hadn't rented out those room types recently. And the member who hit that first threshold and is reviewed may be found to be a commercial enterprise, when the only real difference was the type of room they rented.
 

It wouldn't be a new restriction if they could argue that it does indeed point toward "commercial enterprise" being more likely, which is what the old rules need. I think they could easily argue that heavily renting the rooms that bring in more money can lead to more suspicion of "commercial enterprise" happening

Also one more thing that might help you see it: I think that you may need to think about it in a reverse way as well.

You keep saying that you think room type can be used as part of the initial phase of choosing a member to look at, but not as a determining factor in the end.

So in your equation they would look at determining factors (including room types usually rented) -> then move to only other factors to determine if final commercial enterprise is likely

But there will be members who look VERY similar, almost identical in that first phase, with the only difference being that one factor of room types rented

So some members would be passed over on the first phase and not heavily reviewed simply because they hadn't rented out those room types recently. And the member who hit that first threshold and is reviewed may be found to be a commercial enterprise, when the only real difference was the type of room they rented.

See, in my thought, they wouldn’t pass over anyone because IMO, it wouldn’t be one or the other but both.

Take the old 20 reservations rule…and assume they decide to flag at 15..but also flag all owners with BWV SV. No one is missed.

However, I still believe, especially since they did issue an interpretation for owners to the words “pattern of rental activity to conclude commercial enterprise” in 2008 as 20 reservations, with no mention of room type, it would be an uphill battle from them to come back know and try to say that the pattern doesn’t need to have any level of value.

As has been posted, it appears they can’t limit owners to a low number because to be considered running DV, as a business, it seems built in that a pattern of rental activity would need to include a reasonable number of rentals…whether it’s number of points or number of reservations, or a combination of both.

That is why I think that the first test that has to be met is a quantitative threshold and not something else.

And the document from 2008 IMO was DVCs way of quantifying it for owners and that those terms do matter.

Question being, if 20 reservations per year was the identified pattern of activity that was used as the threshold as that one was a commercial enterprise…which an owner could dispute…what has changed 16 years later that makes that no longer applicable?

I don’t know that answer but I do think that DVC would owe owners an explanation about any changes in how they determine things

As I said, I don’t think it needs to be black and white, but I just can’t agree that the specific rooms should matter and I do see it as a possibly as a new restriction because back when the resorts were created, rooms types did exist.

I do see that some see it that something that makes more money is a target for those running a business but it don’t think the reverse is true.

If the average owner is not renting their points at a level that rises to a reasonable level that it’s a business, then even if all the rooms are popular, they should not be penalized as being a business

Because if they are, then in a way, you are indirectly lifting owners from their right to reserve a room FCFS if they all of a sudden say these particular rooms can’t be rented as much as other rooms at the same resort.

At least that is my take on it and if I was an owner at one of those resorts, and DVC tried to move away from defining commercial enterprise from a pattern of rental activity being a quantitative threshold and now using room types as a way to lower that threshold, I’d certainly file a complaint.

The only piece is I don’t think we will see DVC even consider this because as I said, they don’t need to.

They simply can use the special seasons preference list for those rooms for those hard to book rooms and it achieves the same goal.

Takes them out of the rental world without even needing to explain to anyone how it fits with the way the declaration was written foe rentals
 
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If the average owner is not renting their points at a level that rises to a reasonable level that it’s a business, then even if all the rooms are popular, they should not be penalized as being a business

Because if they are, then in a way, you are indirectly lifting owners from their right to reserve a room FCFS if they all of a sudden say these particular rooms can’t be rented as much as other rooms at the same resort.

At least that is my take on it and if I was an owner at one of those resorts, and DVC tried to move away from defining commercial enterprise using room types when it’s not accompanied with a number of rentals as well, I’d be filing a complaint.
Right, it is only one part of the things they can look at. I never said it was the sole thing that they are looking at, just that it could be the straw that breaks the camel's back, as it were.
 
DVC rental sites have existed for a long time. For many years, these seemed to mostly act as intermediaries between DVC members renting excess points and renters. IMO, these transactions are consistent with the spirit of rentals allowed by the POS.

However, "confirmed reservations" (a.k.a. spec renting) has really gotten out-of-control post COVID. Allegedly, a handful of former Disney employees have been part of business entities acquiring large numbers of DVC points for rent or encouraging DVC members to book rooms on speculation. Disproportionally, it appears these business entities are targeting the most in-demand (i.e. high margin) rooms.

In summary, the apparent brazen violation of the "personal use" clause seems to be a relatively recent phenomenon.
^^^ THIS 100%
 
Right, it is only one part of the things they can look at. I never said it was the sole thing that they are looking at, just that it could be the straw that breaks the camel's back, as it were.

And that is probably the fundamental difference here. Why would there need to be a deciding factor? The simpler the rules, the easier it is to apply, explain, and most importantly enforce.

When I say they can use it to flag it was only to put that membership on their radar.

It’s been said that those who could be renting commercially would be more likely to have those then this helps you filter better as to where to start.

But, on the other hand, if they use a simple number…like reservations that they determine is reasonable that it could be a commercial enterprise, then the rest doesn’t really matter in my view

And I have a feeling that is what they might be doing, deciding on how to look at large point owners and enforce the LLC /corporation clause because the board used the words “large point owners” several times at each of the meetings.

One could definitely walk away with the impression that those are the players they see as potentially issues.

But we also have to remember that they did say that this not a common practice among the membership.

Which tells me that whatever is coming is going to be in line with that level of thinking.
 
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I hope not. As an example, I had two villas booked for later this month (MLK weekend), one for my wife and daughter and I and another for a friend (with no payment). As it turns out, our friend was unable to travel due to a business trip. The points are February use year and we are well past the banking deadline, so I listed the reservation for our friend with DVC Rental Store at $15 per point, and someone purchased it. While some may consider this an "11 month spec rental", I hope that nobody would consider this to be a "pattern of commercial activity" that should not be permitted.
If you aren't doing this with a majority of you reservations, I absolutely dont think most people or Disney more importantly would consider this commercial.

Sticking with my original stance of commercial renters are very obvious who they are, they know who they are and Disney knows who they are, everyones fears here that they will make casual renting that their terms have always allowed are unwarranted imo
 
And that is probably the fundamental difference here.

When I say they can use it to flag is was only to put it on their radar.
And that means that there may be a member with the same amount of points and same amount of rentals at the same resort that doesn't get flagged only because they didn't have any of that particular type of reservations that they rented.

And then if the member who was flagged due to the specific rental reservations is found to have broken the rules while the other member wasn't even flagged for review?

Then the reservations did make the difference. The straw that broke the camel's back.
 
And that means that there may be a member with the same amount of points and same amount of rentals at the same resort that doesn't get flagged only because they didn't have any of that particular type of reservations that they rented.

And then if the member who was flagged due to the specific rental reservations is found to have broken the rules while the other member wasn't even flagged for review?

Then the reservations did make the difference. The straw that broke the camel's back.

Which proves my point…if the pattern of rental activity is based on quanative measure…which can look different when reviewed …then both members get flagged

I only suggested that one might flag by room type because you mentioned it.

If you and I both have 900 points and we both have 10 reservations, then we both are flagged.

If they look at my account and see in the past 12 months my 10 reservations are 300 points but none are high demand.

You do the same but all yours are high demand. Both of us are renting 300 out of 900 a year.

Do you really believe you should be called out for running a business and me not?

That is why I don’t think the type of room matters. Right now, when they want to clean up the market, and can see so many high demand rooms being rented, it might be something they decide to use to help find owners

But, isn’t it just easier to try to find those commercial renters by setting a number to start? no need to take to any farther.

Which is why I hope DVC never adopts any rules that doesnt set the pattern of rental activity based on the quantity of points being rented yearly and one that makes it clear you are in it for something other than vacation.

As long as renters can be under the personal use umbrella, they have to include some in that group as acceptable guests in any of those rooms.

If an owner can stay in a BWV rooms say 5 times a year, then I don’t see any way to say that an owner can’t put a renter in that same room 5 times a year.
 
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5.7 Except for Ownership Interests owned by DVD, rentals of Vacation Homes to the general public by any of The TWDC
Companies including DVD and BVTC, reservation or use of Vacation Homes and facilities of a DVC Resort is limited solely to the
personal use of Club Members, their guests, invitees, exchangers, and lessees and for recreational use by corporations or other similar
business entities owning Ownership Interests while staying as a registered guest at the DVC Resort. Except for any of The TWDC
Companies, purchase of an Ownership Interest and reservation or use of Vacation Homes and facilities of a DVC Resort for
commercial purposes or for any purpose other than personal use is expressly prohibited. BVTC shall be the sole determiner, in its
discretion, of any use or activity that does not constitute personal use or constitutes commercial use under this Agreement. Such
commercial purpose could include a pattern of rental activity of reserved Vacation Homes or frequent occupancy by others of reserved
Vacation Homes other than a Club Member or the Club Member's family; use of regular rental or resale advertising; creating,
maintaining, or frequent use of a rental or resale website
; repeated or frequent purchase and resale of Ownership Interests whether in
the name of a Club Member or those related to such Club Member or through the use of entities, partnerships, or trusts; or the
acquisition of a number of Ownership Interests in excess of the amount of the maximum permitted ownership whether in the name of a
Club Member or those related to such Club Member or through the use of entities, partnerships, or trusts.
This in the Riviera POS:

"Use of regular rental or resale advertising" is listed as one of the criteria by which "the Board or Management Company may conclude that an Owner is engaged in a commercial enterprise". It's part of a comma-separated list:
  • a pattern of rental activity of reserved Vacation Homes or frequent occupancy by others of reserved Vacation Homes, other than an Owner or the Owner's family
  • use of regular rental or resale advertising
  • maintaining a rental or resale website
  • frequent purchase and resale of Ownership Interests whether in the name of an Owner or those related to such Owner

The above points in bold apply to many people actively renting on social media outlets that I am aware of, if me, a nobody is aware of these 2 points about strangers on the internet then 100% Disney knows who these individuals are, regardless if they hold the contract in the name of an LLC or various Trusts.
One of the few things that I'd actually bet cash money on is that, at least for the foreseeable future, if Disney chooses to attack rentals, it'll only go after owners whose activity is unquestionably commercial by pretty much every definition we're considering here. I don't think they're interested in wading into the middle ground where the question of how much they can restrict probably lies in how deferential a court would be to a consumer vs. the large corporation when interpreting the contract.

Yep and once its starts happening those who rent mostly for profit will likely ramp down their enterprises without Disney having to send them "the letter"
 
5.7 Except for Ownership Interests owned by DVD, rentals of Vacation Homes to the general public by any of The TWDC
Companies including DVD and BVTC, reservation or use of Vacation Homes and facilities of a DVC Resort is limited solely to the
personal use of Club Members, their guests, invitees, exchangers, and lessees and for recreational use by corporations or other similar
business entities owning Ownership Interests while staying as a registered guest at the DVC Resort. Except for any of The TWDC
Companies, purchase of an Ownership Interest and reservation or use of Vacation Homes and facilities of a DVC Resort for
commercial purposes or for any purpose other than personal use is expressly prohibited. BVTC shall be the sole determiner, in its
discretion, of any use or activity that does not constitute personal use or constitutes commercial use under this Agreement. Such
commercial purpose could include a pattern of rental activity of reserved Vacation Homes or frequent occupancy by others of reserved
Vacation Homes other than a Club Member or the Club Member's family; use of regular rental or resale advertising; creating,
maintaining, or frequent use of a rental or resale website
; repeated or frequent purchase and resale of Ownership Interests whether in
the name of a Club Member or those related to such Club Member or through the use of entities, partnerships, or trusts; or the
acquisition of a number of Ownership Interests in excess of the amount of the maximum permitted ownership whether in the name of a
Club Member or those related to such Club Member or through the use of entities, partnerships, or trusts.


The above points in bold apply to many people actively renting on social media outlets that I am aware of, if me, a nobody is aware of these 2 points about strangers on the internet then 100% Disney knows who these individuals are, regardless if they hold the contract in the name of an LLC or various Trusts.


Yep and once its starts happening those who rent mostly for profit will likely ramp down their enterprises without Disney having to send them "the letter"

This is honestly what I expect them to do. Go after the LLC and corporations that the contract already prohibits rentals.

It’s easy for them to do and once they do, I think the only other ones are going to be your large point owners who have reached that 8000 limit or close to it and it’s evident they are renting too.

Other than that, I will be surprised to see much else and I also will be surprised if they don’t use this as the solution to walking too and say that by reducing this, it eliminates the main reasons people walk.

And of course, I can be 100% wrong and they make me file a complaint against them!!! lol
 
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It would be like saying that someone who owns a condo at the beach and has oceanfront can be held to a different standard then one who is not when the units are in the same building.

Down the shore many of the beach front condos have update notices posted explaining the stricter dates, some needing guest certificates and others that won’t even accept guest certificates. An owner who rented in the high demand time can say it feels unfair that owners using the condo for personal use during the high demand time and renting out low demand times were not impacted the same as they were.

The changes were made to protect the association/membership from negative impacts brought from the pattern of rentals, so it makes sense the approach includes the problem area.

Not exactly the same, similar to the rooms at BWV. If people are owning Boardwalk just to rent out standard all the time? No. As an owner I’d happily give up my ability to rent Standard View* —if— it meant that somehow DVC enforced commercial use prohibited so that at least those rooms get filled with a higher ratio of owners and their friends/family than they do today. Because as a BWV owner what I really wouldn’t like to know is somebody buying a different resort to use for themselves and the BWV just to rent to pay for the trips at that other resort.

*I realize that wouldn’t actually happen, that there’s no way for them to say one rental crosses a line, but I really would give it up. As long as there were still avenues left for me to rent out excess points on occasion should the need occur that helped offset the cost of our unused points, that is plenty. I could totally live with renting out Pool/Garden. But then again I’m not looking at it from trying to maximize the money possible from renting.

And, if I am understanding that new 2021 condo law, DVC using room type as a clarifier might be seen as a new restriction and thus can’t be included without a vote and even then, owners don’t have to abide.

I don’t remember any clarifiers on the original contracts. It’s pretty vague. Does that leave DVC with nothing they can legally use? They don’t mention numbers of rentals or percentages either.
 
The above points in bold apply to many people actively renting on social media outlets that I am aware of, if me, a nobody is aware of these 2 points about strangers on the internet then 100% Disney knows who these individuals are, regardless if they hold the contract in the name of an LLC or various Trusts.
And that's why I bolded them in my earlier post. There's a really good reason they made that change and utilized that very specific language. There is zero chance they are not aware that individuals or consortiums are buying up contracts under the cover of multiple legal entities, in order to circumvent points maximums, engage in commercial rental activity, and to operate buy, strip, and flip schemes.

As to flippers (not the subject of this thread, but something else worthy of discussion possibly elsewhere) keep in mind that the first bolded section actually reads in its entirety:
Such commercial purpose could include a pattern of rental activity of reserved Vacation Homes or frequent occupancy by others of reserved Vacation Homes other than a Club Member or the Club Member's family; use of regular rental or resale advertising; creating,
maintaining, or frequent use of a rental or resale website; repeated or frequent purchase and resale of Ownership Interests whether in
the name of a Club Member or those related to such Club Member or through the use of entities, partnerships, or trusts
; or the
acquisition of a number of Ownership Interests in excess of the amount of the maximum permitted ownership whether in the name of a
Club Member or those related to such Club Member or through the use of entities, partnerships, or trusts.
So DVC also sees the very real potential for flippers to be engaged in commercial renting (or more specifically purchasing loaded contracts with the primary intent of stripping them, then commercially renting out the points prior to reselling). It's clearly an association/connection DVC has made, based on whatever data they possess. That phrase is a specific reference to purchasing and reselling contracts (flipping) in a paragraph otherwise solely dedicated to renting. The phrase afterwards addresses buying multiple contracts to circumvent points maximums, but that "frequent purchase and resale" phrase specifically relates to flipping.

When you look at "creating, maintaining, or frequent use of a rental or resale website" in conjunction with "repeated or frequent purchase and resale of Ownership Interests whether in the name of a Club Member or those related to such Club Member or through the use of entities, partnerships, or trusts", it sure smells like Disney thinks there are some shenanigans going on with online brokers as well...
 
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show me how making changes will make the quarter to quarter profits better and I will believe that they will take action
If DVC believes the rental market is hampering direct sales, then that’s one potential justification for doing something about it.

Or to put it another way: why did Wyndham and Bluegreen actually spend money going after some renters? They have much less of a retail rental presence, yet they believed the effort to curtail renting was in their best interests.
 
Down the shore many of the beach front condos have update notices posted explaining the stricter dates, some needing guest certificates and others that won’t even accept guest certificates. An owner who rented in the high demand time can say it feels unfair that owners using the condo for personal use during the high demand time and renting out low demand times were not impacted the same as they were.

The changes were made to protect the association/membership from negative impacts brought from the pattern of rentals, so it makes sense the approach includes the problem area.

Not exactly the same, similar to the rooms at BWV. If people are owning Boardwalk just to rent out standard all the time? No. As an owner I’d happily give up my ability to rent Standard View* —if— it meant that somehow DVC enforced commercial use prohibited so that at least those rooms get filled with a higher ratio of owners and their friends/family than they do today. Because as a BWV owner what I really wouldn’t like to know is somebody buying a different resort to use for themselves and the BWV just to rent to pay for the trips at that other resort.

*I realize that wouldn’t actually happen, that there’s no way for them to say one rental crosses a line, but I really would give it up. As long as there were still avenues left for me to rent out excess points on occasion should the need occur that helped offset the cost of our unused points, that is plenty. I could totally live with renting out Pool/Garden. But then again I’m not looking at it from trying to maximize the money possible from renting.



I don’t remember any clarifiers on the original contracts. It’s pretty vague. Does that leave DVC with nothing they can legally use? They don’t mention numbers of rentals or percentages either.

I think I figured a away to explain my understanding…and I realize it could by wrong against what DVC thinks…

The pre RIV resorts usse only the words a “pattern of rental activity that can reasonably conclude one is using their membership as a commercial enterprise.

That is as a business. Since that is the requirement and the only specific way they mentioned was a pattern of rental activity, then those two things must be there when accusing an owner of violating the contract.

Given the right to rent is material to our ownership since it’s a condominium, DVD can’t change the contract unilaterally if it’s a material change to the declaration.

IMO, to rise to the level of being a commercial enterprise there has to be a level of renting happening that one can reasonably conclude makes you one…whether it is number of reservations, number of points, or combination of both, I do believe that how many points are getting rented each year must be high in relation to what you own to reasonable conclude it’s a business…again, I’m addressing pre RIV resorts

And the 2008 interpretation by DVC for owners lends support to that line of my thinking because they identified that if an owner was reaching 20 reservations a year, it was likely they were a business, unless one could prove you were not.

I do think DVC is prohibited from determining whether you have violated the terms because you are renting certain rooms if you don’t also reach that quantitative level that draws a reasonable conclusion you are a business, which I content has to be high in relation to what you own.

For RIV and beyond, because they specifically state they can use other things to determine it’s a business, then for those owners IMO they can legally lower that threshold.

With the pre RIV resorts, where the discretion comes into plays is in not setting a hard and fast rule like the “20” because that can easily be gotten around by someone who is attempting to be a business.

For example, you have 2000 points and you never rent reservations for less than 150 points,,,you’ll never hit that 20 but if you are using most of those points yearly for rentals. it’d say DVC. has a case.

Let’s say that you are one of those owners who has the 4000 points and decide to rent 1000 every year to offset the dues…if you do a lot of one or two night rentals, you might end up with a lot more than 20 reservations but I don’t think it’s reasonable for DVC to conclude you are running a business when that amounts to renting only 25% if your ownership each year.

So, that’s where I think they get to use discretion..,apply different values to each membership based on the actual situation vs a hard and fast,,it’s 20 reservations or it’s not.

But, no matter what they do, for the pre RIV resorts, I do not believe they can lower the standard for determine you are a commercial enterprise because you rent rooms that are high demand, even if every one is a high demand one and every date of the rental falls within a high demand time.

Take a RIV owner,, and it’s different… if they see you setting up say a FB page to advertise a lot of your points they can use that along with how many points got rented.

The threshold for how many points isn’t as critical any longer because the contract defined setting up a website as a qualifier..and they could conclude a FB page fits.

IMO, I believe this was done so they can go after situations like this that they know would get them in legal trouble for the pre RIV resorts.

ETA: to speculate, even further. think that the reasons they have added resources to Yvonne’s team is so that they can reevaluate what quantitative values they can choose to apply to memberships as well as use those resources to ramp up review of memberships and enforcement.

It’s also why I don’t think those owners who have less than 2000 points even have to worry, especially if you own at a pre RIV resort.

But, I admit that if they really want to, they could go after small point owners as well.
 
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If DVC believes the rental market is hampering direct sales, then that’s one potential justification for doing something about it.

Or to put it another way: why did Wyndham and Bluegreen actually spend money going after some renters? They have much less of a retail rental presence, yet they believed the effort to curtail renting was in their best interests.
The managing entity has a fiduciary responsibility to manage the timeshare in the best interests of the timeshare owners as a whole. The managing entity is responsible, for example, for making repairs, dealing with rowdy guests, preventing facilities from being used by non-owners, etc.

In this instance, some owners allegedly are violating the rules of the POS to the detriment of owners as a whole.

Of course, Disney’s fiduciary responsibilities can overlap with corporate Disney’s financial goals. 😉
 
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Nah. Basically every other timeshare developer has a resale market worth $0 and they still sell developer points just fine.
That line of thinking is bonkers to me. None of those other developers are also a lifestyle brand that wants you to see their movies, pay for their streaming service, go to their theme parks, etc.
 
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