# Rent Collection & Delinquency Manager Research

## Purpose

- Supports `skills/asset-management/rent-collection-delinquency-manager.md` (v1.3.0 Asset Management pack)
- Intended for multifamily asset managers, AR managers, and portfolio operators running stabilized conventional 5+ unit properties who need a defensible framework for A/R aging triage, bad-debt reserving, eviction sequencing, and hardship-program administration
- Extends (does NOT contradict) `knowledge/multifamily-benchmarks.md` Bad Debt Ratio benchmark (KPI table: <1% strong / 1-3% average / >3% weak) and `research/asset-management/_taxonomy-seed.md` §5 A/R Aging Bands
- Complements but stays out of the lane of: R4 lease-renewal retention, R5 lease-up collections during stabilization, R8 disposition-level write-off treatment

## U.S.-Only Assumptions

- Geography is the United States; state eviction statutes cited are U.S. landlord-tenant codes
- Asset class is conventional stabilized multifamily (5+ units); LIHTC / Section 8 / public housing collections are governed by separate HUD administrative regulations and are out of scope
- Property management platforms referenced are the U.S. institutional leaders: Yardi Voyager, RealPage OneSite, AppFolio Property Manager, Entrata
- REIT 10-K and supplemental disclosures referenced are U.S. publicly traded apartment REITs (Equity Residential, AvalonBay, Mid-America Apartment Communities, Camden, Essex, UDR)
- Assumes post-COVID moratorium environment (federal CDC moratorium expired August 2021; most state/local moratoria expired 2021-2023) and Risk Rating 2.0-era insurance backdrop
- Reserve-methodology %s are ASC 326 CECL-compatible but not a substitute for operator-specific allowance policy

## Source Table

| Source | Publisher | URL | Publish Date | Access Date | Source Type | Notes |
|--------|-----------|-----|--------------|-------------|-------------|-------|
| Equity Residential 2023 Form 10-K (Item 8 Notes to Consolidated Financial Statements — allowance for doubtful accounts, residential bad debt narrative) | Equity Residential (SEC EDGAR) | https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&CIK=0000906107&type=10-K | 2024-02 | 2026-04-24 | Primary (SEC filing) | REIT-level bad-debt disclosure; Class A coastal portfolio benchmark |
| AvalonBay Communities 2023 Form 10-K (allowance for uncollectible amounts, residential revenue recognition) | AvalonBay Communities (SEC EDGAR) | https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&CIK=0000915912&type=10-K | 2024-02 | 2026-04-24 | Primary (SEC filing) | REIT-level bad-debt and uncollectible lease revenue; high-barrier coastal |
| Mid-America Apartment Communities (MAA) 2023 Form 10-K (revenue recognition, uncollectible lease revenue) | MAA (SEC EDGAR) | https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&CIK=0000912595&type=10-K | 2024-02 | 2026-04-24 | Primary (SEC filing) | Sun Belt Class A/B bad-debt benchmark |
| Camden Property Trust 2023 Form 10-K | Camden Property Trust (SEC EDGAR) | https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&CIK=0000906345&type=10-K | 2024-02 | 2026-04-24 | Primary (SEC filing) | Sun Belt + mid-Atlantic operator bad-debt benchmark |
| 2024 NMHC 50 / NMHC Apartment Strategies Outlook (delinquency trend data; post-moratorium bad-debt normalization) | National Multifamily Housing Council | https://www.nmhc.org/research-insight/ | 2024 (rolling) | 2026-04-24 | Institutional industry association | Bad-debt ratio benchmarking; policy guidance; paywall for full NMHC 50 list — summary data is public |
| NAA 2024 Survey of Operating Income & Expenses (bad debt as a line item; collection losses by region) | National Apartment Association | https://naahq.org/survey-operating-income-expenses | 2024 | 2026-04-24 | Institutional industry association | Bad-debt / uncollected rent benchmarking (paywall for full report; summary figures public) |
| Every Landlord's Legal Guide (32nd ed.) and state-by-state eviction/notice tables | Nolo | https://www.nolo.com/legal-encyclopedia/evictions-landlords-tenants | 2024 (rolling updates) | 2026-04-24 | Tier 3 legal reference (secondary) | State notice-period, filing-to-judgment, writ-of-possession timelines |
| Texas Property Code Chapter 24 (Forcible Entry & Detainer) + Texas Rules of Civil Procedure Rule 510 | Texas Legislature Online / Texas Judicial Branch | https://statutes.capitol.texas.gov/Docs/PR/htm/PR.24.htm | 2023 (statute codified) | 2026-04-24 | Primary (state statute) | TX 3-day notice, justice-court filing, 5-day writ timeline |
| Florida Statutes Chapter 83 Part II (Florida Residential Landlord & Tenant Act) | Florida Legislature | http://www.leg.state.fl.us/Statutes/index.cfm?App_mode=Display_Statute&URL=0000-0099/0083/0083ContentsIndex.html | 2023 (statute codified) | 2026-04-24 | Primary (state statute) | FL 3-day notice, summons timeline |
| California Code of Civil Procedure §§1161-1179a (Unlawful Detainer) + AB 2347 (2024 amendments extending tenant response time) | California Legislative Information | https://leginfo.legislature.ca.gov/ | 2024 (AB 2347 eff. 1/1/2025) | 2026-04-24 | Primary (state statute) | CA 3-day pay-or-quit; 10 business-day answer (post AB 2347); sheriff lockout timing |
| New York Real Property Actions and Proceedings Law (RPAPL) Articles 7 & 13 + Housing Stability and Tenant Protection Act of 2019 | New York State Legislature | https://www.nysenate.gov/legislation/laws/RPA | 2019 (HSTPA) | 2026-04-24 | Primary (state statute) | NY 14-day demand; holdover vs nonpayment distinction; post-HSTPA longer timelines |
| Georgia Code Title 44 Chapter 7 (Landlord and Tenant — Dispossessory Proceedings) O.C.G.A. §44-7-50 et seq. | Georgia General Assembly | https://law.justia.com/codes/georgia/2022/title-44/chapter-7/ | 2022 (codified) | 2026-04-24 | Primary (state statute) | GA immediate demand, 7-day answer window, fastest eviction in major markets |
| Arizona Revised Statutes §33-1368 (Arizona Residential Landlord & Tenant Act — noncompliance/nonpayment) | Arizona State Legislature | https://www.azleg.gov/ars/33/01368.htm | 2023 (codified) | 2026-04-24 | Primary (state statute) | AZ 5-day pay-or-quit; special-detainer action timeline |
| Nevada Revised Statutes §§40.253-40.254 (Summary Eviction) | Nevada Legislature | https://www.leg.state.nv.us/NRS/NRS-040.html | 2023 (codified) | 2026-04-24 | Primary (state statute) | NV summary 7-day pay-or-quit; tenant-response-driven timeline (unique in US) |
| North Carolina General Statutes Chapter 42 Article 3 + Article 4 (Summary Ejectment) | North Carolina General Assembly | https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/ByChapter/Chapter_42.html | 2023 (codified) | 2026-04-24 | Primary (state statute) | NC 10-day grace / demand; magistrate court small-claims-track timeline |
| CDC Eviction Moratorium Order (Agency Order) + Alabama Association of Realtors v. HHS (594 U.S. ___ (2021)) | U.S. Centers for Disease Control / U.S. Supreme Court | https://www.supremecourt.gov/opinions/20pdf/21a23_ap6c.pdf | 2021-08 (SCOTUS) | 2026-04-24 | Primary government / judicial | Federal moratorium sunset date Aug 26, 2021; baseline for post-moratorium bad-debt normalization |
| Eviction Lab Moratorium Scorecard / State-Local Tracker | Princeton University Eviction Lab | https://evictionlab.org/ | 2023 (final tracker update) | 2026-04-24 | Institutional academic | State/local moratorium expiration dates; filing-rate data during/after moratoria |
| Equifax / TransUnion Rental-Applicant Scoring & Collection-Probability Data (commercially published industry note) | Equifax / TransUnion SmartMove | https://www.mysmartmove.com/ | 2024 | 2026-04-24 | Quasi-primary vendor research | Collection probability by days past due; skip rates by credit band (paywall for full detail) |
| Yardi Voyager / Yardi Breeze documentation — Resident Aging Report default bands | Yardi Systems (product documentation) | https://www.yardi.com/ | 2024 | 2026-04-24 | Quasi-primary platform source | Default aging schema (Current / 0-30 / 31-60 / 61-90 / 90+) |
| RealPage OneSite / AR Aging configuration guide | RealPage | https://www.realpage.com/ | 2024 | 2026-04-24 | Quasi-primary platform source | Configurable aging bands; collections-workflow triggers |
| AppFolio Property Manager — Delinquency & Collections product documentation | AppFolio | https://www.appfolio.com/ | 2024 | 2026-04-24 | Quasi-primary platform source | AR aging thresholds; collection notice automation |
| Entrata Platform — AR Aging & Delinquency Tools | Entrata | https://www.entrata.com/ | 2024 | 2026-04-24 | Quasi-primary platform source | AR aging bands; integrated collections notices |
| Camden Property Trust Customer Bill of Rights / Hardship Policy (public-facing) | Camden Property Trust | https://www.camdenliving.com/ | 2024 | 2026-04-24 | Quasi-primary operator policy | Published hardship-flex policy framework for REIT-operated portfolio |
| CFPB Debt Collection Rule (Regulation F, 12 CFR Part 1006) | Consumer Financial Protection Bureau | https://www.consumerfinance.gov/rules-policy/final-rules/debt-collection-practices-regulation-f/ | 2021 (eff. 11/30/2021) | 2026-04-24 | Primary government regulation | Collection-agency referral compliance framework |
| Fair Debt Collection Practices Act (15 USC §1692 et seq.) | U.S. Congress | https://www.ftc.gov/legal-library/browse/rules/fair-debt-collection-practices-act-text | 1977 (as amended) | 2026-04-24 | Primary federal statute | Third-party collection-agency governance |
| FASB ASC 326 (Current Expected Credit Loss — CECL) — Measurement of Credit Losses on Financial Instruments | Financial Accounting Standards Board | https://asc.fasb.org/ | 2016 (eff. 2020 for SEC filers) | 2026-04-24 | Primary accounting standard | Reserve-methodology framework for operating-lease receivables (paywall for codification; summaries public) |
| NCREIF PUR (Property Universe Report) — Apartment Delinquency / Collection Loss metrics | NCREIF | https://www.ncreif.org/ | 2024 | 2026-04-24 | Institutional industry data | Institutional-portfolio collection-loss benchmark (paywall for member data) |

## Key Findings

- **Aging-band convergence is real but not universal.** All four major PMS platforms (Yardi, RealPage, AppFolio, Entrata) default to the canonical 5-band schema (Current / 1-30 / 31-60 / 61-90 / 90+). REITs, however, frequently use a 4-band schema (Current / 1-30 / 31-60 / 60+) in their 10-K disclosures and internal portfolio reports because the distinction between 61-90 and 90+ is largely irrelevant once eviction is already filed. The taxonomy seed §5 correctly instructs downstream skills to treat 60+ at 90+ reserve rates when the data source provides only a combined bucket — this is the operationally correct conservatism.
- **Bad-debt benchmarks by class, post-moratorium.** The taxonomy seed ranges (A 0.5-1.0%, B 1.0-1.5%, C 1.5-2.5%, Affordable 2.0-3.0%) are consistent with REIT 10-K-disclosed uncollectible lease revenue for 2023: MAA and Camden (predominantly Class A/B Sun Belt) reported uncollectible-revenue rates in the 0.5-1.2% range, while Equity Residential and AvalonBay (coastal Class A) normalized toward 0.5-0.9% by year-end 2023. NAA 2024 I/E data for broader Class B and Class C (including non-REIT owners) shows a higher 1.0-2.0% range. Affordable operators (LIHTC + unsubsidized workforce) report 2.0-3.5% because of the income-volatility profile of the resident base. **Key caveat:** 2021-2022 REIT bad-debt ratios were abnormally high (2-4%+ in some coastal portfolios) due to residual moratorium-era receivables being written off — do not use 2021-2022 figures as a steady-state benchmark.
- **Eviction timeline bifurcation.** There is a roughly 3x variance between fastest-eviction and slowest-eviction states. Fast-track states (GA, TX, AZ, FL, NC) can complete an uncontested nonpayment eviction in 3-6 weeks from first past-due day to writ-of-possession execution. Slow-track states (CA, NY, NJ, MA, WA) routinely take 90-180+ days, with NY post-HSTPA often exceeding 6 months even uncontested. This variance is the single most important input to hardship-policy design and reserve calibration.
- **Hardship-policy norms have institutionalized post-COVID.** All major REITs (EQR, AVB, MAA, CPT, UDR) now publish some form of hardship framework — typically (a) 3-5 day grace period before late fee, (b) written payment-plan option for partial-payment tenants in 31-60 aging before eviction filing, (c) deposit-waiver alternatives through third-party surety products (e.g., Rhino, Jetty, LeaseLock), and (d) repayment-plan documentation that tolls the eviction clock. NMHC's post-moratorium guidance recommends codifying these as written policy rather than ad-hoc discretion, both for Fair Housing Act compliance and collection-consistency.
- **Partial-payment acceptance is the single highest-leverage policy choice.** Under common-law contract doctrine and many state statutes, accepting a partial payment after serving a pay-or-quit notice can **waive** the eviction and restart the clock. The operator must either (i) refuse partial payment entirely, (ii) accept with a signed non-waiver addendum, or (iii) convert to a written payment plan that toll the notice. Most REIT policy memos explicitly instruct site teams to refuse partial payment once a Notice to Pay or Quit has been served, unless converted to a formal payment plan.
- **Collection-agency referral threshold is NOT uniform.** REITs typically refer to third-party collection agencies at 60-90 days post-move-out (not post-first-delinquency) with balances >$500. Smaller operators refer at 90-120 days. Commercial Collection Agency Association data (cited in NetSuite source in taxonomy seed) shows collection probability drops to ~73% at 90 days past due and <50% at 6 months — the economic case for faster referral is strong.
- **Skip/abandonment rates vary ~4x by class.** Institutional tracking (Equifax/TransUnion SmartMove and REIT-disclosed move-out data) shows skip rates of roughly 0.5-1.0% of move-outs in Class A, 1.5-3.0% in Class B, 3.0-6.0% in Class C, and 5-10%+ in deep-value-add / distressed repositioning. Skip is defined as vacate without proper notice and with unpaid balance; it accelerates write-off to the 90+ bucket regardless of calendar aging.
- **Chronic vs one-off delinquency must be classified operationally, not just statistically.** A tenant with a single 15-day late payment in 12 months is one-off (retain, no extraordinary action). A tenant with 3+ late payments in 12 months, OR 2+ NSF events, OR any 60+ aging is chronic (do not offer lease renewal; consider non-renewal at lease end; monitor aging weekly). REITs disclose chronic-delinquency cohort rates of 5-15% of the resident base; managing this cohort to exit is one of the largest NOI levers in stabilized AM.
- **Eviction moratorium overhang persists in specific jurisdictions.** Although the federal CDC moratorium ended Aug 26, 2021, residual state/local protections (NY's ERAP backlog, CA's AB 832 residuals, DC's eviction moratoria extensions) continued to affect filings into 2023. These distort T-24 bad-debt data for properties in those markets; underwriters should use T-12 from 2023 forward as the cleanest post-moratorium baseline.
- **Reserve methodology by aging band is simple to state but contested in application.** The taxonomy-seed bands (1% / 5-10% / 10-15% / 15-20% / 40-50%) are consistent with CCAA-published collection-probability inverses and with institutional servicer practice. CECL (ASC 326) requires entities to use historical loss experience as the starting point and adjust for current conditions and reasonable forecasts — the %s above are a reasonable starting point but a CECL-compliant operator must support them with its own loss history and forecast assumptions.

## Benchmark and Formula Decisions

- **Adopt the taxonomy seed §5 aging bands verbatim.** Current / 1-30 / 31-60 / 61-90 / 90+, with reserve %s 1% / 5-10% / 10-15% / 15-20% / 40-50%. Do not invent an alternative schema.
- **Bad-debt ratio definition.** `Bad Debt Ratio = Uncollected Rent / Gross Potential Rent`. Use the taxonomy-seed §2 formula. Report separately from concession drag and vacancy loss.
- **Benchmark ranges to publish in the skill's decision tables:**
  - Class A: 0.5-1.0% (strong <0.5%, watch >1.0%)
  - Class B: 1.0-1.5% (strong <1.0%, watch >1.5%)
  - Class C: 1.5-2.5% (strong <1.5%, watch >2.5%)
  - Affordable / workforce: 2.0-3.0% (strong <2.0%, watch >3.0%)
  - Regional overlay: Sun Belt moderate-income markets +0.25-0.75% on the class baseline; coastal gateways -0.25% (higher-income resident base)
- **Eviction-timeline reference table (to be included in the skill).** Sourced from state statute + Nolo state pages. Provide notice-period → filing-to-judgment → judgment-to-writ as three columns. Round to ranges, not point estimates, because court-calendar congestion dominates in slow states:

| State | Notice Period (nonpayment) | Filing → Judgment (uncontested) | Judgment → Writ / Lockout | Total (typical) |
|---|---|---|---|---|
| Georgia | Immediate demand on default (no statutory wait) | 7-14 days | 7 days | 2-4 weeks |
| Texas | 3 days | 10-14 days | 5 days | 3-5 weeks |
| Arizona | 5 days | 3-6 days (special detainer) | 5 days | 2-4 weeks |
| Florida | 3 days (excluding weekends/holidays) | 2-3 weeks | 24 hours-1 week | 4-6 weeks |
| North Carolina | 10-day demand (Art. 3) | 2-3 weeks | 10 days | 4-7 weeks |
| Nevada | 7-day pay-or-quit (summary) | Tenant-response driven (5 days to answer) | 24 hours-1 week | 3-5 weeks |
| California (post AB 2347) | 3 days pay-or-quit | 30-60 days (10 business-day answer + trial set) | 5-15 days (sheriff lockout) | 45-90+ days |
| New York (post-HSTPA) | 14-day demand | 60-120+ days | 14 days + marshal queue | 90-180+ days |

- **Reserve methodology.** Apply taxonomy-seed §5 reserve percentages to each aging bucket balance and sum. Do not additionally reserve on the full GPR — the aging reserve replaces, not supplements, a gross bad-debt accrual. For CECL-compliant operators, this is the "specific reserve" — a pooled/aggregate overlay may be added if historical loss experience demonstrates residual uncollectibility beyond the aging reserve.
- **Warning threshold.** Adopt taxonomy-seed threshold: if >20-25% of total receivables are past-due (any bucket beyond Current), flag collections problem to ownership.
- **Split-aging rule.** Adopt taxonomy-seed split-aging rule verbatim: apply the decision action for the oldest band in which the tenant has >=$100 balance; report each band separately.
- **Chronic delinquency classification (operational).** Flag tenant as chronic-delinquent if ANY of: (i) 3+ late payments in trailing 12 months, (ii) 2+ NSF events in trailing 12 months, (iii) any aging >60 days in trailing 12 months. Output: do not offer lease renewal at current market rent (either non-renew, or renew only at market rent + late-fee escalator + month-to-month premium).
- **Collection-agency referral threshold.** Refer to licensed collection agency when (a) tenant has vacated (voluntary, abandonment, or post-eviction), AND (b) balance ≥$500, AND (c) 30+ days have elapsed since move-out with no payment plan in force. This is the institutional norm; smaller operators may wait to 60-90 days post-move-out.
- **Hardship-policy minimum framework (to be recommended by the skill).** Codify in writing: (a) 3-day grace before late fee; (b) payment-plan option available for any resident in 31-60 aging who has not yet received pay-or-quit, with signed documented plan, typically 2-3 installments over 30-60 days; (c) non-waiver addendum required for ALL partial-payment acceptance once pay-or-quit has been served; (d) hardship-plan approval logged and applied consistently across the resident base to satisfy Fair Housing Act disparate-impact review.

## Conflicting Source Resolution

- **REIT bad-debt disclosures vs NAA industry-wide data.** REIT 10-Ks consistently report lower bad-debt (0.5-1.2% range) than NAA I/E (1.0-2.0% Class B / 1.5-2.5% Class C) because REITs concentrate in higher-class newer product with tighter screening. Use the class-specific taxonomy-seed ranges, not a single industry average, for underwriting.
- **Yardi/RealPage 5-band default vs REIT 4-band reporting.** Use the 5-band schema for operational aging reports (follows the PMS default, preserves granularity). Use the 4-band schema only when interfacing with REIT-format supplementals. Apply the taxonomy-seed mechanical rule: if source data is only 4-band (60+), treat 60+ at the 90+ reserve rate for conservatism.
- **Nolo state summaries vs state statute direct reads.** Nolo state pages are compiled but occasionally lag statutory amendments by 6-12 months (notably CA AB 2347 effective 1/1/2025 was not reflected in some Nolo tables for several months). Where Nolo and state statute conflict, **state statute wins** and Nolo is used for illustrative/narrative framing only.
- **"Days to evict" marketing numbers vs operational reality.** Eviction service providers (Hemlane, Avail, Landlord Law) publish optimistic end-to-end timelines assuming uncontested cases and no scheduling delays. Actual court-calendar congestion in LA, NYC, and Cook County IL routinely adds 30-90 days. Use the ranges in the decision table (not point estimates) to reflect court congestion reality.
- **CECL reserve %s vs taxonomy-seed pack defaults.** The pack defaults (1% / 5-10% / 10-15% / 15-20% / 40-50%) align with CCAA collection-probability data but are not a CECL-compliant substitute. For CECL-reporting entities, the taxonomy-seed %s are a reasonable starting point; the operator's own loss history and adjusted forward-looking factors must ultimately govern. The skill should output both the pack-default reserve AND a placeholder for operator-specific CECL overlay.
- **Partial-payment acceptance doctrine vs operational reality.** Site teams frequently accept partial payments without non-waiver language, which can and does undermine subsequent eviction filings. Where operator policy permits partial payment, the skill must enforce the non-waiver-addendum requirement and flag any partial payment accepted after service of pay-or-quit as a legal-risk event requiring counsel review.

## Edge Cases and Red Flags

- **Security deposit offset is NOT a pre-eviction tool.** Applying security deposit to current-month rent (instead of to post-move-out damages/unpaid rent) is permitted in some states but not others, and can extinguish the basis for the unpaid-rent eviction filing. Require counsel review before netting deposit against in-place rent.
- **Rent-control and just-cause jurisdictions.** In CA (AB 1482 statewide + local), NJ, OR (statewide), NY (HSTPA), and select municipalities (Portland, Seattle, St. Paul, Berkeley, Santa Monica, Oakland, Mt. Vernon, Kingston, etc.), non-renewal of a chronic-delinquent tenant may require a just-cause showing. Chronic nonpayment is almost always a valid just cause, but requires documented pay-history evidence; the skill should instruct operators in these jurisdictions to preserve payment-history documentation BEFORE deciding not to renew.
- **ERAP (Emergency Rental Assistance Program) residual balances.** Some markets (NY, NJ, DC, IL) still have ERAP payments in process into 2024-2025 for pre-2023 arrears. An aged balance showing in the 90+ bucket may actually be covered by a pending ERAP application; the skill should require confirmation that no ERAP application is in-process before writing off a 90+ balance or referring to collections.
- **Partial-payment waiver trap (reiterated from Key Findings — this is a field-recurring failure mode).** The single most common legal failure in multifamily collections is site-team acceptance of partial payment after pay-or-quit service without non-waiver documentation, which voids the eviction. Flag in the skill output.
- **Skip diagnosis ambiguity.** A tenant who stops paying and stops communicating may be skip OR merely unresponsive. Some states (TX, AZ) have statutory presumption-of-abandonment rules after a period of non-occupancy; others do not. Do not assume abandonment without the statutory trigger — entering a unit without proper notice or process can create a self-help-eviction liability that dwarfs the unpaid rent.
- **Co-signer / guarantor collection.** When the lease has a guarantor (common in student, young-professional, and some affordable settings), post-move-out collection can pursue the guarantor directly under FDCPA. Confirm guarantor is documented in lease file BEFORE referring to collection agency — retroactive guarantor "discovery" does not work.
- **Moratorium-era writeoffs rebooking.** Some operators wrote off large 2020-2021 balances directly to bad debt; others capitalized them as long-term receivables. Comparing bad-debt ratios across portfolios requires understanding the operator's 2021-2022 writeoff convention. Use 2023+ T-12 for cleanest apples-to-apples benchmarking.
- **LeaseLock / Rhino / Jetty / third-party surety.** Deposit-alternative surety products have grown rapidly since 2020 and are now at 15-40%+ adoption in Class A portfolios. These shift bad-debt risk to the surety (within coverage limits, typically 1-2x monthly rent). Bad-debt ratios at properties using surety products will read lower than otherwise-comparable properties because the surety absorbs a slice of bad debt. Note this in skill output when benchmarking.
- **Payment-plan enforcement without proper documentation.** A verbal payment plan does not toll the eviction clock in most states. Require signed written plan before suspending a filed or noticed eviction.
- **Fair Housing Act disparate-impact review.** Hardship-flex discretion must be applied consistently across protected-class tenants. Ad-hoc site-team discretion ("gave Mrs. Smith 2 weeks because she's nice") without written policy creates disparate-impact liability. The skill should recommend documented hardship-approval criteria and a decision log.
- **Collection-agency compliance (FDCPA + Reg F).** Third-party agencies must comply with Regulation F (CFPB, effective 11/30/2021), including the 7-in-7 communication cap and validation-notice requirements. Operators retain vicarious-compliance risk if they select non-compliant agencies. Recommend the skill flag agency-selection as a compliance-review point.

## Open Questions

- Whether future versions of the skill should include a **CECL-compliant reserve calculation helper** that ingests operator-specific T-24 aging roll-forward data and outputs a FASB-compliant allowance estimate (current version uses pack-default %s only)
- Whether **state-specific eviction-timeline data should be expanded** beyond the 8 major multifamily states to include all 50 states (current version covers ~75% of U.S. institutional multifamily inventory by unit count)
- Whether **hardship-policy language templates** should be included as skill output (e.g., ready-to-adopt payment-plan agreement, non-waiver addendum, hardship-approval decision log template) or whether that crosses into legal-document territory requiring counsel review
- Whether the skill should model **surety-product-adjusted** bad-debt ratios separately from cash-deposit-adjusted ratios when comparing across operator portfolios
- Whether future versions should integrate with specific PMS **API endpoints** (Yardi Orion / RealPage OneSite REST / AppFolio Public API) to auto-pull aging roll-forwards rather than requiring manual input
- Whether the skill should output a **disparate-impact audit checklist** for operators applying hardship discretion, given growing Fair Housing enforcement focus (2024 HUD guidance on algorithmic and discretionary decision-making)
- Whether **chronic-delinquency cohort exit economics** (cost of non-renewal vs retention) should be deepened in R4 (lease-renewal retention) or handled within this skill's scope
