Many Florida planned communities layer multiple governing entities over the same physical footprint: an HOA under F.S. 720, sometimes a master association (master declaration over multiple sub-HOAs), and often a CDD (Community Development District under F.S. 190). Each has separate governance, separate assessments, separate authority, and separate board elections. Owners get confused; boards step on each other's authority; legitimate disputes arise over who has jurisdiction over what.
This post is the CAM playbook for navigating the overlap.
Beat 1: map the governance structure
For the community, identify:
- HOA(s): chartered under F.S. 720, declaration-driven
- Master association (if any): umbrella over multiple sub-HOAs or sub-CDDs
- CDD: local special-purpose government under F.S. 190, created by the state + adopted by county
- County / municipal authority: zoning, code enforcement, road maintenance (if dedicated to public)
Each entity has separate:
- Board/supervisors
- Budget
- Assessments
- Meeting schedule
- Records
Beat 2: CDD vs HOA authority distinctions
CDD authority (F.S. 190):
- Infrastructure (drainage, stormwater, roads if owned, some utilities)
- Bond debt repayment (most CDDs were formed to finance infrastructure + members pay off CDD bonds via annual assessment)
- Recreational amenities in some CDDs (pool, clubhouse owned by CDD not HOA)
- Quasi-governmental powers (limited taxation, eminent domain)
HOA authority (F.S. 720):
- Covenant enforcement (architectural, use, lifestyle)
- Common-area maintenance (if common areas are HOA-owned)
- Assessment collection for HOA budget
- Rules specific to the community's governing documents
Overlap zones:
- Pool + clubhouse often CDD-owned + HOA-maintained (or vice versa)
- Landscape maintenance sometimes split (CDD for public medians, HOA for lot-adjacent)
- Gates sometimes CDD (public access issue)
Beat 3: dual assessment disclosure
Owners pay BOTH HOA assessments AND CDD assessments. At closing, both are disclosed separately. During ongoing ownership:
- HOA assessment on the HOA's annual schedule
- CDD assessment appears on the property tax bill (collected with property taxes in most counties)
- Separate delinquency processes per entity
Failure to pay either can lead to foreclosure. CDD delinquency is on the tax bill; HOA delinquency runs through 720.3085.
Beat 4: member confusion + communication
Most owner confusion:
- "Why am I paying twice?" (HOA + CDD = two separate assessments)
- "Why can't the HOA fix X?" (when X is CDD's jurisdiction)
- "Why is the CDD doing Y?" (when Y is HOA's jurisdiction)
CAM's role: clear communication about which entity governs which surface. Annual newsletter section explaining. Welcome packet clarification per new owner welcome playbook.
Beat 5: cooperation agreements
HOAs + CDDs often execute a cooperation or interlocal agreement:
- Shared maintenance responsibilities
- Event coordination
- Facility access arrangements
- Mutual communication protocols
These agreements live in the records. Annual review during annual legal + compliance audit identifies drift.
Beat 6: CDD board vs HOA board dynamics
CDD board members (Supervisors) are often elected via a different process than HOA directors. In early years developer-appointed; transitions to landowner-elected per F.S. 190.006.
HOA and CDD boards may include the same individuals, different individuals, or no overlap. Personal politics across the two boards sometimes generates disputes that feel personal but reflect governance-structure complexity.
Beat 7: enforcement coordination
When an owner violates both an HOA rule and a CDD rule (e.g., unauthorized construction affecting a CDD stormwater easement):
- HOA enforces HOA rules per enforcement escalation playbook
- CDD enforces CDD rules separately
- Each entity's records kept separately
- Parallel proceedings, not combined
Beat 8: shared facility maintenance
If pool + clubhouse is CDD-owned + HOA-maintained (common pattern):
- Maintenance contract typically through HOA's CAM
- Usage rules jointly adopted or CDD-adopted
- Capital improvements CDD-decided
- Liability coverage often split
Clear documentation of who owns + who operates prevents misunderstanding during incidents.
Beat 9: records-request coordination
An owner's records request may span both entities:
- HOA-held records per 720.303(5)
- CDD-held records per 190 (public-records law applies, as CDD is a local government!)
CDD records are broader-access than HOA records (Florida Sunshine Law applies). Owners frequently prefer to use the CDD records path for this reason.
Beat 10: annual review
During annual-audit:
- Cooperation agreements current
- Dual-assessment disclosure + communication materials accurate
- CDD-HOA boundary-of-authority questions logged + resolved
- Joint meeting (if any) scheduled
Structural overlap needs regular re-alignment.
Five HOA-CDD failure modes
Observed patterns:
- Boundary-of-authority dispute. HOA enforces against owner for fence location; fence is actually in CDD right-of-way; owner sues HOA for trespass + wrongful enforcement.
- Dual assessment confusion. Owner stops paying HOA thinking they're paying the CDD bond instead; racks up delinquency; HOA enforces via 720.3085; owner surprised by foreclosure.
- Shared facility liability unclear. Pool incident occurs; HOA + CDD point at each other; claim delayed; plaintiff sues both + picks the better insurance.
- CDD records request exploited. Owner uses CDD's broader Sunshine-Law records access to obtain documents the HOA would have carved out per 720.303(5)(c); HOA posture compromised.
- Records duplication / conflict. HOA minutes + CDD minutes capture same discussion differently; discovery exposes inconsistency; credibility issue.
Bottom line
Florida communities with layered HOA + CDD + master association governance require clear understanding of each entity's authority + careful coordination between them. A CAM + board that navigate the overlap with documented agreements + clear owner communication avoid most cross-entity disputes. A board that assumes its HOA jurisdiction extends everywhere generates legitimate claims of overreach.
The statute sets each entity's framework (720 for HOA, 190 for CDD). The playbook is the coordination that makes the layered governance workable.
This post is an operational walkthrough, not legal advice. For specific HOA-CDD boundary or cooperation agreement questions, consult a licensed Florida attorney familiar with both community-association + local-government practice.