This page is for the nitty gritty of what goes on behind the scenes to keep Southbridge running from month to month, so if you want happy, shiny feel good news and fluff, the rest of the website is conflict free. This is the section that will make you wonder just how it all looks so peaceful on the outside and yet can be so chaotic behind the green curtain.

At the 8/9/07 SBHOA meeting the usual thirty to forty people showed up.  The last meeting’s minutes were approved by the SBHOA Board, but they were not presented beforehand or posted on any website for anyone to review and object.

A presentation was made by Garden City officials regarding the Food-Lion anchored shopping center on Dean Forest Road opposite our entrance. Once again, the sound system failed, and hand-held only (as opposed to easel- or projection-based site-design graphics) were presented.  So the crowd’s reaction (acceptance or rejection-wise) was understandably muted, but at least one attendee felt that the site plan looks good if it actually is built according to the drawings presented.

The officials promised that there would be no Certificate of Occupany issued for any of the buildings until a new traffic light is installed, and on the Food Lion site developer's dime if necessary. But there may be delays on the stoplight because Garden City, Chatham County and The State of Georgia State (DOT) jurisdictions all overlap. Construction is set to begin 9/07 or 10/07.

SBHOA David Gelaude presented a review of the budget hand-out sheet distributed to the crowd. He reported a new net reserve of $383,000, which is up from $332,000 in 10/06.

SBHOA President Leah Gross announced new Board of Director Resolutions governing things like how long holiday decorations can be left up, how they must be “reasonable” and not abusive, etc.  Also, all garbage cans and woodpiles, etc., must be concealed behind a screen on the side of one’s home or kept in the back of the home so such cannot be seen from the street.

In that regard, Joshua Reeves's (the SBHOA attorney) answered questions regarding covenants. Joe Griffin, Joan Griffin and Chris Desmond questioned him about what were best characterized as gaping flaws in his legal analysis.  With respect to the “holiday decoration” resolution, for example, Reeves cited Southbridge Covenants Art. IX § 1 Rules and Regulations: “The Board of Directors of the Association shall have the power to formulate, publish and enforce reasonable rules and regulations concerning the use and enjoyment of the yard space of each Lot and the Common Area......”

Joe, however, pointed out that that covenant is expressly limited to THE YARD SPACE OF EACH LOT.  Thus, the SBHOA cannot, by mere resolution, promulgate what amounts to a new covenant regarding the restriction of what decorations one may place on their HOME (as opposed to yard space).  Reeves disagreed, but did not explain the basis for his disagreement.

Joan Griffin, The Covenants Committee Chairwoman, inquired whether our covenants would expire  on 2/8/08, pursuant to a Georgia statute automatically extinguishing covenants after 20 years.  O.C.G.A. § 44-5-60(b) (“Covenants restricting lands to certain uses shall not run for more than 20 years....”).

Reeves responded that Southbridge has an automatic-renewal provision in its covenants and case law has upheld such a provision in cases from similar neighborhoods.  Joan pointed out, however, that the automatic-renewal provision ITSELF is a covenant and what about case law one can cite to the effect that one cannot use an expiring covenant to renew other covenants?  (In an email to Reeves, Desmond had pointed out that such argument had not been raised in previous cases so litigation could break out on it).  Reeves replied that he didn’t think that would be an issue, but again did not state his reasons why. A 2001 letter from the Developer's own lawyer [1], acknowledged that Joan's argument is a live issue.

Joan also adverted to another issue, with respect to her Committee’s consideration of proposing new covenants, that Desmond had raised in a lengthy email letter to Reeves and the SBHOA Board, and to which no one has responded.  It turns out that another Georgia statute,  O.C.G.A. § 44-5-60(d)(4), prohibits any new covenants unless each owner agrees to it in writing.  In an earlier opinion letter [2], Reeves had cited a case (Hill v. Fontaine Condo. Assoc.) [3] to support the proposition that Southbridge could use its Covenants’ 2/3 vote provision (under which 2/3 of all the residents could vote to pass new covenants) to pass new covenants.

Desmond had insisted that the “Hill” case on which Reeves relied didn’t even mention O.C.G.A. § 44-5-60(d)(4), so it was legally reckless of Reeves to rely solely on that case in advising the SBHOA to undertake the expense of a 2/3-vote  process -- only to wind up having its enforcement efforts judicially invalidated and maybe face high litigation costs in the process.

“That’s now two litigation time bombs that you’ve tossed into the crowd, Desmond said to Reeves.  Reeves did not respond.

Desmond also questioned Reeves whether he perceived any conflict, within the meaning of the Georgia Attorney Ethics Code, in representing “the SBHOA” when he is on notice that the Developer has a conflict of interest with the homeowners and a lawyer cannot serve two masters [4]. (Background: In an earlier email to Reeves, Desmond insisted that our Covenants were negligently drafted and will be costly to fix, so the Developer, not the homeowners, should bear that expense; also, the SBHOA in 2001 publicly recognized this conflict when it received two different opinion letters -- one from the Developer’s lawyer [5] and one from the homeowner’s lawyer [6] on the claim Desmond then made that the Developer contractually promised us guttered curbing under the Covenants but then breached that promise).  In response toDesmond's "conflict" question at last night's meeting, Reeves insisted that “I represent the Southbridge Homeowners Association” and refused to respond further.

With regard to recently resigned Area Representative Michael Shortt's assertion, "that the SBHOA Newsletter needs to be changed to a quarterly or web only format because it loses over $20,000 per year." According to David (CPA/Treasurer) actually costs the SBHOA a net loss of $24,000 per year for 12 monthly issues. The President was going to have the crowd vote on whether to cut it back to every two months or even quarterly but did not. She also admitted that yes, the SBHOA has been paying an Editor and that she wants to continue to keep paying someone to do that job.

A resident from the crowd asked why not just go to email distribution and online presentation and eliminate the ads (new website is the old one, http://southbridgehomeowners.org ).  Chris Desmond offered to edit/produce the newsletter for free if the SBHOA “dumped all the advertising and placed it in email and online form only.” Some in the crowd expressed support for his offer, but no consensus was expressed either way.  Leah Gross said the SBHOA would study all of the options and decide the matter later.

Manker, our landscaper, was given kudos by the SBHOA for its good service to the community.  A budget sheet handed-out at the meeting shows what Manker and other vendors are paid.

As a result of Joe Vallari's incessant complaining, it was reported that the SBHOA had encased the video-surveillance signs in wood, no cost was given for this change, it was estimated to be between $500.00 to $1,000 ) They will remain, however, blue colored. She also thanked Lisa Swearingen for getting a “posted for Children” sign for our playground.  And, she reported the planting of a new tree on Pine Lakes Ave.

The traffic control officer at the Dean Forest Road entrance will return 8/15/07 and will be on duty only during school days.

Jeff Jepson gave the Developer's report and shared that 99% of all the common areas has been transferred to the SBHOA. He also shared that he has met with Tom Harris of the SBHOA’s  Transition Committee, and he is working through a "punch-list" of infrastructure issues that need to be brought up to snuff before the Developer leaves. There was no reporting on what the punch-list is and how those items were being resolved.

Jepson also said that “Tract K” will start construction in September.  Also in the Developer’s inventory are 154 lots, with half being purchased by Centex Homes and 80 lots unsold. Eight plans have thus far been submitted to the Architectural Review Board, and they all range in the $400,000+ category.

Security Officer Mike Ramsey’s Security Report: About 24 traffic tickets have been issued since the last security report, one led to a drug bust, and Ramsey claims a 50% reduction in crime over this time last year.  Most calls have been false alarm responses to faulty home alarm systems.  He encourages homeowners to notify security when they plan to be away from their home for an extended period.

Van Isenhour made a property report: He reports that he has been dealing with stray dog and cat problems, including reports of some wild dogs.  He has also had to deal with snakes and alligators this summer (one may surmise that, as a result of the drought the reptiles are leaving the reserve areas and coming onto homeowner properties looking for food).

Van said the SBHOA is temporarily waiving the no-boats covenant "to give people a break on Friday nights so they don't have to drive to Thunderbolt early Saturday morning to get their boats.”  That way, he reasoned, they can have the boats for the full weekened.  However, he pressures them against keeping the boat in their driveway into the following week.

Webmaster’s Questions: Does this not defeat the purpose of the covenants and constitute a deliberate covenant waiver that, in turn, sets the SBHOA up for a judicial declaration that it has legally abandoned this covenant as a result?  Selective covenant enforcement by the SBHOA also has an obvious adverse impact on neighborhood politics, no?


During the questions period Chris Desmond asked about the new "Real Estate Transfer Fees" projected to bring in some $15,000 per year. The President said Bosley concocted it and someone in the room said they've since paid it.  Every property transfer gets "taxed" $115 dollars, so when a house is sold $115 is added to the closing cost. When asked what specific covenant authorizes that, Jeff Jepson promptly admitted that there wasn't one and agreed that it "probably shouldn't' be collected." Desmond then urged that all those who have paid should get a refund with interest. The SBHOA did not respond.

Finally, the SBHOA did not mention the succession issue (whether Chris Desmond should named to the SBHOA Board to replace Michael Shortt).  Here’s his earlier email exchange with Leah Gross [7].

The quarterly SBHOA meeting is being held on Thursday, August 9th at 7:00 p.m. on the second level of Grand Lakes Lodge and Spa. Your attendance is highly encouraged. There are many issues that need to be resolved and only your presence will cause these to be discussed or solutions sought.

1. What's the situation with the Covenants Committee, are they in fact going to enforce covenants that are unclear or unknown to residents? Is it true that the Committee Chairperson raised concerns against grand fathering in long term existing conditions which have never been enforced in 20 years? Where will it stop? Who decides what may or may not need to be changed on my property at my expense? What about residents who bought houses with possible violations in place that were not disclosed to them nor enforced for 20 years? What about residents who bought homes and were never supplied with the Architectural Guidelines from the previous owner, either real estate agent or the SBHOA in authority at the time of purchase? Who decides the Architectural Guidelines, approves plans, etc? Are they a Southbridge resident? Are they indeed paid $200.00 per house? Sure, the covenants are flawed, but are we going to correct them using common sense or narrow-minded and unyielding fervor!

2. Is it true that if a home is titled in a corporate name or held by a holding company that the resident owners are not members of the SBHOA? Are those considered non-members therefore not liable or responsible for paying association dues? If a spouse or a child is not named on a title or deed does it mean that they are not association members and are therefore precluded from all Southbridge events or serving as an elected representative? Who decided these new conditions since they are not covered in the By-Laws or Covenants?

3. Is it true that the SBHOA reneged on an agreement with a company to supply the community with a website at no cost to the association or the residents? Was the real reason because the company (in accordance with the original agreement) actually attracted sponsors to offset the hosting costs? Is it true that the President of the SBHOA demanded that all sponsorship money be turned over to the SBHOA even though they had no legal rights or claims to it? It is also true that the current leadership then hired another web design company using association monies to duplicate the website for thousands of dollars? It is true that there will now be a $100.00 per hour cost to update the site and monthly hosting fees? Is it true that this entire episode is over the sum of $297.00?

4. Why did the SBHOA knowingly overpay for newsletter printing for three months by over $1,000 per month to the printer even though a lower bid was submitted by another printer who offered a better product at a lower price and could have easily printed all three issues?

5. Is it true the the newsletter operates at a loss of $20,000 per year and costs residents over $4.00 per copy? Why are the newsletters coming out at the middle or end of the month of the dated issue? Are association dues used to pay a salary for the newsletter as well as commission on advertising sales, and if so what's the problem with a website supplying services for free which are not at a loss and more importantly, not costing the community anything?

6. After the forced resignation of an area representative, why did the leadership of the SBHOA suddenly change the method that was recently used twice to fill other vacant positions with replacements? Was it simply because they didn't like the next person in line who should be named as a replacement as a result of the established precedent? If so, should all three positions be filled using the newest method to right previous wrongs?

See the whole story on this, click here.

7. Is it true that the unwarranted actions of the leadership has placed the association in possible liability for damages caused?

8. How much is the SBHOA spending of your association dues to pay a law firm to harass a former area representative with unfounded, illegal demands with no basis in law? Are these really just personal attacks that are funded by your association monies?

9. Why don't your elected leaders want to be accessible to the residents by email? Why do they want to be impossible or difficult to communicate with regarding community affairs?

10. Are your elected leaders going to retain the services of both the Property Manager and the Business Manager (both were given only 6 month contracts which expire in October)? If not, why not? What are their plans and do they include saddling the residents with yet another management company like Bosley that failed the community so badly and cost residents almost three times more than as the current in-house services cost?

The SBHOA has voted to spend your association money to have an outside non-community resident vendor develop a new website. This website was built and developed to be that website and was made available to the Southbridge community at NO COST, the original agreement was that The Web Advantage would provide the website in exchange for exposure of our business interests. That stipulation included the ability to seek sponsors to help offset the operating costs of the website, but the members of the SBHOA demanded not only that we cease as the official website after hundreds of hours of work was invested but also demanded any funds raised by our third party marketing firm be turned over to them.

So there you have it, you now get to pay for a website that you had for FREE because the SBHOA wanted to steal the grand sum of $297.00 that was paid to help sponsor the website (actually, 297.00 isn't correct, the third party marketing company retained a 25% commission for selling the sponsorship, so according to the SBHOA, we would have to pay them the entire 297.00, thus losing an outright 74,66, plus pay for all the hosting services, do all of the programming and keep the website updated daily. Great deal for us don't you think, especially when you know that the newsletter editor was paid $1,000 a month as a base plus commission on ad sales for a newsletter that loses $20,000 a year.

When did the federal government get in the homeowner association business?

The "Covenant Committee Reports to SBHOA" article written several stories below was presented to soften how the Covenant Committee wants to interpret the Covenants literally and enforce outdated rules and regulations at the peril and expense of homeowners.

Much ado was made by this article by the Covenant Committee Chairperson Joan Griffin who wrote the following in her letter to the association, "

Finally, we believe you cannot make any CCR covenant retroactive. Therefore, there is no reason to ask any homeowner to document any feature, improvement, or modification of their property which may be contrary to a loosely written covenant, or a capriciously  enforced covenant or one that is not yet in writing and not a part of the existing formal printed Homeowners Association membership by-laws.

We believe the neither CCR Committee nor the SBHOA Board has the legal authority to write covenants and/or resolutions which are retroactive...

In other words, if your home currently violates an outdated covenant that has not been enforced in years, that perhaps was never enforced or that was in place when you bought your home - you will be expected to spend money to make it meet covenants that were written 20 years ago. It does not matter to the Committee if you did or didn't know about the violation, if you were even given a copy of the covenants when you purchased your home or lot ( many people where not ) or if the violation has been in place for 18 years, according to their language you should be forced to correct the problem at your expense or if followed through to the very end of their authority, the association can place a lien on your home. That is what they mean by "retroactive covenant", "loosely written" and "capriciously enforced covenant".

It was discussed after Committee members left the meeting that enforcement of dated covenants that have not been enforced in years and violations that have been in place on homes through several owners would not be legally enforceable, that if in court the law will generally side with homeowners almost every time. It seems that the intent of these non elected Covenant Committee members is to be unyielding, and in that realization they will try to pursue these dated covenant violations/homeowners at the expense of the SBHOA through all legal means using your homeowners dues money to pay for their attorneys fees paid to fight your fellow residents.

Nobody wants a neighborhood that doesn't conform to the agreed upon standards, nobody wants their property values to drop, covenants are there to protect everyone, BUT a sudden renewed application and overzealous enforcement of dated and long ignored violations should not be tolerated or paid for by homeowners. Just because a few people were assigned to a committee do not use common sense or realize the uselessness of their actions. It takes 66% of the community to make changes to the covenants in Southbridge, that's approximately 750 votes at one vote per house or lot, in the last election, 101 properties actually voted. Apathy for home owner association issues is rampant nationwide, Southbridge is not alone in the fact that 66% (750 people) will never cast a vote to approve or disapprove anything, people are simply too busy with their lives to get involved. Therefore, common sense must be used when trying to enforce covenant violations, recent violations should by all means be fully enforced, but violations which have been in place for years and years should be grand fathered in and if that implies a "retroactive covenant", well then so be it! "Good Fences Make Good Neighbors", but so too does reasonable enforcement and knowing when to fight and when to settle for a draw.

Watch your "Covenant Committee" closely, demand fair and reasonable enforcement but not at the cost of resident upheaval, increased community bad feelings and great legal expense by the association; especially when it is known in advance that most homeowners will win if pushed into court. Understand that our legal opinions come from the same firm that will be paid to fight outdated covenant violators at your expense.

It seems that the SBHOA doesn't understand that a newsletter is supposed to provide news in a timely fashion or offer event calendars where 90% of the events haven't already happened! Not once this year has "The Perspective" SBHOA funded newsletter been printed or mailed so that it would arrive in resident mailboxes before the 1st, the most recent July issue was received by most homes on the 25th of the month it claims to represent. Produced at a cost of over $4,000 an issue and operating at a loss of almost $20,000 per year, has it in fact outlived its reason to exist? Do you feel that your homeowner dues money is being well spent?

Either produce and mail it on time or turn it into something else and remove the outdated calendars inside, perhaps a bi-monthly or quarterly publication full of the fluff that usually fills the other few pages that aren't advertising.

This website was originally proposed and accepted to be a source of news for the residents, 85% or more who do use the internet would have received timely news and event notices BEFORE they happened, but that information wasn't supplied. Rise up and demand SBHOA accountability, your money is being wasted and at over $4.00 per copy, who needs old news?

As of July 18th, Online Southbridge is a stand alone, independent website that is not funded, edited or controlled by the Southbridge Home Owners Association. They have no decision making ability or say in the content of this website.The website will continue to exist and provide all the news that can be shared, we will depend upon many of you to provide information that you feel should be shared with your fellow residents. The restrictions of being at the mercy of a group that wants to restrict web site content and discourages "telling it like it is" was just more than could be endured. The SBHOA elected members have decided to force a separation against the website and the original terms that allowed Online Southbridge to become established as well as impact the fiscal health of the enterprise.

There are people who reside within the community who work against progress, through a constant barrage of emails, telephone calls, personal visits and inappropriate actions they behave in a way that is contrary to the financial interests and general well being of the majority of the community. Their only desire seems to be to wear down and beleaguer those who step forward and those who care enough to try to make a difference. By these acts they effectively destroy community goodwill and induce apathy amongst property owners. These people will be exposed, using nothing more than their own words and reporting their actions. The goal is to keep you informed of their misguided efforts and deceptive methods. Online Southbridge will make every effort to see that you are informed and demonstrate how your life and it's quality has been and still is being negatively impacted by these people.

What's the story behind the story?

Simply stated, it is greed and avarice by the leadership of the SBHOA to invalidate the original agreement between The Web Advantage and the SBHOA. That agreement in it's entirety was the following, "The Web Advantage will provide a community website at no charge to the Southbridge Homeowners Association for its creation and design, daily updating or monthly third party vendor hosting services in exchange for business exposure". Which was voted on and approved by all members and officers.

A part of that plan from the beginning was to find sponsors to help offset the ongoing costs incurred to keep the website operational, but suddenly this is sent to me by Leah Gross on July 18th,

"Michael it is a community website which you wanted to do against my concerns presented to the committee about a conflict of interest. Checking with the attorney it is a violation for you to make money off the HOA website reguardless of who made it. So what I am saying is the website is property of HOA thus any monies being made belong to HOA. "

It seems that once the site was complete after hundred's of hours of work (and public support and praise by both the association members and many community members ) that the SBHOA has changed it's mind now that two sponsors actually stepped up with a combined $297.00 to pay for exposure and to help keep the web site going.

One can only surmise that it was OK to invest our own money, do all the creative efforts and design work in the hope that we could make it work, and do so at no cost to the association or the residents. It was a true "win-win" proposition. How that became a conflict of interest is lost on us!

Our idea, Our money, Our work, Our marketing efforts and the HOA now wants to keep any and all money paid towards keeping the web site operational for itself. They even wanted to keep the small commission money paid to a third party outside marketing company to find those sponsors that wanted to support the site. The very same HOA that loses over $20,000 a year on a newsletter that costs $4.00 per house per issue and gets delivered on the 25th of the current month.

This is what you have for leadership!

The SBHOA now claims to be researching paid web site vendors to create another website at your expense to do the very same thing.

This attorney must live in a bottle and be a real genie, it appears that the original bylaws prohibit a website ( which didn't exist when they were written ) from being operated this way. This is also the same attorney who makes up resident membership definitions that are also not in the bylaws. I guess the SBHOA President has one wish left!

Michael Shortt, who was elected in fall 2006 to serve as a Southbridge Home Owner Area Representative until 2009 was forced to resign from his position by unrelenting pressure and harassment by the SBHOA.. A replacement has not yet been named.

"First and foremost it was an honor to be elected by the community, their faith and trust is greatly appreciated, but the reality of the situation is that I have discovered that although I'm a political consultant, I'm no politician. I can not and will not remain silent and be the good soldier while elements within this community work to tear it apart from the inside. I must have the freedom to say, print and share information so that the majority of Southbridge property owners are kept informed. Nor will I or my wife change the way that we conduct our legal affairs and business. I made a conscious and well thought out decision with input from both legal counsel and from our CPA to not be on the title to my home. Legitimate reasons which are not the concern or business of the SBHOA or its members, yet they have used that to hound me, pressure me and eventually force me to resign, going so far as to get a legal opinion which clearly defies every association in the state and is not listed in our own bylaws.

There are a handful of people who manipulate this community, they do not represent me or anybody I know and yet their concerns seem to occupy 90% of the attention of the association representatives. It's not fair to the other 1,100 plus property owners who need a voice and I intend to be that voice."

 

A representative of the Covenant Committee made a brief presentation to the SBHOA on Wednesday, June 27th to show the committee's efforts to date. Concerns were raised regarding out dated Covenants, applicable Resolutions and existing items which are not appropriate to the 2007 version of Southbridge as opposed to the "new" development that was Southbridge twenty years ago.

The SBHOA gave the Covenant Committee the task of reorganizing all existing Covenants, Valid Resolutions, Building Review Guidelines, out dated items as well as New Covenant Suggestions into one inclusive document. Once complete the reorganized covenants will be reviewed, debated upon, feedback solicited, adopted and ultimately - a strict neighborhood covenant enforcement campaign will begin to right the wrongs of the past and ensure that future property owners know what they need to know to avoid unnecessary spending when remodeling, re landscaping or maintaining their homes.

Concerns which were raised included: Painting, Construction, Holiday Decor, Pets, Free Standing Buildings, Maintenance, Swimming Pools/Screening, Fences, Landscaping, Excessive Toys, Swing Sets, etc. Some current long standing infractions may be grand fathered in if the homeowner can document these longstanding conditions (years and years) and provide a previous provable history of the item. Recent infractions and new items which are clearly defined violations of the covenants will result in letters being sent to the property owners. If not acted upon, fines may be levied, which if unpaid will result in liens being placed on the offending properties that have not conformed to the guidelines within the specified period.

Therefore, if you feel that you have a historical non-complying issue on your property, now is the time to gather support, photos and other relevant documentation so that you may present your materials to the committee. If you know that you have recently violated the covenants in some way and where hoping that you would not get caught - think again! Please make the needed conforming adjustments to your property so that letters are not sent in the first place. Nobody wants this refocus of the community to the original guidelines to be a negative experience, these efforts are intended to correct outright violations which occurred when energies were focused elsewhere. The bottom line is that every property owner who lives in or owns a lot(s) within Southbridge agreed to abide by the rules and regulations when they purchased their property. The intent of the SBHOA is to enforce our covenants fairly, uniformly and equally throughout the entire community. The SBHOA or the Covenant Committee Members are not ogres or trolls living under a bridge who only come out to collect fines and make life difficult, they were elected by you to oversee our community. They have two main missions - Security/Safety and Maintaining Property values within Southbridge. The desire for a safe and attractive community where property appreciates in monetary value is universal as is the wish that we all have neighbors who respect each other as well as the rules.

P. S. The Committee is not looking for, requesting or otherwise encouraging an influx of neighbor against neighbor complaints until such time that the Covenants are more clearly defined and approved by all appropriate parties. If you must report an infraction regarding a property owner please make it for an infraction that is worthwhile and which might affect the entire community. The SBHOA is not in place to intervene or referee over petty squabbles between residents. Please behave like the professional, successful adults that you are and deal with the problem amongst yourselves before you involve others; nobody likes a tattle-tale or a busy body and remember that when the dust settles that you will still live next door or down the street from the offender. Issues that are reported will be given priority if they involve Security, Safety, Roaming or Miscreant Animals, Vandalism, Danger to Children or the likelihood of property damage to one property by the carelessness of another property owner.

The most recent known copy of the Architectural Guidelines are posted on the same page as the Covenants, please scroll down the page to see where they begin. Both these documents form the basis of the agreed upon rules and regulations that all property owners signed when buying homes or lots within Southbridge. Although some modifying resolutions have been added over the years, these form the bulk of the regulations and the reorganization effort described above will seek to clarify any questions.