HOA Detective™ | December 5, 2025: Most Americans have no idea that the nation’s largest and fastest-growing housing sector – the one that governs the lives of more than 80 million U.S. residents – remains almost completely absent from the federal government’s core housing data infrastructure.
Homeowner associations (HOAs), condominium associations, and other common interest developments (CIDs) form the backbone of modern residential development, especially in high-growth states. Yet these communities are missing from the most important federal datasets used to understand American housing, shape national policy, and allocate billions in public funding.
Persona Non Statistica™: In the world of federal housing data, homeowner associations (HOAs) occupy what The HOA Detective™ has aptly labeled Persona Non Statistica™, a term coined by the Detective to describe an entire class of housing that is structurally present yet statistically nonexistent. Despite governing tens of millions of homes and exerting profound influence over affordability, access, governance, and long-term asset planning, HOAs remain invisible inside HUD’s statistical classification schema.
This bureaucratic blind spot treats HOA-governed housing not as a definable housing sector with measurable characteristics, but as an uncounted shadow population – an omission that obscures policy failures, distorts national housing analysis, and perpetuates federal ignorance about the fastest-growing form of residential development in the United States.
Not a Subtle Omission: HOAs do not appear in the American Community Survey (ACS), the annual nationwide survey conducted by the Census Bureau. They do not appear in the American Housing Survey (AHS), the biannual dataset maintained by HUD and the Census Bureau, which policymakers rely on for measuring housing characteristics and trends. Nor do HOAs appear anywhere in HUD’s administrative data compilations, despite the department’s central role in shaping national housing policy.
This omission is astonishing when you consider that if any entity should have HOAs squarely in its statistical cross-hairs, it is HUD – a cabinet-level department whose secretary reports directly to the President of the United States. And yet one of the largest quasi-governmental systems in the nation is effectively invisible at the federal level.
The Vast, Unseen Housing System: The scale of the HOA housing sector is difficult for most Americans to grasp. According to the Community Associations Institute (CAI), the U.S. is home to approximately 378,000 common interest developments (CIDs), which include homeowner associations of various forms, not the least of which are condominium associations and planned unit developments (PUDs). Combined, the HOA housing milieu represents:
- Over 80 million Americans;
- Roughly one-quarter of all U.S. households;
- More than $10 trillion in residential real estate value.
- 75%-plus of the new residential construction in metro regions across the Sun Belt and West Coast.
In states like Florida, Nevada, Colorado, Utah, Arizona, North Carolina, and Texas, PUDs and condo associations dominate the housing landscape. In some jurisdictions, almost all new housing is part of an HOA, which is created by the developer to satisfy local requirements for stormwater management, open space preservation, and infrastructure maintenance costs that local municipalities refuse to accept in the 21st-century world of the privatized metropolis.
Even though HOAs govern the lives of 25% of the U.S. population, and contain within the legal borders ~19% of the housing units in the U.S., this housing subset is not officially identified by HUD or the Census Bureau. This means HOAs are not inventoried, tracked, or recognized in any formal way by the federal agencies responsible for understanding, much less managing American housing policy.
Census Bureau’s Blind Spot: The Census Bureau administers numerous surveys, but two datasets stand above the rest in shaping housing policy and research:
- The American Community Survey (ACS) – a massive annual survey used to allocate hundreds of billions in federal funds.
- The American Housing Survey (AHS) – the nation’s most comprehensive survey of housing characteristics, administered biannually by HUD and Census.
Despite their breadth, these surveys do not directly identify households that live in HOAs. The ACS and AHS ask whether a household pays a “condominium fee,” but they do not ask whether a detached single-family home or a townhouse is under the jurisdiction of an HOA – an omission that conceals millions of governed households where a landlord may pay a “condominium fee”, but the occupant of the unit does not pay the fee directly. This sloppy statistical methodology also misses the millions of HOA housing units that are NOT condominiums.
Because most HOAs are not condominiums, this omission means that federal data cannot distinguish HOA households from non-HOA households or evaluate the cost burdens, governance structures, or financial obligations that shape the lives of millions of residents.
The federal government can tell you how many households own a smartphone, how many commute by carpool, how many heat their homes with propane, and how many have a flush toilet. But it cannot tell you how many Americans live in HOAs.
HUD – The Missing Data Steward: The omission extends to HUD, the federal agency most responsible for monitoring national housing conditions. HUD oversees fair housing enforcement, FHA mortgages, disaster recovery funds, housing counseling, and vast national research initiatives. And yet:
- HUD does not track HOA financial stability.
- HUD does not collect data on special assessments, reserve funds, or structural risk.
- HUD does not monitor HOA foreclosures or governance failures.
- HUD does not integrate HOAs into affordability or risk models.
- HUD’s data portal contains no meaningful HOA dataset.
This is remarkable considering that HOAs now perform many functions traditionally handled by local governments, including maintaining roads, stormwater systems, wildfire buffers, shoreline reinforcements, and critical community facilities.
Why the Data Gap Matters: The invisibility of HOAs in federal data has real-world consequences:
- National housing policy is built on incomplete information.
- Structural and safety risks go unmeasured.
- Disaster recovery models miscalculate vulnerability.
- Academic research remains fragmented and shallow.
How Did HOAs Slip Through the Cracks? When the ACS and AHS were created decades ago, HOAs represented a small portion of housing. Their rapid growth since the 1990s simply outpaced the evolution of federal survey design. Bureaucratic inertia kept HOA-focused questions from being added, even as HOAs became the default method of new housing development across wide swaths of the country.
A Call for Federal Data Modernization: If federal housing policy is to reflect the reality of how Americans live, three reforms are essential:
- Add HOA-specific identifiers to the ACS and AHS.
- Integrate HOA data into HUD’s affordability and risk models.
- Track HOA financial health in mortgage underwriting.
Without these steps, the nation’s vast and invisible system of private neighborhood governance will remain unaccounted for—shaping affordability, safety, risk, and property values without appearing in a single federal spreadsheet.
References
Community Associations Institute. “2023–2024 U.S. Community Association Data.” CAI Research Foundation. Accessed [insert date]. https://www.caionline.org/Advocacy/GovernmentAffairs/Documents/2023-2024-Statistical-Review.pdf.
U.S. Census Bureau. “Programs and Surveys.” U.S. Department of Commerce. https://www.census.gov/programs-surveys/.
U.S. Department of Housing and Urban Development. “American Housing Survey (AHS).” HUD USER. https://www.huduser.gov/portal/datasets/ahs.html.
U.S. Census Bureau. “2024 American Community Survey (ACS) 1-Year Estimates – Data Release.” Accessed [insert date]. https://www.census.gov/programs-surveys/acs/news/data-releases/2024/release.html.
