Landlords in Columbia facing scrutiny for not providing safe places to live for tenants

by Mirania 27, November 2012 16:09

Recently, we came across a write-up on The Maneater.com about maintenance issues in Columbia that are seriously affecting the relationship between tenants and landlords. The dilapidated condition of the rental units have left the renters in a condition that has violates the minimum health norms set by housing law. The article states that in the Dumas apartment building, located towards north of campus, a tenant used to sleep every night for over two months in a bedroom that had the windows removed, and due to the lack of a window rain and animals  entered the room.

In another East Campus house, there was an animal carcass had rotted in the house of a student. Moreover in  another rental apartment, the tenants were compelled to sleep in the dining room as the wed bedroom carpet used to smell like mold.

We often explain to our landlords both the investor and the “accidental” landlord (a person who is renting his home till the market gets better) that there are minimal standards. If you do not think that you can maintain minimal health and safety standards, then you will be violating Texas property code standards, which outline that a landlord should provide a home free of things that would affect the health and safety of a normal resident. Unfortunately, some landlords will not or cannot understand that, and they could face legal issues as well difficulty maintaining quality tenants in their properties.

As a property management company who operates in both the Houston and Dallas markets, we know it is important to make a healthy profit for our landlords and investors, but our property managers cannot do so at the expense of legal and moral obligations to our tenants to provide a healthy environment.  Therefore, if we feel that a client will not make the appropriate repairs in a safe and proper manner, then we are prepared to walk away from that client.

For the full story about the issues facing these Columbia tenants, click here.

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Landlord & Tenant Disputes in Dallas and Tampa

by Mirania 8, November 2012 15:25

Several landlord and tenant disputes make news every week with incidents covering a broad variety of strong conflicts taking place between landlords and renters. We will discuss some of the most notable incidents of landlord-tenant disputes.

1)  In February 2012, Dallas police had arrested a landlord who had shot a tenant at a condominium in the 5200 block of Bent Tree Forest Drive off the Dallas North Tollway in far north Dallas. According to Dallas police, the landlord Gabriel Abraham, was trying to evict Daniel Sipes, his tenant when there was some sort of argument. Finally, Abraham shot his tenant multiple times leaving the victim in a critical condition. Abraham was arrested by police on the spot. (Click here for the story)

2)   Another incident took place in Florida in September this year when a Tampa resident was stabbed several times following a tussle with his landlord. The landlord was taken into custody by police and the investigation is underway. (Click here for the story)

How to avoid Landlord and Tenant Disputes?

Such incidents of landlord and tenant dispute generally arise due to disagreement over a rent increase, return of security deposit and responsibility for repairs. To avoid such disputes both landlords and tenants should know their rights and responsibilities under federal, state, and local law. Also, the landlord and tenant should ensure that the terms are precisely mentioned in the rental agreement. It is also important to keep copies of each and every correspondence that takes place between the landlord and tenant and make notes of conversations about problems, if any.

A responsible landlord and a good tenant should always follow these tips in order to avoid conflicts with each other and to co-exist better with each other. If a landlord is having a problem with a tenant for nonpayment of rent, then they should refrain from engaging in personal attacks and focus on following the eviction procedures as outlined by the letter of the law in their state and local area.

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Psycho: Norman Bates was evil, but Marion Crane was no saint either.

by jay.raman@ashokalion.com 7, October 2012 15:40

As a child, I had a strong appreciation for Alfred Hitchcock's brand of horror. It was chilling, but subtle. Psycho was a prime example of the brilliance of the gifted Alfred Hitchcock. However, as I was reviewing this movie for our Ashoka Lion Facebook list of horror movies for property managers; I realized that Marion Crane (played by Janet Leigh) was no angel herself. If you recall, Marion had embezzled $40,000 from her employer, and this is why she was hiding at the motel. Unfortunately for Marion, she met her untimely death in one of the most famous murder scenese in cinematic history (the bathroom scene in Psycho is a all time classic moment).

As a property manager, I am obviously scared of knife weilding lunatics; but Marion's crime is equally as scary for a property manager. As a licensed Texas real estate brokerage in both the Houston and Dallas markets, we are bound by ethical and legal obligations of fiduciary duty to our clients.  Marion's crime could devestate a firm like ours if that money stolen was the client's rent money.  Our duty as a property managers includes safekeeping of the client's rent monies collected, insuring appropriate disbursement of funds to vendors, and keeping record of income and expenses. This is a duty that our firm takes very seriously, as we want to limit mistakes and issues from ever arising. It would be nice to claim mistakes would never occur, but this would be foolish, as humans are bound to make mistakes. The key is to reduce those occurences. Our processes and procedures are sometimes unique from other property management firms. For example:

 

  • Rent is not to be mailed to our offices in Houston or Dallas.   Many firms do allow tenants tenants to mail in payment, but our property management policy is to disallow this. Over the years, tenants will claim that the rent is lost in the mail, and they did send it In fact, tenants will go so far as to show receipts from money orders,etc to prove this. These kinds of issues can be dealt with at a eviction hearing, but today, some judges will have sympathy for the clients who provide some kind of documentary proof. The burden is on the landlord to prove that the rent was not paid at that point.
  • Property managers do not pick up rents.   We do not pick up rents from tenants. A few years ago, one of our property managers had her purse stolen after leaving a property. Reprimanding the property manager does not solve any issues, and a landlord may have sympathy to our plight, but they expect their money to be remitted to them. Fortunately, this crime only resulted in the loss of a few hundred dollars of rent, and reimbursing the owner for that loss was not dramatic. However, that lesson taught to my property management team has stuck with us to this day. Our rent collection process does not involve picking up rents either.
  • Double entry accounting of money on two systems: We maintain our records of our bank accounts on Quickbooks for our internal records, but we also maintain our owners and tenant records on a web based system as well. By utilizing the two systems, we are able to identify issues more quickly as we use different staff to handle each system's entries.
  • Match Bills to Work Orders: To pay bills of nonutility nature, our accounting staff is required to upload invoices to an appropriate work order. If they cannot locate the work order or the work order amounts do not match, the back office staff will assign a review to clarify and approve the bill.
  • Person who organizes payments is not person entering bills: Our staff divides the role of uploading bills and paying bills to two different persons. Occassionally, our office will get a bill that we missed or some how the system was not working, and our managing director will sign off on the overriding the control. This separation of duties further insures that bills are paid as appropriate and reduces risk of a employee embezzling the funds.
  • Person who organizes and sign off on payments does not perform the reconcilation of the bank account.  Our managing director approves payments if they do not follow our process procedure and he is the only signer on the account , but another member of our back office team does the reconciliation of the various property management accounts (escrow owner reserve, accounts, escrow deposit accounts, etc). This separation of duty further reduces risk that a fraudulent act could occur.

Marion Crane may have been victim to a insane man living in a creepy house with his deceased mother, but her crimes against her employer scare property management firms like ours almost as much as Norman Bates (played by Anthony Perkins).

 

 

The Fly: Another reason to not bring your work home with you

by jay.raman@ashokalion.com 3, October 2012 14:37

The Fly is a movie about a scientist who uses a warehouse like space to live and conduct experiments. Unfortunately, his experiment involves teleportation of items, and during one of his experiments a fly is trapped in the teleportation pod. THe unfortunate scientist begins to mutate to a savage cross of insect and man. Now, I know that most people are carry out teleportation or time travel experiments in their homes, but as property managers,we do come across people who try to use their home as a place of business. Our property management company's policy in our Houston and Dallas leases is that a home, duplex , condo, or apartment is used as a residence.

Allowing tenants to run a business out of their home is not a good idea on so many levels. First, the business is probably prohibited by community or homeowner association. Second, the business customer traffic to your home increases the risk that a incident can occur at the home. Third, many homeowner policies do require notice if the home is being used as place of business.  Our stance against home based business is not to be confused with a stance against people who bring their work home or who telecommute into their work.

Therefore, when our property management firm was approached by real estate investors or others who seek to use our homes as group homes, day care business, etc; we politely explain that most of our properties would not be qualified to be used in such a manner. However, in parts of Houston (namely the Heights and Museum District areas), where homes and properties can be used in a mixed use manner. In these scenarios, it is possible to lease to a person in this manner, but it would be important to use a commercial lease and know up front that the tenant's intent is to run a business.

Next time, your tenant backs up a truck filled with large nuclear powered pods, just remember that we warned you.

 

 

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Amityville Horror: Know before you buy!

by jay.raman@ashokalion.com 1, October 2012 14:34

To commemorate Halloween, Ashoka Lion will be providing a fun look at our favorte horror movies. Amityville Horror (1979) was the story of a family who got a great home for a incredibly low price. Unfortunately, this home has a few issues including leaky pipes, bad phone connections, pest problems, and of course a demon possessed home. Now, I doubt most investors or landlords in Houston or Dallas ever face the need to have a home excorcised while adding a new paint job and floors, but it does remind owners to understand that unexpected things can pop on any real estate investment.  It is very difficult to learn every aspect of a home before buying, so the unexpected can arise. For our firm, we do request owner's to tell us about their rental properties to help us have a idea of what we could be facing.

The disclosure forms help us to know if there were any major repairs, types of ammenities, and features. Also, it helps our owners to remember things that may have been issues in the past (foundation, termites,etc). This kind of information helps us better understand potential issues that may arise and cost as a landlord. Owners must realize that those cost must be reserved for potential replacement for things like water heaters, garbage disposal, carpets,etc.  Being a landlord can be very lucrative, but it means trying to understand the risk. Our job as property managers are to help our Houston and Dallas owners understand and prepare for the worst and minimize the risk.  However, even with the experience of our property management team, you can encounter weird situations.

Now whether you are home buyer or investor, you have to accept the risk of the unknown, but I am not sure whether there is enough of a deal for a investor to buy a home that scream "GET OUT" to you!  

Check out our list being revealed at our Facebook page.


Ashoka Lion and its partners take marketing vacant rentals seriously

by jay.raman@ashokalion.com 14, April 2011 17:15

Ashoka Lion and its affiliated real estate brokerage have developed a marketing program that is one of the most extensive for filling vacancies. We know that our property management clients want their vacancies filled as quickly as possible. Our vacancy marketing program includes the following tools:

  • Online Posting to over 20 online databases including RentalHouses.com, Rental.Com, RentalHomesPlus.com, Homes.com
  • Videos posted of our rental properties on YouTube (AshokaTenants)
  • Listed through our Realtor Partners to Multiple Listing Services (MLS)
  • Distinctive Yard Sign
  • Online Application
  • Realtors can pay their client's app fees through our Pay Lease, Inc
  • Marketing through our Twitter Accounts: LionRealEstate and HoustonRenting and DallasRenting
  • QR Bar Codes linking to mobile ready listings for vacant properties
  • Text marketing programs
  • Periodic Marketing reports tracking views, appointments, and applications
  • Showing services track all agent showings and collect agent feedback

In addition, to our extensive marketing program, Ashoka Lion demands that our Realtor partners also take additional precautions to reduce risk that our marketing is misappropriated by scam artist. These steps include:

  • Watermark Pictures with Brokerage name
  • 3rd party sites must also reference MLS listing number to help tie the 3rd party site ads to the local association MLS site.

These techniques are designed to give potential prospective tenants confidence that our rental listings are legitimate and not some exotic scheme designed to bilk them of their rent money. Therefore, when prospective owners of rental property in Houston and Dallas are looking for a property management firms to help them lease their properties; they can feel confident that the Ashoka Lion team is giving a maximum effort to fill their vacancies.

Ashoka Lion partners with Realtors to preserve their sales business: 4 important reasons

by jay.raman@ashokalion.com 3, April 2011 01:45

Ashoka Lion introduced our marketing program to Realtors, and we have had people asking us what are the benefits to referring the property management/leasing business to our firm in the Houston and Dallas markets.There are 3 easy reasons to partner with our firm to handle this business.

1) Ashoka Lion pays a 25% Referral Fee  After we successfully lease a property, we will pay the referring agent through a check to his broker a referral fee equal to 25% of the final lease price. This is the easiest fee that you can earn as you do not have to do showing, use up fuel for showings, spend time filling out paperwork ,etc. We handle the leasing and property management, and when your client is ready to sell or buy more property; then we return it to the agent who referred us the client.

2) Our primary business is property management and leasing: Our Houston and Dallas property management teams are focused on the business of managing and renting out homes in the Houston and Dallas area. In most Realtor's businesses, this is a time consuming process with very little upside due to the lack of manpower to help assist you in preparing financial statements, recording work orders, paying our repair bills, etc. These are time consuming processes, and they really eat into a Realtor's time and margin.Our leasing packets are very thorough and include processes to make prospective tenants aware of eligbility requirements, screening that goes beyond just a credit check, and providing tenants the option to digitally signing off on lease packets that are almost 60 pages with all the required addendums and sheets.  If we list the property, the agent can still provide leads and get the buyer's agent portion of a commission, but they avoid the responsibilities of screening, advertising, and coordinating showing. Our marketing program for leasing includes listings being included in Rentals.com, RentalHomes.com, Homes.com, GoSection8.com and other sites that require to pay per listing.  Our program includes these marketing opportunities as standard. This is in addition to the marketing that is done through MLS and yard signage.

3) We will honor any noncompete for the sales business: Most agents who cannot manage a home may not take on that business, and in doing so; their clients will find someone else that can provide the property management service. These other Realtors will also position themselves to take on the future sales business in the Houston and Dallas markets with your investor. Our firm will sign a noncompete and return the sales business back to the referring agent, when the investor is seeking out property sales related assistance for this property.

4) Realtors grow their "team": Realtors are often solo practioners in most real estate practices in the Houston and Dallas market. This means that you have a lot of responsibility to growing your practice. With our program, the client can position herself as the "Sales Expert" who has a property management team to handle the day to day property management business. This will impress upon your clients that you are building a niche and emphasize your expertise that makes Realtors today successful.  In addition, by stating that you have a team that you work with,  you can draw yourself into a role of a expert guding your clients with your various connections and resources. This helps once again emphasize that your clients should work with you as your sphere of contacts seems more complete and full service.  Our goals is for successful Realtors is to make clients feel that there is a advantage to working with you versus simply doing the research through all the various online tools at their disposal. By positioning yourself as a person with contacts, resources, and tools; investors will feel that you as their Realtor can make their buying and selling experience more pleasant and less confusing.  Ashoka Lion's property management team is ready to help your Houston and Dallas clients feel like you have top notch operational suppport at your disposal.

As TREC has clarified that agents cannot do property management without their brokers approval including that rents must be collected through Broker trust accounts, the days of agents doing property management "on the side' is not really a option. Check out the TREC Advisor here.  Working with our firm allows you to avoid losing clients to brokerages and agents who can do property management and sales activities, and it also provides you another tool in the tool belt to impress clients. Also, we have a great marketing program to thank the realtors that do provide referrals. Check out a summary of those efforts here.

 

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Ashoka Lion wants to help Realtors Grow their businesses when they refer us property management clients!

by jay.raman@ashokalion.com 26, March 2011 16:33

Ashoka Lion launching a "Thank you for the property management client referral" marketing campaign for Real Estate Agents. It is a quick social media campaign that we will do for our property management client referring Realtors. Social Media is a buzz word, but with this quick campaign, you will gain some exposure without it being perceived as you marketing yourself. Here are the three aspects to our "Thank You" program.

1)www.LionRentalMangaement.com Blog Entry: The basis of the program is that we are providing the agents a blog entry off our property management site that links back to your webpage of choice (as long as it is related to your business). Also, if you provide us a bio about yourself and the type of clients that you work with or areas, we will intertwine that in our blog entry off our website (www.LionRentalManagement.com).  The bio will give visitors about the type of practice that the Realtor has, areas that they provide service, and any other information that will personalize the Realtor to visitors who read the "thank you" blog entry.
 
2) FaceBook Marketing: www.FaceBook.com/AshokaLion   We will market the property management "thank you" blog entry on our FB business page that will state "We got a great referral from "JOHN or JANE DOE REALTOR, and we wanted to let you all know about him/her. Check out their story at XXXX.com".   Your also welcome to "like" our Business Page so our update will show up on your Facebook page wall.  This will allow you to share this update to your friends if you have a facebook page.  By "sharing" or "liking" that particular entry, the entry willl show up on your Facebook page wall that your friends and family can see.   This is a subtle marketing announcement that will remind all your facebook friends that you are in the Real Estate business.
 
3) Twitter Marketing: We will blast this property management blog entry on our Twitter account: www.Twitter.com/AshokaLion that has over 500 followers. If you have twitter, you can pass it along (Retweet) to your friends.  This is another method that you can let clients and followers know that you do real estate and a little about your practice.
 
We hope this exposure will be good for our Realtor referral partners, and we hope that our Realtor friends will continue to see our property management team as a valuable asset to their real estate practice. Additionally, the link to your real estate website or profile in our blog entry will be credited as a "quality" link in regards to search engine optimization as our site is a real estate related site that is constantly adding content and updates regarding real estate. Basically, we will be assisting your website in being found by Google or other search engine searches.

Thank you for providing us property management referrals in the Houston and Dallas area markets, and we look forward to working with you in the future as well.
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Survive and thrive by "Going Green and Going Mobile".

by jay.raman@ashokalion.com 22, March 2011 14:49

Today, our economy is facing a double whammy in that we have weak economic data and we also see further cutbacks in governmental support.  For Ashoka Lion, this is just another feather in our cap for thriving and improving our firm's property management services during these difficult times. Since 2008, the real estate market has been in a tail spin, and most economic indicators indicate that it will continue to be weak market for forseeable future. Investors cannot get lending to buy investment property, and so it limits the potential pool of real estate investors that are buying in the Houston and Dallas markets.

Our property management firm saw the writing on the wall, and we decided to reposition our value proposition in this real estate market. Instead of cutting back and shriveling up  to wait out these economic times, Ashoka Lion has expanded our property management service offering every year.

Since 2006, here is a list of improvements that we now offer real estate investors and tenants:

  • Online Rental Owner Portals with financial reporting including income statement, balance sheet, and rent roll
  • Online tenant portals with tenant statements
  • Online document storage of leases
  • Online rent payment option for tenants
  • Online rental owner disbursements
  • Electronic calendars accessible by Mobile phones for property managers
  • Property managers telecommute into our property management system
  • Voice Over IP Phones routed to property managers
  • Electronic disbursements of Vendor Payments for services done for properties
  • Tenants can provide us written notice of repairs or move outs via our online portal
  • Property repair Work Orders are emailed to Vendors
  • Digital approval of Estimates and Documentsby Rental Owners
  • Use of Electronic Signature Programs for Leases
  • Tenants can now pay rents over the phone
  • Mobile friendly riders to Text to get information about Listing and Vacant Properties
  • QR Bar Codes on sign riders to get information about Listing and Vacant Properties
  • Vendors were instructed to fax or email over invoice versus mailing us paper invoices
  • Online rent application for our properties that can be found at www.LionRealEstate.com
  • Providing tenants a letter of top energy saving ideas to reduce down electricity usage
  • Our website's "Green Lifestyle" Section 
  • Expanded our property management operations to the Dallas, Texas area
  • And More!

Do you see a pattern in our improvements? Yes, our property management firm focused on being "Green" and mobile.   We decided that we could not build a business in the traditional mode to server our property management clients in the Houston and Dallas markets, and so we tailored our property management business to be built on a mobile platform that reduces down as much waste as we can.  In Houston,  our property management team got rid of our former office space near downtown Houston.  We shifted to mobile platform that agents  and property managers access from home or  on their mobile phones. This saves us in cost related to overhead for rent, storage space,etc. In addition, our property managers do not waste time driving to the office to do their work,  and so they are generally happier with the arrangement. Our business structure allows us to save in several ways that benefit our bottom line, but these improvements have also benefited our company in our goal to be one of the "greenest" management companies in the property management industry. Our tremendous financial savings also translated to environmental benefits including:

  • mileage lost to commuting to office
  • paper consumption printing invoices to store in paper files
  • paper printing for leases
  • mileage spent driving to collect rent

In fact in 2010, Ashoka Lion was selected as one of the top case studies by our digitial contract and document approval vendor (http://bit.ly/fnzaa0 ).  I know that our property management team is not perfect, but we are trying to improve our property management services for our rental property owners by relying on state of the art technology to maximize efficiencies and reduce our carbon footprint.  We could have waited to be a late adopter to technology or try to do business in a more traditional manner, but these difficult economic times requires us to think in new bold ways; if we want to thrive. If the old adage is that "the early bird catches the worm", then isn't it easier to catch the worm if you are mobile and nimble?

 

What is normal wear and tear? 6 techniques to reduce down issues with tenants

by jay.raman@ashokalion.com 15, March 2011 11:28

I came across a article on the AshokaLion Twitter account, and it got me thinking about "wear and tear" clauses in leases. Every lease has a "wear and tear" clause in it, but it always remains a vague concept. I decided to research what other investors and real estate sights came across, and I found most had the vague notion of the wear and tear clause. I did find one article by Rental Housing Online (http://bit.ly/gklzFl) and they had a pretty good list. It definitely was not exhaustive, but either is our addendum that we provide to tenants at their walk through with our property managers upon moving in.  We have tried to provide a list of common types of damages, explainations what we consider to be "normal", and we try to explain to them what potential charges may be upon them moving out (at least some minimums that we have come across). We know this is not a complete list, but it is impossible to have a complete list due to all the circumstances at the property (including condition of the property at the time of  tenant moving in and age of the items).

I know it is impossible, but we do try to explain that "normal" is based on reasonable standards. For example, we state that scuffing a wall and it needing to be repainted is not "normal".  However, it is "normal" to have a rug steam cleaned with a rug doctor machine. However, if I have to get a commercial cleaner to take out damages to a carpet, then this should be considered "excess" of normal wear and tear".  As a kid growing up in the Houston area, my family lived in a home for over 10 years as kids, and when we moved from that home; our family was able to cleaned our carpet  to make it presentable.  It is not a huge leap of faith to think that our care was not extraoridinary, and this is why our property managers in Houston or Dallas do not understand tenant's claims that it is normal to have punch stains in the floor or bleach on the floor. 

Typical things that we would deduct from the security deposit for include:

  1. Scuff Marks on walls requiring us to paint
  2. Nail Holes in Walls
  3. Damages to windows
  4. Broken Knobs on ovens or stoves
  5. Unreported leaks that cause damage to cabinets or floors
  6. Carpets requiring commercial carpet cleaning
  7. Smoking in the house and it sticking to walls and carpet (we request all tenants if they smoke to smoke outside the house).
  8. Pet Urine requires us to get  a professional cleaning
  9. Lost Keys
  10. Unreturned Garage Remotes
  11. Food left in the refridgerator (if mold is in the refridgerator, then we may just replace refridgerator)
  12. Broken door knobs
  13. Missing Smoke Detectors after it was installed
  14. Blinds damaged
  15. Carpet that burn marks or bleach stains (replacing room carpet)

I know that there are horror stories for tenants about items being charged that they would not consider normal wear and tear. To reduce these confrontations between tenants and landlords or tenants and property management companies in the Houston and Dallas area, I would suggest doing the following:

  1. Fill out the Inventory and Condition Form within the requested time and keeping a copy. Many real estate agents and property managers will give you this form to fill out, so I would strongly urge you to do.
  2. Take Pictures and/or Video.  You, your property manager  and/or real estate agent should take pictures and/or video of the property at the time of the move in. I would make sure to have the correct time stamp on videos and pictures, so you can demonstrate what condition the property is at move in.  As you usually are given a few days to finish documenting this form, it is not hard for tenants to document with video and cameras damages.   I would suggest sharing this with landlords and managers as soon as possible to make them aware of these damages that you find subsequent to the move in walk through, if you want to claim it on your inventory and condition form.
  3. Report damages quickly. Landlords can charge tenants for damages that they fail to report on a timely manner that get worse. For example, if you see a leaking pipe under a kitchen report it, as it may lead to damaging the wood in the cabinets.
  4. Know how to shutoff toliets and cut off water at the main water cutoff. If you see water flowing, know how to cutoff the water at the main water cutoff. This will reduce down damages that remain that could have been prevented.
  5. Do not use items that you know are possibly damaged. If your AC is having problem, shut the AC off to prevent further damage because you used it after it was having problem. The same could go for appliance, disposals, and anything else that you fear may not be working. You should report these items and take the appropriate precautions. These kinds of damages could be grounds to deduct part or all of a repair cost for the matter.
  6. Keep up your preventitive maintenance. If your home has a AC unit, then I would suggest changing the filters to avoid damaging the system. Unpaid repair costs in our leases can be deducted from the security deposit.

I know that some of our real estate investors probably have more examples, so if you do not mind sharing on our Facebook page (http://on.fb.me/dQDvrM) that would be great. We will post a discussion under that tab to collect feedback and input regarding example of what is and is not considered "normal wear and tear", and while you are there; please do not hesitate to "Like" our facebook page.

If anyone has dealt with court cases that involve these issues, then feel free to share this as well in our discussion section. We would love to see how any of our Houston, Dallas, Texas, or any courts around the United States for that matter adjudicate these standards.