About typical violations of the law when electing the chairman of the HOA board

Who is the chairman of the HOA?

The chairman of the HOA is the head of the board. He is elected from among the members of the homeowners' association (based on the provisions of paragraph 3 of Article 147 of the Housing Code of the Russian Federation), unless otherwise reflected in the charter of the HOA: often the charter leaves the right to choose a manager to the general meeting.

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The provisions of paragraph 2 of Article 147 of the Housing Code of the Russian Federation state the following: the chairman of the HOA, like other members of the board, must be a member of the partnership. That is, he must have an apartment or plot in this apartment building. However, he is not required to live in this territory.

As stated in the above article, the head of the HOA board is not required to issue a power of attorney in order to protect the interests of the owners: his assumption of this position indicates that the majority of the board members trust the chairman.

For your information

If we talk about how it happens in practice, people often go to the chairman of the HOA if certain difficulties arise. That is, he must monitor the energy supply, the functioning of the elevator, and perform other household duties - both within the premises and in the area near the house.

Advice for an apartment building with an HOA

If a homeowners association has not been created in an apartment building and there are more than four apartments in the building, the owners at a general meeting are required to elect the council of the apartment building. In this case, the council operates until re-election at the general meeting or, in the case of a decision to create a HOA, until the election of the board of the partnership (Parts 1 and 9 of Article 161.1 of the Housing Code of the Russian Federation).

In practice, questions arise about the legality of choosing a house council where there is an HOA, at least formally existing as a legal entity. For example, the author is familiar with a case where the management organization refused to recognize the powers of the house council only on the grounds that the HOA that once managed the house a long time ago was not finally legally liquidated.

There is little practice on this issue; I have summarized a few examples.

Appeal ruling of the Moscow City Court dated April 24, 2019 in case No. 33 – 9803/2019

The owner did not like the change in the management method and went to court, where he asked to declare, among other things, the choice of the house council illegal. However, the court refused:

the creation or election of a new management organization means the termination of the rights of the management organization or another manager, including an HOA, who previously exercised management functions;
election by the general meeting of another method of management is grounds for termination of management of the TSN house;
Considering that from the moment the general meeting of owners makes a decision to change the management method, the powers of the HOA to manage the house actually cease, in addition, time is required to resolve the issue of liquidating the HOA and formalizing the powers of the management company, including the issue of electing the chairman and members on the agenda for the general meeting council of an apartment building is acceptable.

Ruling of the Seventh Court of Cassation of General Jurisdiction No. 88 – 191/2019 – upheld the appeal ruling of the Perm Regional Court in case No. 33 – 9588/2019

The owner filed a claim against the HOA to invalidate the decision of the general meeting of owners and members of the partnership on the agenda items “Approve the composition of the House Council”, “Instructing the House Council to sign a management agreement with Parus Management Company LLC.” The plaintiff believed that the creation of a house council contradicts the provisions of Article 161.1 of the Housing Code of the Russian Federation. “In addition, the board of the HOA was elected, while the Council was given the right to sign, on behalf of the owners of the premises of the apartment building, a management agreement with LLC Management Company Parus, in violation of the provisions of the HOA Charter.”

The court refused to satisfy the owner's demands. At the meeting, decisions were made: to elect the composition of the board of the HOA, the method of managing the apartment building - management of Parus Management LLC, to approve the transfer of the apartment building to the management of Parus Management LLC, to elect the composition of the council of the apartment building, to instruct the house council to sign on behalf of the owners management agreement.

the election of a house council does not contradict the provisions of the law, since the decision to create a house council is derived from the decision of the owners to change the method of management, which is not disputed;
the creation of a building council is a necessary measure when changing the way an apartment building is managed, including when transitioning from the management of a building by a homeowners’ association to a management organization.

The courts rejected the tenant’s arguments that the existence of two building management bodies at the same time, such as the building council and the homeowners’ association, is not provided for by law, while the meeting did not decide to liquidate the HOA, “since the law does not contain a ban on the creation of a building council, in including when managing a house by a homeowners’ association, since in this case the law provides for other legal consequences, namely the exercise of the powers of the house council, provided for in Art. 161.1 of the Housing Code of the Russian Federation, governing bodies of the homeowners’ association.”

Appeal ruling of the Samara Regional Court dated October 22, 2014 in case No. 33 – 10476/2014

The owner of the house did not agree with the decision of the meeting to create a HOA and initiated his own meeting, where they elected members of the house council and chose another management organization. The court declared these decisions illegal due to violations during the meeting, and regarding the council, the court stated: “the agenda of the general meeting indicates the issue of choosing the council of an apartment building and the chairman of the council of the apartment building, which is not permissible, since a homeowners association has been created in the building and it not liquidated."

Please note that the decision to select a management organization was also declared invalid.

Appeal ruling of the Moscow City Court in case No. 33 – 10171/2017

The house was managed by a partnership that was formed to manage several houses. The owners of one of them decided to go under the control of a management organization. They held a meeting on the issues of choosing the council of the house, the management organization, “exiting the HOA” and “excluding the house from the HOA.” These decisions were declared invalid by the court. According to the owners who challenged the decision, if there is a board of the association and the homeowners association itself as a legal entity, the house council cannot be elected. The court upheld the statement: “the presence of a partnership board and a house council in the same house is contrary to the norms of the current legislation.”

Regarding the choice of a management organization, the court indicated the need to reorganize the partnership in the form of a spin-off.

Appeal rulings of the Saratov Regional Court in cases No. 33 – 2927/2019, No. 33 – 55/2018

The same stories happened as above: the residents of one of them wanted to leave the HOA for several houses. At the meeting, they chose a new method of management, a management organization, a house council together with a chairman. And again, the court wanted to see the reorganization of the partnership before changing the method of management, and also declared the choice of the house council illegal:

“Taking into account that the decision to choose management of the house by LLC Management Company “Solnechny Gorodok” was declared invalid, and the disputed house is part of the homeowners’ association, there were no legal grounds for choosing the house’s council.”

Thus, usually the courts are calm about the choice of the council of a house during the transition from an HOA to a management organization, provided that the decision to choose a new method of management is not recognized as illegal.

Normative base

The activities of the HOA chairman are regulated by the regulations of the Russian Federation. Of course, first of all we are talking about the Housing Code of the Russian Federation.

Alas, its provisions do not contain a separate article directly on the personality of the chairman. But, despite this, there are separate fragments taken from norms and other provisions. They record the following: the chairman of the HOA has the right to manage the board and make additions and changes. He can perform other functions that are not available to other members of the partnership. We'll talk about them a little later.

Attention

The activities of the partnership are also regulated by local regulations. It is accepted by the residents of the apartment building themselves. The document also contains the rights and responsibilities of the chairman of the HOA. As a rule, we are talking about a charter, which reflects all the features and nuances.

To draw up the Charter, it can be used as a standard model - with formulations and interpretations that are well known to everyone, as well as a non-standard one - if the general meeting of residents decides to add some of its own provisions to it.

Who is eligible?

The choice under the Housing Code of the Russian Federation can be carried out by two bodies. The first is the homeowners association board, which consists of active homeowners. They can choose a new candidate based on their own considerations and recommendations .

The second body that has the right to elect a leader is the meeting of owners of premises in an apartment building.

Typically, this method is used when it comes to the initial election of a person as chairman.

This body has great influence and can even overturn the board's decision.

You can download samples of employment contracts and job descriptions for all HOA employees, as well as other important documents, receipts and certificates on our website.

Who can become the chairman of the HOA board?

A candidate for the position of HOA chairman must meet the following main conditions:

He must have his own apartment directly in the building whose residents elect a leader. It will be better if he lives in it permanently, because no one will want to trust the future chairman of the partnership with all responsibilities if the apartment is rented out under a lease agreement, and the owner himself lives at a different address. This person will not be aware of the real difficulties at home, which means he will act ineffectively.
He must have a higher education. The ideal option is if the future manager has already worked in a senior position in some organization. This will make it easier for him to negotiate with service providers, hold meetings, and distribute functions among board members.

Additional information
A citizen who has leadership qualities can become the chairman of an HOA. He must be able to quickly make a variety of decisions.

How to become a manager of a partnership?

As a rule, the chairman of the HOA is selected through the following steps:

By voting in person - if it was possible to obtain the quorum required for this method.
By voting in absentia - if it is impossible to record decisions made due to a lack of the required number of votes.

Based on the provisions of Article 48 of the Housing Code of the Russian Federation, the votes of owners are taken into account in proportion to the size of the ownership share of each of them.

How to choose a chairman if voting is in person:

Initiative owners of residential premises in apartment buildings are united into a specialized group.
A list of issues that need to be resolved during the meeting is outlined. The chairman of the board is elected in the same way.
Members of the association must learn about the upcoming meeting either in person or by written notice.
Next, a meeting of apartment owners is held. If a sufficient number of votes is collected, a protocol of closed questions on organizational aspects of the organization’s functioning is drawn up. This also includes issues related to the formation of the board and the selection of a leader.

IMPORTANT
If the meeting in person was not attended by most of the owners of residential premises, the initiators proceed to organize voting in absentia.

This method of expressing will differs from the first only in that the results are formatted as questionnaires. Personal data about the owner, details of the title documentation for the apartment are recorded, and a written response to requests for the meeting agenda is sent. There are only three ways to submit an answer: for, against, and abstain.

Detailed step-by-step instructions

Most often, the election of the chairman takes place in 2 stages:

in-person voting , when it is possible to collect the quorum necessary for making decisions;
meeting in the form of absentee voting - if it is not possible to record the decisions made due to a lack of the required number of votes.

According to Art. 48 of the Housing Code of the Russian Federation, votes of owners are taken into account in proportion to the size of the share of ownership (room area) in the apartment building of the voting participant.

Stages of selecting the chairman of the board of a homeowners' association through in-person voting

association of initiative homeowners of apartment buildings into an organizational group.
determining the range of issues to be resolved during the meeting, including the election of the chairman of the board;
notifying HOA members about the upcoming meeting in person or in writing;
holding a meeting of owners of residential premises and, in the case of a sufficient number of votes, recording in minutes closed issues on the organization of the activities of the HOA, including the formation of the board and the election of the chairman.

If the majority of owners were unable to attend the in-person meeting , the initiative group will organize absentee voting.

The only difference between this type of expression of will and in-person voting is the registration of the results in the form of a questionnaire, indicating the passport details of the owner, details of the title document for the residential premises and a written response to the questions on the meeting agenda. The answer can be presented in only three options: for, against and abstained.

Selection Protocol

Since the HOA is considered a legal entity, a chairman is also appointed taking into account the measures outlined in the legislative acts of the Russian Federation:

The minutes of the meeting of the board or members of the HOA are drawn up and signed. It should record the majority opinion regarding the selection of a new leader.
On the basis of the above document, the elected leader issues and signs an order to assume a new position.

To draw up such an order (instruction), either the unified form No. T-1 is used (it was approved by the Resolution of the State Statistics Committee of Russia dated January 5, 2004) or a free form.

The following must be indicated:

Full name of the person taking office.
The temporary period of his powers.
Address of the house that will be supervised by him.
Date, personal signature.

The protocol for selecting the chairman of the HOA can be found here.

Order to take office

The HOA is a legal entity, therefore the appointment of the chairman must occur in compliance with the procedures prescribed by law:

the meeting's decision to elect a chairman by a majority vote is reflected in the minutes;
Based on this protocol, the elected chairman issues an order for the appointment of the head of the HOA.

The order is drawn up in form No. T-1, or in free form.

Instead of the chairman, a manager who is not a member of the HOA, but capable of managing the affairs of the partnership, can be hired. This possibility and powers of the manager must be written down in the charter.

Responsibilities of the chairman of the HOA

The responsibilities of the chairman of the HOA are specified in Article 148 of the Housing Code of the Russian Federation. The most famous and widespread of them are:

Monitoring decisions made by board members. When analyzing the proposed arguments, the chairman must not forget about the interests of each of the parties.
The chairman must issue orders to each officer working for the benefit of the partnership. Instructions can be of a very different nature, the most important thing is that each of them relates to the maintenance of an apartment building.
The chairman of the HOA must carry out all activities on behalf of the partnership. That is, open an account and withdraw funds from it for the needs of the house. He must also report - both to the members of the board and to all residents.
The manager must sign on each payment document - this serves as a guarantee of confirmation that he is monitoring cash flows.
The chairman of the HOA must ensure that all employees of the association comply with internal regulations if this could in any way affect the territory they serve with the building.
The chairman must pay salaries to employees (those who maintain the premises).
Also, the chairman of the homeowners association is obliged to attend all meetings of apartment owners and implement all decisions made at them.

The legislative framework

A homeowners' association is a state-registered voluntary non-profit association of owners of premises located in housing construction, with the goal of creating conditions for high-quality housing management. The procedure for the formation and functions of HOAs are regulated by the Housing (LC) and Civil (CC) codes of the Russian Federation.

Every adult owner of premises in a housing construction who has declared membership in the organization in writing becomes a member of the partnership.

The highest management of the partnership is carried out by the general meeting. It adopts the HOA charter.

The current management of the functioning of the HOA is carried out by the board. Its powers are enshrined in the charter on the basis of Art. 147, 148 Housing Code of the Russian Federation.

What powers does the chairman of the HOA have?

The list of rights of the HOA chairman is extremely wide.

This manager has the right to:

reversal of decisions made by the board;
making proposals at meetings of owners;
reduction of employees due to certain circumstances (the main thing is that the provisions of the Labor Code of the Russian Federation are observed);
receiving remuneration in a strictly fixed amount;
making personal additions and changes to decisions made by the board.

Most of the rights of the chairman of a homeowners association are fixed in the HOA charter. We can also talk about non-standard clauses, the most important thing is that their initiators are the apartment owners. Only then will they be legitimate on any of the grounds.

What to do if the chairman of the HOA does not fulfill his duties

Very often the question arises: where can one complain about the chairman of a homeowners association? Such provisions are enshrined in law. According to them, first of all, the conflict can be resolved by appealing to the board of the HOA. Citizens are also given the choice and right to appeal to the Housing Inspectorate, the prosecutor's office or the court. The latter is used very rarely. This only happens in a situation where the chairman’s actions are clearly illegal.

Most often, he is simply removed from his position and a new manager is chosen. This possibility must be spelled out in the HOA charter.

Responsibility

Attention
If the chairman of the HOA does not fulfill the duties assigned to him, he may be subject to sanctions prescribed in the charter of the partnership. For example, he may be removed from his position ahead of schedule.

The use of penalties depends on the essence and nature of the violation committed. Let’s say that if a citizen spent the money donated by the tenants on his personal needs, they can be taken from him by decision of the court. If it turns out that he committed fraudulent actions, he may be subject to criminal liability.

Grounds for holding elections

Initially, elections for the chairman of the HOA are held when the partnership is created. Without this stage, registration of this organization is simply impossible. But even in the course of its work, it may become necessary to determine the head of the board, for example, in situations where:

the term of office of the chairman, prescribed in the charter of the HOA, has expired;
the head of the board resigned from his position at his own request;
one of the residents made a proposal to change management;
Significant violations were discovered in the work of the HOA or the current chairman.

In the latter case, government bodies and regulatory authorities (for example, the prosecutor's office or housing inspection) can initiate the election of the chairman of the HOA board.

As for changing the head of the board at the initiative of residents, such a proposal can be made by any of the owners of real estate under the control of the partnership.

Job description

The main provisions of the job description of the chairman of the HOA board are as follows:

The selection of the director is carried out by the members of the board. The goal is to manage the activities of the partnership.
When performing his official duties, a citizen is obliged to comply with Russian laws and local regulations. It is also mandatory to comply with the provisions of regulations and your job description.
The manager is obliged to conscientiously perform the functions assigned to himself.
Since the chairman directly manages everything, he has the right to provide orders to each of the HOA employees.
The chairman is responsible for monitoring the implementation of all regulations and decisions of the partnership.
The citizen must develop and submit for discussion to the members of the HOA rules regarding the calculation of wages, working conditions and the schedule of employees of the partnership.
The head of the HOA protects the interests of citizens before all authorities.

Is the chairman’s working day regulated?

In this case, everything depends on what is stated in the HOA charter. As a rule, a standardized working day is not established, since when managing an apartment building there is no need to constantly be at the workplace and resolve certain issues.

Is vacation allowed?

If an employment contract has been concluded with one or another member of the board of a homeowners’ association, then he has the right to paid leave of 28 calendar days. Even if such an agreement is not concluded, there is still a chance. You just need to submit an application to the board of the partnership!

During the absence of the chairman, his duties will be assigned to his deputy; the HOA board, if necessary, can also take over his work. You can read more here. ⇐

Does the HOA chairman receive a salary or remuneration?

To calculate whether the HOA chairman receives a salary or remuneration, you must first clarify the basic terms.

What is an HOA? The organization is a legal entity, that is, an institution that includes citizens - owners of apartments in an apartment building. Any member of the partnership (including the chairman) must try to take every possible action to improve and maintain the premises. That is, each of them is obliged to ensure that the apartment building is in good condition. And this must be done for free.

The manager of the HOA is called the head of the partnership. This is a citizen whom the residents have nominated to control the affairs of others. In addition, it performs other functions required to keep the apartment building in good condition.

The provisions of the Housing Code of the Russian Federation, and specifically, Article 147 states that the following cannot act as the chairman of a partnership:

a person interacting with the HOA on the basis of a management agreement;
member of the management company;
member of the audit commission body of the partnership.

Also, such a person is prohibited from assigning or transferring his own powers or responsibilities by different methods. It is not possible to conclude an employment agreement with the partnership.

For your information

The provisions of Article 147 state that the chairman of the HOA is elected from the board structure. The exception is situations when such responsibilities are assigned to the general meeting of the HOA. In life, decisions are almost always made by board members. The head of the HOA must be a member of the board.

From all that has been said above, we can draw the following conclusion: a member of the board has a chance to occupy the position in question. That is, he is subject to the same restrictions as other participants in the partnership. Thus, the law does not require a salary for the position of HOA chairman.

Attention

And although there is no labor agreement, the chairman of the HOA is paid a remuneration. The basis for the payment is the Charter of the HOA. That is, the work activity of the chairman of the homeowners’ association is compensated by certain finances. In fact, this is a real analogue of wages, which allows you to bypass legislative restrictions on the conclusion of labor agreements by members of the HOA board.

Responsibilities of the Chairman

organizing cooperation with companies providing utility services;
supervision over the good condition of utility networks and other common property of housing construction;
interaction with owners who have not joined the HOA;
preparation of technical documentation for repair work;
control over the collection and expenditure of partnership money.

The activities of the chairman should be based on the provisions of the Housing Code of the Russian Federation and the job responsibilities approved on this basis.

The operation of the management of an apartment building by a partnership of premises owners will be effective if the elected board and chairman are competent, proactive, decent, quickly find the necessary solutions and are ready to be responsible for the assigned work.

Reward formation

It is worth noting that to establish the remuneration of the chairman of the HOA, 2 acts are used at once. This helps to eliminate corruption, fraudulent activities, and various frauds on the part of members of the HOA board. The first act on the criteria for calculating remuneration is the Housing Code of the Russian Federation. It sets out standard requirements, on the basis of which any partnership has the right to form a personal list of criteria - the HOA Charter.

As a rule, the Charter does not specify any complex calculation formulas - the matter is limited to the fact that the chairman of the HOA is paid a specific percentage of the amount of services performed in the apartment building.

IMPORTANT

The percentage – the manager’s salary – is determined directly by the residents themselves or members of the HOA board. If there are no objections, this amount can be any. But there is one condition - this should not seriously affect the amount of funds covering the needs of the MKD.

Calculating remuneration for the head of an HOA is a process that requires separate study, because it has serious differences from standard accounting transactions. To organize it, the owners must hold a meeting on a specific day. As a rule, for such cases, invitations are used in written form.

To correctly process the salary of the HOA chairman, it is necessary that the general meeting is attended by at least 50% of apartment owners. If the turnout is too small, the meeting’s decision will not enter into legal force.

The established procedure states that the manager is obliged to provide citizens with an estimate for the services provided. After the procedure is completed, minutes of the HOA meeting are drawn up. It records the progress of the process and its outcome. It is written down what amount will be the chairman's remuneration. The salary itself can be cashed by the manager after submitting the protocol to the tax office. If there are no violations and all requirements are met, he is paid the amount of remuneration for the services provided.

Report of the Chairman of the Board of the Homeowners Association

When choosing the chairman of the HOA board, the following responsibilities are taken into account:

Drawing up the partnership budget for the year.
Monitoring every payment.
About hiring new employees. This also includes the obligation to reduce staff.
On maintaining accountant reports.
Holding meetings.
On maintaining current lists of partnership participants.
On the performance of secondary duties, based on the provisions of the charter.

Chairman of the board of the HOA and simply the chairman of the HOA: what is the difference

The Board is the highest executive body of the HOA. The chairman is an analogue of the general director in a legal entity. These are completely different positions.

The chairman of the board, in fact, is the head of the board and is not vested with the official powers of the director of the HOA.

In some management structures, there is a practice of combining these positions into one. This is fundamentally wrong, as it violates the provisions of housing legislation. This is due to the fact that the HOA board and the chairman must exercise control and supervision over each other’s activities, and if these positions are combined, this is not possible.

Vacation

The head of a homeowners association, like any other official, has the right to go on vacation.

And, although the functions of the chairman are not considered to be the labor sphere, the charter secures his right to receive leave. The maximum number of days the HOA chairman can be absent reaches 30.

Of course, while the manager is on vacation, the partnership is forced to resolve some of the issues on its own.

Additional Information

Any member of the board can act temporarily as chairman. But for this he must be elected in advance. The meeting of owners examines the applicant (whom the chairman himself proposes), and if no one objects (majority vote), the candidacy is approved.

While the manager is on vacation, his deputy performs all duties and enjoys all the rights imposed on the chairman. He has the right to make important decisions, make changes, hold meetings and put personal signatures on payment documentation.

Immediately after the chairman returns from vacation, the deputy relieves himself of his assigned duties and transfers them back.

Actions after re-election

A homeowners association is a legal entity. Accordingly, any changes in its board must be recorded with the tax authority at the place of registration. To do this, after familiarizing the new chairman with the order of appointment, the secretary of the HOA, or one of the board members performing secretarial functions, must prepare the following package of documents:

a copy of the minutes of the general meeting of the partnership;
a copy of the new chairman’s passport;
a copy of the organization's charter;
extract from the Unified State Register of Legal Entities;
copy of OGRN;
a copy of the appointment order;
application for assumption of office by the selected citizen.

All copies are notarized, after which the new head of the board submits them to the local branch of the Federal Tax Service. After checking the submitted papers, the tax service makes appropriate changes to the register of legal entities. At the end of this process, the new chairman is given an extract from the Unified State Register of Legal Entities, where he already appears as the head of the HOA. After this, the newly elected head can begin to perform his duties.

Important! Submission of documents to the tax office must be carried out no later than 3 days from the date of summing up the voting results.

Re-election of the chairman of the HOA by the board

The change of the head of the HOA is carried out as follows:

First, one citizen makes a proposal that it is necessary to change the chairman of the HOA. We can talk about either one owner of a residential premises, or an initiative group, as well as a board.
After this, a meeting is required to be convened to provide information that may influence the citizens' choices. The most important condition is that it should not be fictitious, but real.
Next, a vote of owners is held. If almost all of them wish to change the manager, the procedure is documented. If there are a minority of votes, nothing changes - the chairman of the HOA continues to occupy his workplace.

Dismissal

The chairman of the HOA and the organization itself enter into labor relations.

The work of such employees is regulated by Chapter 43 of the Labor Code of the Russian Federation.

Attention

Based on the provisions of Article 280 of the Labor Code of the Russian Federation, the chairman of the HOA has the right to early termination of the employment agreement, with prior notice. The form must be in writing. Term – no less than 30 days.

In other words, if the chairman of the HOA entered into an employment contract, he can resign on his own initiative, giving the HOA one month’s notice.

Nuances

It is important to note the following: the chairman of the HOA and the manager perform similar functions, but there is still a difference between these categories of persons. The chairman of the HOA is elected from among the apartment owners and is primarily responsible for performing representative tasks. He organizes and conducts meetings, records the decisions made at them, and monitors how the board functions.

But the manager works mostly with such categories of persons as: contractors, service institutions, local administration. It happens that an MKD has both a chairman and a manager. In such a situation, it is the latter who submits to the former. But, most often, all of the above functions are performed by one chairman.

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Ways to select the chairman of the HOA

The election of the chairman of the HOA takes place according to one of the following options:

Organization of a general meeting, at which more than 50% of homeowners are present.
Decision-making by persons included in the management. The chairman of the HOA is elected from among its members.

The first method is a priority, since the majority of residents trust the person chosen for the position of chairman. The official is elected for the period provided for by the HOA charter. The law establishes that it cannot exceed 2 years.

What is a HOA and how to organize it - read this article https://realtyinfo.online/5989-instruktsiya-po-otkrytiyu-tszh-mnogokvartirnogo-doma