HOA may amend parking rules without recording the amendments

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Facts: The covenants, conditions & restrictions (CC&Rs) of a homeowners’ association (HOA) prohibited the HOA from discriminating against owners when creating or amending its CC&Rs. An owner of a unit in the HOA parked an inoperable vehicle in front of his garage. The HOA amended its parking rules to prohibit inoperable vehicles from parking in front of any garage in the association. The owner did not move his vehicle and the HOA had his vehicle towed.

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