Communities warn ODSEC restricts participation in proposed regulation of property titles

On March 19, 2025, Governor Jenniffer González Colón, together with the Department of Housing, delivered 90 property titles to families in the Bayamón region, which includes Toa Alta, Toa Baja, Dorado, Cataño, Comerío, and Vega Alta.

By THE STAR STAFF

Community organizations are raising alarms over what they describe as another misstep by the Office for Socioeconomic and Community Development (ODSEC) in the process of approving a new regulation governing the issuance of property titles under Law 115‑2025. 

The groups argue that the agency has restricted public participation and failed to hold required public hearings, despite thousands of families having waited more than a decade for formal title to their homes.

Firm, United, and Resilient with the Legal Profession (FURIA, Inc.), an organization that provides free legal and procedural support to community groups, said the draft regulation contains serious deficiencies and that ODSEC’s approval process contradicts its mission of promoting community empowerment. “We have serious concerns about the content of the draft regulation and about the way ODSEC has conducted the approval process,” said FURIA’s executive director, attorney Nayda Bobonis Cabrera.

Law 115 was enacted to address a longstanding problem: families in numerous communities, including designated special communities have spent more than 10 years waiting for property titles. A similar effort was attempted in 2012, when the Department of Housing was authorized to issue certifications under Law 82‑2012 and adopted Regulation 8254. Despite those measures, the problem persists.

FURIA noted that ODSEC initially granted only 15 days for public comment on the draft regulation—half of the 30 days required under the Uniform Administrative Procedures Act (LPAU). The organization submitted a detailed statement within that shortened period, requesting that ODSEC correct the deadline and hold public hearings. ODSEC later issued a new notice with the proper 30‑day period, which expires July 8, but has not scheduled hearings.

Attorney Juan Capella Noya of FURIA emphasized that ODSEC has a history of limiting public comment periods. In 2023, community leaders successfully sued the agency for shortening the comment period on Regulation 9457, leading the court to nullify the regulation. In its ruling, the court warned that agencies cannot reduce public participation to “the illusion that comments are taken into account.”

Among the amendments proposed by community residents is a requirement that ODSEC process applications and issue title certifications within 90 days, with the option of an extension if the applicant agrees. Another proposed change seeks to prevent applicants from being denied certification simply because the Municipal Revenue Collections Center (CRIM) has not assigned a cadastral number to the property—an issue FURIA argues should not block families from receiving titles.

Community leaders also want the regulation to explicitly allow applicants to replace lost or irretrievable documents with a sworn statement supported by letters from community boards or neighbors. They say the omission could leave many families without a viable path to complete their applications.

FURIA urged ODSEC to hold public hearings and engage directly with affected communities before finalizing the regulation. “ODSEC has the opportunity—and the duty—to adopt a new culture of community empowerment,” Capella Noya said. “Dialogue with the communities is indispensable to ensure the most just and appropriate regulation.”