California Condo & HOA Law: June 2007 Archives

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June 20, 2007

May Residents Plant Flowers in the Common Area?

You would not believe how troublesome this subject can be. Here are some questions that have been sent to me on the topic:

Is the Board of Directors allowed to allow homeowners to alter the landscaping outside their units? ... What happens when residents plant flowers or trees in the common area, who maintains them? .... We have a disaster. Residents in our association have taken over the common area for gardens, yes! They are planting tomato plants right in the front yards. ...

The short of it is this: Usually, the Board would be allowed to allow residents to plant in the common area. That is because usually, the documents for the Association give the board authority to regulate maintenance of the common area. There could be restrictions or prohibitions on it, so look closely at the documents. Now the question: is it a good idea?

It is interesting how diverse the opinions of Boards are on this. Some boards want to retain the "cookie cutter" look where everything needs to look exactly alike and in that case a Board would probably be against letting owners do anything. Then, at the opposite end of the spectrum, there are the Boards that let residents do whatever they want to do. In these cases, a common problem is that residents get excited about planting, but not the ongoing maintenance of the planted areas, and then the Board becomes responsible for making decisions about what to do. If they try to remove the plants, the residents scream; but if they don't, the neighbors scream.

So here is some advice on this subject if you are (as a board or community) inclined toward the non-cookie cutter look):

1. Check the documents to see what authority exists.
2. [Perhaps] Poll the owners to see if they are in favor of having some individualism in the common area.
3. Choose specific areas and not entire lawns, if you want to retain some common look.
4. Set parameters through rules, standards or policies (and do not forget the California requirements on rule-setting in Civil Code Sections 1357.100 and following).
5. Consider requiring a signed agreement between the Association and Owner who wants (or whose tenant wants) to do some individual planting that says if the person doing the plantings fails to maintain them to the standards required by the Board, the Owner of the Unit must have the plantings removed and restore the area to the standard required by the Board (that is equivalent of course of other areas).

If residents plant in areas that are common area and there is no authority in the documents for this, the Board would generally have the right to enter the areas (after all, I am assuming we are talking about common areas) and remove the plantings. If the documents allow the Board to do work that would otherwise be an obligation of an owner and seek a reimbursement assessment, then that is a reasonable direction to go. That would require a hearing under Civil Code Section 1363, and my suggestion is always to give the Owner the opportunity to do the work required before considering doing it and charging the Owner. I think this serves well if the Board is challenged on collection of the assessment or taking the action.

If the area is "exclusive use" common area, there may be more to the discussion. Owners tend to assume they can do anything they want to in exclusive use common areas. Boards often wonder if they have any authority to regulate these areas. Usually the Board does have authority to set and enforce standards in these areas, such as having rules about what can be planted or kept on patios and decks, etc.

When considering allowing Owners or residents to plant in common areas, the key is to think about what that means in the grand scheme of things. Will it complicate the work of the association gardeners? Will it increase costs to the Association in any way? Is there clarity in who maintains the areas once planted? Is there a means to force the Owner or resident to restore the area if the plantings are not maintained. Is there a need to have a written agreement, or a benefit to having one? (I would guess the answer is "yes"!) Have you set up some standards for what can be planted in the visible or non-visible areas? (Tomato or vegetable plants in the front yards are probably going too far, but herbs may not be.)

Like everything, a little balance between the diverse opinions as to how much individuality should be allowed is worth at least considering.

Posted by Beth Grimm at 8:05 PM

MAINTENANCE STANDARDS - WHO DECIDES WHAT THEY SHOULD BE?

In a simple question presented to me, the reader writes: Is the Board of Directors allowed to make rules regarding maintenance of the common area?

The simple answer is "Yes". Of course, it is critical to review the governing documents because there could be language that is significant to this issue. In general, the Board may not set lesser standards than called for in the documents. Often though, the Board can set higher standards. Sometimes there is clear language that indicates Board discretion is the final word.

In some cases owners complain that the Board has set standards that are too high. There are probably not many cases where this argument would prevail, unless the Board is inconsistent in the standards that it applies to all owners.

In other cases, residents may complain that the Board is either not enforcing standards or has set standards too low. Property values are an important thing for Boards to consider, as it is very common that either the Articles of Incorporation, the Bylaws, or the CC&Rs for the Association require the Board to preserve or enhance property values.

Then, the question arises, may the Board regulate standards in the areas of exclusivity to members, including requiring homeowners to maintain their own area, and to certain standards?

The answer is probably yes, but it really depends on what the CC&Rs or regulatory documents say.If the areas are visible from the streets, common area or other properties in the development (like by the neighbors), there probably is some language allowing a certain amount of control over what is placed in and how the areas are maintained. However, if the resident is the only party that is subjected to the sight of the area, and is fully responsible for maintenance, and there is no potential threat to the surrounding properties by what the resident might do (short of criminal activity like planting marijuana), then there are less likely to be controls.

Posted by Beth Grimm at 8:03 PM

HOA Board Soliciting Business - Is It OKAY?

Here is a conglomeration example of some common questions presented to me: "One of the Board members of our HOA board distributed a letter on her company letterhead (realtor) thanking "neighbors" for their support of the association, announcing the winners of the recent board election, and giving news of the community. Then, the letter went on to tout her experience as a realtor and was clearly soliciting business. This letter was also posted on the community bulletin board. Isn't this a conflict of interest?"

It's fairly common to find realtors serving on boards in their associations. It is probably good when that happens because it gives the realtor a real education on what it is like to be on the "other side" of the buy-sell transaction and demands to "hop to" on the disclosure packages.

However, it is probably as common that a realtor serves to get their name out there, get a neighborhood specialist edge, and a membership list for solicitation purposes.

The letter described above clearly is out of line, I believe. Misusing the membership list for this purpose is not really kosher. But you will not find a specific legal prohibition of it so it becomes a question as to whether there is some basis to complain and ask that it stop.

If you review Corporations Code Sections 8330 and following (www.ca.gov - navigate to California laws), you will see that any member can ask for a membership list. The request must be in writing and the purpose stated. The Board does not have to provide it if it believes the purpose is not valid. Solicitation of busines would not be a valid purpose.

Thus, I believe it fair to say that access to the list of homeowner members by board members still does not make use of the list for soliciation purposes a valid purpose and it should not be done.

Some use local tax records or insurance company records to get the list. In that case, at least, it would not be considered improper if they did the footwork needed.

As for conflict of interest, that is explained in a separate blog. In order to be in conflict of interest, a board member must be receiving or benefiting from some financial gain because of a relationship of some kind AND fail to disclose the relationship or contract or benefit being received. Disclosure does make a difference. It can more or less "legalize" what seems a conflict of interest to the homeowners that are asking the questions.

Posted by Beth Grimm at 7:56 PM

Renters At Meetings - Are they Allowed to Attend?

Here is a question on renters at meetings:

"I am a Board Member and at one time knew that ONLY members whose name is on the deed are allowed to attend meetings. Is that still correct. I am running for the BOD at our Condo (attached) unit and want to abide by rules and did not find it."

The answer is that the Board sets the requirements. Some boards allow tenants to attend. Some do not. If an owner gives a tenant a general or special power of attorney to exercise the rights of the owner, or even it could be so specific as to appoint the tenant as a person that can attend the association meetings on their behalf, the Board probably has to allow the tenant to attend, unless of course the tenant becomes a problem attendee, and then the Board would need to know what to do about that. (I will answer the question in another blog but search the blogs to find more on this.)

Documents do not always say specific rules about attending meetings but some do, so be sure to check the documents.

Posted by Beth Grimm at 7:49 PM

June 11, 2007

Termites - Who Is Responsible?

Many people in HOAs have difficulty with responsibility for termites. The question often arises, who is responsible for treatment and eradication?

Question recently submitted: "In our documents, no reference is made to the term Planned Unit Development but that is what the board claims we are. We have lived here for more than 20 years and have had several instances of termites in one of the three exterior walls of our unit. The first two times, the HOA paid for eradication - the termites were in the experior wall. Then, the third time, the HOA refused.. but the work was still under warranty so further treatment was completed. The next time the Board refused to pay and there was no warranty. The HOA attorney says Civil Code ( Stirling Act) says that each unit owner is responsible for termites within their unit but we believe we are still dealing with an exterior wall. The termite company that I called said the same thing our "in-house" (association) termite company said - that the building can't be tented, we cannot tear open the exterior wall, the treatment will always be a "band-aid " approach by treating from within my unit to through the wall to exterior "dead space" before the stucco... and the cost is more than $500!!! The HOA has done nothing to treat these termites recently from the exterior, even though it is a known termite area...what can we do?"

Basically the answer is this: unless the CC&Rs (aka Declaration) say otherwise, in California the Davis Stirling Act - Civil Code Section 1364 essentially (paraphased) says that in a planned development, the owners are responsible for reasonable termite treatment and prevention with regard to their lots and in a condominium development, the association is responsible for reasonable termite prevention and treatment in the common area (which is usually the building except for the airspace that are the units). The scheme can be changed by a vote of the members to amend the documents.

There is a leading case in California that stands for the proposition that if the Board has a plan for dealing with termites, even though a spot treatment which may need to be repeated, it is not required to accept the demand of an owner for a different (and in the case more invasive) treatment such as tenting the units. The court applied the business judgment rule essentially saying that it would not second guess the Board on this subject.

The most common problem for owners in a planned development is how to contend with neighbors who take no measures to protect their units and will not willingly participate in a treatment for the entire building. Because of the law and documents that impose an obligation on the individual owners to take reasonable measures with regard to termites and pests, one owner who wanted to initiate treatment for his or her dwelling but needs to treat the neighbors as well to make the treatment effective would probably be able to get some relief in small claims court or superior court for the cost of any work done that was needed (the owner would have to prove this), which the neighbors refused to approve or contribute.

In any event, this is just general guidance/information. Legal counsel should be consulted if you need a legal opinion. There are factors that may enter into the final determination as to who is responsible.

Posted by Beth Grimm at 9:11 PM

June 8, 2007

Practicing Law - Or Any Other Profession - Without "Proper" License - Beware!

Today, I guess I have to pick on community association managers for a minute. I was at a seminar recently and spoke with an insurance provider at one of the sessions - on the subject of earthquake insurance. In the course of preparing I spoke to many experts, many managers and many board members.

Many of the insurance professionals and board members disclosed that the managers for the associations are very influential in convincing the Boards that earthquake insurance is not a good value and it should be dropped.

Managers - are you insurance experts? Can you advise on all of the various options ranging from full to partial coverage, the CEA, and other insurance options? Are you lawyers - are you qualified to advise on fiduciary duty of board members and whether the Association or Board can be sued if the earthquake insurance is dropped, or how to prepare the association records and achieve the necessary due diligence and best defense possible if that happens?

All I can say is .... be careful.

Posted by Beth Grimm at 10:32 PM

Earthquake Insurance For Condos - Drop It Or Keep It?

The question keeps coming up - “ ... why would we (condominium board members or owner members) want to keep earthquake insurance when it costs so much and promises so little?

This is part of it: the insurance “pendulum” swings back and forth, meaning it goes from being affordable and desirable to expensive with decreased coverages, and back again. Associations commonly drop earthquake insurance when it gets really expensive, underestimating the ultimate benefits of having it if an earthquake seriously damages association buildings. The ultimate benefit is not often (necessarily) 100% coverage. That is not feasible to get these days. The ultimate benefit is having at least enough coverage so that the members are not devastated by such an event ... at least enough coverage that owners are encouraged to stay and rebuild, even if a loan is needed to bear the uninsured portion of the damage costs.

This is another part of it: if your HOA steps out of the market intending to come back in when the prices go down, you might be sorely disappointed. Carriers limit their risks by limiting inventory as to geographic areas, building types, etc., and even if the cost goes down, you are not guaranteed of getting back into the market in as favorable position as you once were because the carrier you used before may no longer have any room to add you back in.

Let’s be honest. Condominium living is marketed as "affordable". However, there are hidden expenses such as special assessments imposed for various purposes. Regular assessments commonly increase each year. Costs rise each year. Utilities, water costs, maintenance and costs are commonly subject to unanticipated increases. Utility shortages, materials shortages, and insurance-namely reinsurance - shortages are often directly related to serious crises like Hurricane Katrina and others, tornadoes, floods and "acts of God" (or mother nature), and shortages lead to higher costs. And then ... of course ... there are the rising compliance costs.

The California Earthquake Authority (CEA) says, and probably rightfully so, that there is no area of "low risk" in the state. There are only areas of "higher" risk and "lower" risk. Living in California is a choice. Living in California is expensive. Living in California is living in "earthquake country". Earthquake insurance can be very expensive. Where is that surprise in that?

Much of the real estate in California has appreciated providing very beneficial return in the form of increased appreciation for property owners. But the amazing thing is that those owners who are benefitting from these [inflated] property values aren't willing to pay alot more for whatever insurance protections are available. That is the real surprise.

Yes, the association earthquake policy premiums spiked this past year. Rumor is they are going to come down next year - why? The providers in the reinsurance market that got burned by the reach of Hurricane Katrina pulled out this past year or increased costs considerably to reduce their own risk. Rumor is that some of the providers that left the market are coming back next year. It is likely that the pendulum will swing back the other way, in favor of decreased premiums and/or increased coverage.

There are already two articles on the guru website relating to whether or not to buy earthquake insurance (visit www.californiacondoguru.com). One suggests that if your HOA is considering dropping its master coverage, there are steps that should be taken to assure due diligence in making a decision, and that the decision to keep or drop earthquake insurance should not be taken lightly. Another full blown article is going up soon, the emphasis on the fiduciary aspects of decisions relating to earthquake insurance, and whether the Board can be sued if the earthquake insurance is dropped.

Here is an angle you have probably not considered: In a perfect world all owners in the HOA would carry individual earthquake insurance through the CEA and all would share the cost of a reasonable level of master coverage for the buildings, whatever the cost was. This is the best protection for EQ that association members can get. Associations that are receiving EQ bids are having to accept high deductibles; however, consider this: owners can procure a private EQ policy through the CEA of up to $50,000 loss assessment coverage (coverage that would qualify to pay for the special assessments imposed by the HOA for earthquake building damage). If every owner had this coverage, even though their policy would have a $7500 deductible, every assessment dollar requirement over that $7500, up to $50,000 in coverage, more or less, would be covered. This means that HOAs could raise the deductible on the first layer of coverage (which can be up to 25% of the coverage amount), and pay less in premiums, if the owners in the development would in large percentage carry individual coverage providing loss assessment coverage. In other words, there are ways to balance the costs and spread the sharing of the risks, and possibly even lower the overall cost for each owner individually.

In short, and in plain English, instead of gathering information that helps members understand the adverse ramifications of dropping the EQ coverage and helping them get educated as to how to protect themselves to the extent possible, albeit expensive, and instead of encouraging owners to vote to keep the insurance, Boards are more often discouraging paying the high price and thereby eliminating the best chance for owners with equity in their property to protect the property from a serious earthquake event, by dropping the earthquake coverage.

And worse yet, the effect of this dichotomy is that Boards are letting owners with little or no equity "off the hook". Dropping insurance coverage puts everyone at risk, even those who have considerable equity. Why shouldn't every member of the community contribute a fair share for insurance to protect property values in the community. If they do not contribute to premiums and carry individual insurance, the special assessments to rebuild will be much higher, and those without equity will walk away - how do we know this? One word - Northridge.

And last but not least ... keep in mind what Boards are normally duty-bound to do .... the answer is protect property values. Dropping earthquake insurance coverage does not seem consistent with that stated purpose.

Watch for an upcoming article explaining all this in more detail on the website http:www.californiacondoguru. It’s complicated, but an unfortunate reality.

Posted by Beth Grimm at 8:40 PM

June 5, 2007

Emergency Assessments - When Are They Justified?

Here is a question from a reader about emergency assessments.

"I purchased a condo 3 years ago and the Board is always [sic] doing special assessments. They are in the process of repairs some parts of the building such as patios, balconies and painting the entire building and they call this an Emergency Special Assessment. They want each owner to pay an assessment that is over $3000 and some of the people dont have this money and pay the regular assessments too. Can they do this?"

There are specific requirements for the imposition of emergency assessments in California. They are:

(b) Notwithstanding more restrictive limitations placed on the board by the governing documents, the board of directors may not impose a regular assessment that is more than 20 percent greater than the regular assessment for the association's preceding fiscal year or impose special assessments which in the aggregate exceed 5 percent of the budgeted gross expenses of the association for that fiscal year, without the approval of owners, constituting a quorum, casting a majority of the votes at a meeting or election (by written mail ballot). For the purposes of this section, quorum means more than 50 percent of the owners of an association. This section does not limit assessment increases necessary for emergency situations. For purposes of this section, an emergency situation is any one of the following:

(1) An extraordinary court-ordered expense;
(2) An extraordinary expense necessary to repair or maintain any part of the CID for which the association is responsible where a threat to personal safety is discovered;
(3) An extraordinary expense necessary to repair or maintain any part of the CID for which the association is responsible which could not have been foreseen by the board in preparing and distributing the pro forma budget under Section 1365 above.

Prior to imposition of this emergency assessment, the board must pass a resolution reflecting written findings about the need for the assessment and why the expense could not reasonably be foreseen. The board must distribute the resolution to the owners with the notice of assessment.

(4) An extraordinary expense in making the first payment of the earthquake insurance surcharge pursuant to Section 5003 of the Insurance Code.

My Comment: The intent of these sections of the assessment statutes is to assure that associations have adequate authority to impose assessments "sufficient to perform the obligations" imposed on the association. The rights and limitations to increases and imposition of assessments without a vote of the membership are the legislature's view of what's reasonable, no matter what appears in the governing documents. The statutory provisions control. As for understanding subsection (b), most HOA attorneys interpret this section (in its poorly worded condition) to mean that an association may increase regular assessments up to 20% of the regular assessment for the preceding year without a vote of the membership, even if the governing documents provide stricter limitations. Likewise, the association may impose a special assessment or special assessments that do not exceed 5% (in the aggregate) of the budgeted gross expenses for that fiscal year without a vote of the membership. If the association needs more money to pay expenses, approval of a majority of a quorum of the membership is required (a quorum being more than 50% of the owners) either at a meeting duly called, or a written ballot sent by mail that satisfies the written ballot requirements.

“Emergency” needs are an exception, as described. However, the emergency assessments need to qualify under the descriptions provided, must be for repair costs not known or anticipated at the time of the budget preparation. So the question is, do the repairs and maintenance that are necessary based on safety, a hazard, or other subject matter embodied in the statute?

Posted by Beth Grimm at 10:06 PM

RESERVES - HOW DO YOU DETERMINE WHAT IS "HEALTHY" FINANCIAL PLANNING?

Your Association's financial strength should be of a number one concern. HOA regulatory documents commonly specify that the purpose of the homeowners association (HOA) is to protect the property values and sometimes even "enhance" property values. Other purposes commonly include maintenance of buildings and grounds, and collecting assessments to carry out the purposes and obligations of the Association.

That said, what exactly does that mean? Some associations can cope with shortfalls rather readily. I am talking about those whose members can withstand sizable assessments without blinking an eye. For the most part, that would require a membership of financially flush owners with the cash, equity or resources needed to step up to the plate and respond to any special assessment that might be imposed in lieu of having savings to pay the expenses and arrange for work to be done as the need arises. Know of any associations like this? I don't.

What I see are associations with financially strapped members, or associations with a variety of members, ranging from the financially flush to the ones who got in with creative financing and have no buffer available for the "surprise" special assessments. Many of these kind of members are first time buyers. These associations need healthy reserves. So what are "healthy" reserves. In California, studies accomplished by industry providers tend to show that the average association is about 60% funded per the current reserve study that was commissioned as required by Civil Code Section 1365. Yours may be more or less. 60% may or may not be considered "healthy" but sometimes average has to do. It is my belief that Boards should have a goal to reach 100% funding at the least. If not there yet, working reasonably with the members to improve the financial strength is better than ignoring or covering up financial woes.

And unfortunately the specific percentage funded shown in the financial statements is not a guarantee that the figure will not change drastically within any fiscal period. A matter of a $25,000 special assessment was recently brought to me by a new buyer who could not understand how the association went from 114% funded reserves to 2% funded with a $25,000 special assessment (from each owner) needed. The course of time between the reserve studies was only two years. I could not understand it either. The documentation provided to the new owner was not comprehensible.

Here are some questions from readers.

1. My association took out a loan a few months ago which was structured as an equity line the first year, that would be converted into a fixed period loan based upon the total amount used in the equity line. When the board makeup turned over in a recent election, we ended up with a new board that was vehemently opposed to the loan concept. This Board is completing rehab of buildings that will completely deplete the reserves, without tapping into the equity line. This board is on a course that will reduce the reserves to zero and then the Board says it will enact special assessments if they are needed. Do we have any recourse to this kind of activity?

Answer: The Board has considerable latitude in determining finances. This sounds like a difficult situation. There should be a plan in mind to assure that as reserves are used, they are replenished. Whether that should be a loan or special assessment or regular assessment increases is determined by the circumstances. The makeup of the membership should be kept in mind and if there is a way to structure the financials that the members can withstand, that is critical. Here are some important considerations in deciding what the best course of action is when the financial strength is seriously threatened:

**Without utilizing the loan in a scenario like this, are the members able to bear the special assessments needed to fund the remaining costs of the reconstruction, and bear the expenses in the future when they arise? If a loan would ease the pressure on members and help keep the reserves funded to a reasonable level even during a major construction project, it makes sense to utilize that option. Strapping the members beyond their means when there is another option will not be a win-win situation.

**An association with seriously depleted or underfunded reserves will be less enticing in the marketplace than a comparable association that shows stronger in financial strength. In past years this did not always make a difference as few could read and comprehend the financials and reserve studies and so few even tried. People tended to purchase based on what they saw when driving down the street, and entering through the front door. However, the California legislature, at the urging of the California Association of Realtors (one of the strongest lobby groups in the state) has over the past 5-6 years pushed for clarity and substance in the reserve disclosures and this has improved, in many cases, the ability to determine whether there are any "surprises" lurking in the background.

In trying to combat financial decisions made by your board, your best recourse is to run for the board, and try to get into the inner circle where the decisions are made. If that does not work for you, attending meetings, paying attention to financials, and communicating concerns to other owners might help. Some boards respond to membership pressure. Others do not. If you still are not satisfied and feel that you have losses caused by the action of the board, you can pursue legal action, either in small claims court (the upper limit for individual personal claims is now $7500.00) or superior court. Get legal advice first, though, because disagreeing with the Board, even strongly, is not cause for a lawsuit. One has to be able to prove that the Board members had a certain duty that was breached, and the losses which are identifiable were attributable to (caused by) that breach.

All this being said, there are still serious problems with some boards remaining "in denial" about what the law requires. See question 2.

2. My Board of Directors finally agreed to have our first reserve study prepared. They did not want one prepared because they knew that it would result in having to admit our association is severely underfunded. (As above) the board's mind set sseems to be "pay for it when it is absolutely necessary". We only pay for things via special assessment. We are not even covering our operating expenses. We will be bankrupt at the end of another 12 months if we do not raise the monthly dues.We have not had a contribution to funding the reserves for several years. What can I do as a homeowner to get not only the Board, but the other general members to vote for increases that will pay for normal operations as well as fund our reserves? Do I have legal recourse to threaten them with?

Answer: The answer is essentially the same as above. Getting your board to get the required reserve study done is easier than getting the board to adopt a realistic budget and the reserve study and funding it. Sometimes a board will simply refuse to adopt a reserve study prepared by an industry vendor versed in preparing such studies. They tend to be suspicious of anyone who puts in writing that the association is seriously underfunded. However, the reserve study preparers are finding in all too many situations that this is the case. Many studies contain a "recommended" level of funding (with a goal to get closer to 100% funded) and a "lowest threshhold" for funding and some boards do not even follow through with the threshhold level. However, if this is the case, at least there is an objective standard to be looked at if the Board is challenged on its decisions.

Getting the owners to approve assessments is the Board's job. It is the job of the Owners to run for the board and serve. And if Owners are not willing to get involved, but still want to challenge the Board's practices, proof of a duty, breach, causation and a loss would be necessary to prevail in a claim.

Here is another question.

3. After many years I finally purchased a condo. Before the purchase, I reviewed the CC&Rs as well as the total budget including reserves. My question what is the lowest acceptable reserve funding level for a condo complex? I am currently reviewing our condo's recent reserve study and we are at 62% and that seems unnecessary. Where do most CA condos place regarding reserve funding?

Answer: Here is a member who thinks 62% percent is too high. Go figure. It's average, and the question is, is average good enough? It's better than 50% but not as good as 75%. Wish I had a bettern answer. In the event any legal complaint is made that such a level is too high or too low, many factors would have to be considered. So, I have to give a lawyer opinion on these questions that ask if there is recourse for what are considered bad board decisions.

"It depends!"

Posted by Beth Grimm at 8:36 PM

California Condo & HOA Law

Beth Grimm