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Preparing Your Multifamily Property for a CPTED Assessment: A Practical Guide to FSS 768.0706 Compliance

Aug 13, 2024
8 min read

Updated: Sep 28

For Florida multifamily property owners and operators, compliance with Florida Statute § 768.0706—formerly HB 837—is more than checking a box on a property-management checklist. It requires property owners to establish and maintain specific security measures, complete a Crime Prevention Through Environmental Design (CPTED) assessment, and provide appropriate crime deterrence and safety training to employees.


The original deadline for having a qualifying CPTED assessment completed was January 1, 2025. The statute requires the assessment to be no more than three years old, meaning property owners should think about compliance as an ongoing process rather than a one-time project.


For owners who are preparing for an initial assessment—or preparing for a future three-year assessment—the following roadmap can help organize the process.


1. Run a Cost-Benefit Analysis


Before beginning the assessment process, it is worth understanding what compliance could mean for your property from both a financial and risk-management perspective.


The purpose of the law is not simply to require property owners to install security equipment. Under § 768.0706, a multifamily property that substantially implements the specified security measures and meets the assessment and training requirements can receive a presumption against liability for certain criminal acts committed on the property by third parties who are not employees or agents of the owner or operator.


That potential protection should be weighed against the cost of bringing a property into compliance.


Consider the potential benefits


Property owners may want to consider:


  • The potential liability protection associated with satisfying the statute.

  • The property's existing security vulnerabilities.

  • The potential impact of security improvements on resident and employee safety.

  • Insurance considerations and whether an insurer offers any benefit for documented security improvements.

  • The potential long-term value of maintaining a documented security program.

  • The costs and disruption associated with addressing security deficiencies after an incident rather than proactively.


Consider the costs of noncompliance


The analysis should also consider what happens if a property has deficiencies.


For example, a property may need improvements involving:

  • Parking-lot lighting

  • Walkway and common-area lighting

  • Security cameras

  • Access controls

  • Pool-area gates

  • Door and window locks

  • Landscaping or visibility concerns

  • Employee training

  • Documentation and recordkeeping


The goal of a cost-benefit analysis is not to assume that every possible improvement must be made immediately. Instead, it gives ownership and management a clearer picture of the property's current condition, potential deficiencies, and the resources required to address them.


2. Determine a Schedule for Compliance


Once the financial and operational considerations have been reviewed, establish a compliance schedule.


A property should not wait until an assessment date is approaching to discover that it needs major security improvements.


A useful compliance schedule can include:


Phase 1 — Preliminary review

Identify the properties that fall within the statute and review the seven specified physical security measures.


Phase 2 — Internal assessment

Conduct an initial review of the property's existing security conditions and identify obvious deficiencies.


Phase 3 — Corrective work

Prioritize and complete necessary improvements before or in response to the professional CPTED assessment.


Phase 4 — Professional CPTED assessment

Have the required CPTED assessment completed by an appropriately qualified practitioner or law enforcement agency.


Phase 5 — Documentation

Maintain records showing the assessment, corrective actions, training, inspections, and other compliance-related activities.


Phase 6 — Ongoing monitoring

Continue monitoring the property rather than treating the assessment as a one-time event.


Phase 7 — Three-year reassessment

Plan ahead for the next CPTED assessment. The statute requires the assessment to be no more than three years old.


Creating this schedule early can also help property owners incorporate security improvements into normal capital-planning and maintenance budgets.


3. Conduct an Internal Assessment or Inspection


An internal assessment is a valuable first step before bringing in an outside professional.


The purpose isn't to replace the required CPTED assessment. Instead, it gives ownership and management an opportunity to identify obvious issues before the professional assessment takes place.


Florida Statute § 768.0706 identifies seven physical security measures that should be reviewed:


  1. A security camera system at points of entry and exit that records and maintains retrievable footage for at least 30 days.

  2. A properly illuminated parking lot.

  3. Lighting in walkways, laundry rooms, common areas, and porches.

  4. At least a one-inch deadbolt on each dwelling-unit door.

  5. Locking devices on windows, exterior sliding doors, and other applicable doors.

  6. Locked gates with key or fob access around pool fence areas.

  7. A peephole or door viewer on applicable dwelling-unit doors.


During an internal review, document what is actually present—not simply what property records say should be present.


For example:


  • Are all cameras functioning?

  • Are recordings actually retrievable?

  • Is the required footage being retained?

  • Are there areas where lighting is inadequate?

  • Are locks and access-control devices functioning?

  • Are pool gates consistently secured?

  • Are door viewers installed where required?

  • Have changes to the property created new security concerns?


Photographs, maintenance records, work orders, equipment inventories, and other documentation can also be useful in establishing what was inspected and what corrective measures were taken.


4. Hire a Qualified Professional for the CPTED Assessment


The professional assessment is an important part of the process.

Under § 768.0706, the required CPTED assessment must be performed by a law enforcement agency or a Florida CPTED Practitioner designated by the Florida Crime Prevention Training Institute of the Department of Legal Affairs. The assessment must be no more than three years old.


This is different from simply having a property manager or maintenance employee conduct an internal inspection.


A professional CPTED assessment can provide an independent evaluation of the property's physical environment, security measures, and potential crime-prevention concerns.


Depending on the property, the assessment may involve reviewing areas such as:


  • Building entrances and exits

  • Parking areas

  • Pedestrian routes

  • Lighting

  • Landscaping and visibility

  • Access control

  • Cameras and surveillance

  • Pool areas

  • Common areas

  • Doors and windows

  • Other environmental conditions that may affect security


The practitioner may also be able to identify issues that are difficult for property staff to evaluate themselves.


Don't choose a professional based solely on price

The assessment becomes part of the property's compliance documentation, so experience matters.


When evaluating a practitioner, property owners should consider:


  • Whether the practitioner meets the statutory qualification requirements.

  • Experience with multifamily properties.

  • Experience conducting CPTED assessments.

  • Familiarity with Florida Statute § 768.0706.

  • Ability to clearly document findings and recommendations.

  • Experience working with property owners, management companies, and legal counsel.

  • The practitioner's process for documenting deficiencies and recommended corrective actions.


The objective should be to obtain a thorough, property-specific assessment—not simply a document that says an assessment was completed.


5. Understand the CPTED Assessment Process


CPTED stands for Crime Prevention Through Environmental Design.

The basic concept is that the physical design and management of a property can influence opportunities for crime and can improve visibility, access control, territorial awareness, and other aspects of security.


A CPTED assessment is therefore more than simply looking for broken lights or checking whether cameras exist.


A qualified practitioner will evaluate the property and its environment to identify security strengths, weaknesses, and opportunities for improvement.


The process may begin with a review of the property itself, followed by an on-site evaluation. The practitioner may examine buildings, parking areas, walkways, landscaping, lighting, entrances, exits, recreational areas, and other relevant spaces.


The resulting report can then identify findings and recommended corrective measures.


This is where the preliminary internal assessment becomes especially useful. Management already has an understanding of the property's condition, so the professional assessment can be used to validate existing information, identify additional issues, and establish a more comprehensive roadmap for improvements.


6. Create a Corrective-Action Plan


Completing the assessment is not the end of the process.


Florida law requires the owner or principal operator to remain in substantial compliance with the CPTED assessment for purposes of the statutory protection.


That means property owners should have a process for addressing identified deficiencies.


A corrective-action plan can include:

Finding

Recommended Action

Priority

Responsible Party

Target Date

Completion Date

Insufficient lighting

Upgrade fixtures

High

Maintenance

MM/DD/YY

MM/DD/YY

Camera coverage issue

Add/relocate camera

High

Security Vendor

MM/DD/YY

MM/DD/YY

Pool access issue

Repair access control

High

Management

MM/DD/YY

MM/DD/YY

Landscaping concern

Trim/replace vegetation

Medium

Landscaping Vendor

MM/DD/YY

MM/DD/YY

This approach turns the assessment from a static report into an actionable management tool.


Just as importantly, document the work that is completed.


Keep copies of:

  • Work orders

  • Invoices

  • Photographs

  • Inspection records

  • Vendor documentation

  • Equipment records

  • Maintenance records

  • Training records

  • Updated policies and procedures


It is recommended to maintain records of completed improvements for documentation and potential discovery purposes.


7. Provide Crime Deterrence and Safety Training


Property security isn't only about physical improvements.


Florida Statute § 768.0706 also requires proper crime deterrence and safety training for employees. Current employees were required to receive the training by January 1, 2025, and employees hired after that date must receive the training within 60 days of their hire date.


The statute defines proper training as training that familiarizes employees with the security principles, devices, measures, and standards described in the statute.


Training should therefore be treated as an ongoing component of the property's security program.


The statute also provides that the training must be reviewed at least every three years and updated as necessary.


8. Plan for Long-Term Compliance


One of the biggest mistakes property owners can make is treating compliance as a one-time event. A property may be compliant today and have significant deficiencies several months or years later.


Cameras fail. Landscaping grows. Lighting deteriorates. Gates break. Locks are replaced. Buildings are renovated. Employees leave and new employees are hired.


All of those changes can affect the property's security environment.

For that reason, property owners should build compliance into their regular property-management processes.


Consider establishing:


Annual internal reviews

Conduct periodic inspections of the property's security measures rather than waiting for the next professional assessment.


Ongoing maintenance

Track security-related repairs and improvements just as you would HVAC, plumbing, electrical, or other building systems.


Employee onboarding

Make crime deterrence and safety training part of the onboarding process so new employees receive the required training within the statutory timeframe.


Training reviews

Review training materials at least every three years and update them when property conditions, security systems, or applicable requirements change.


Three-year CPTED planning

Don't wait until the assessment is about to expire.

Put the next assessment on the property's long-term compliance calendar and begin planning well in advance.


9. Think of Compliance as a Cycle, Not a Deadline


The January 1, 2025 deadline was an important milestone, but compliance shouldn't end there.


A better way to think about FSS 768.0706 compliance is as a continuous cycle:


Assess → Identify → Correct → Document → Train → Monitor → Reassess

That approach helps property owners stay prepared as the property changes over time.


For multifamily owners and operators, the goal isn't simply to complete an assessment and put the report in a file. The goal is to establish a repeatable security and documentation process that can be maintained over the life of the property.


Final Thoughts


Preparing for a CPTED assessment doesn't have to be overwhelming.


Start by understanding the statutory requirements. Conduct an internal review. Identify obvious deficiencies. Develop a budget and timeline. Engage an appropriately qualified CPTED practitioner. Address findings, document the work, train employees, and establish a process for ongoing monitoring.


Most importantly, don't wait until the next three-year assessment deadline is approaching to begin.


The best time to build a compliance process is before a problem occurs.


This article is intended for general informational purposes and should not be considered legal advice. Property owners and operators should consult qualified legal counsel and appropriately designated CPTED professionals regarding their specific properties and compliance obligations under Florida law.

 
 
 

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