The Pennsylvania Commonwealth Court recently reinforced the importance of following statutorily prescribed provisions when creating planned communities under Pennsylvania law. In a December decision, the court denied the ability of a developer to encumber property with declarations of covenants, conditions and restrictions (CCRs) where the developer failed to follow specific provisions of the Uniform Planned Community Act (UPCA) in creating a homeowners association, accepting homeowners' assertions that they were neither subject to CCRs that did not clearly encumber their property nor subject to CCRs recorded after they purchased their property.