Florida CAM audit partner guide: tourism-market strip center CAM overcharge patterns
Florida's commercial real estate market is shaped by two forces that create unusual CAM billing dynamics: tourism-driven retail density and a property insurance market that has experienced some of the most dramatic cost increases in US history. For advisory professionals who serve Florida commercial tenants, these two forces have created a concentrated CAM overcharge environment that I designed CAMAudit to systematically detect.
Florida Statutes do not provide commercial tenants with statutory CAM audit rights. Everything runs through the lease. That means Florida tenants with poorly negotiated leases have no legal lever to compel document production, and Florida tenants with well-negotiated audit clauses have the foundation for a structured recovery. The partner's job is identifying which clients fall into which category and providing the forensic analysis to act on findings.
Florida commercial tenant audit rights: Florida Statutes Chapter 83 governs landlord-tenant relationships in Florida. The commercial provisions address remedies for wrongful exclusion and certain notice requirements but do not establish statutory CAM audit rights. Florida commercial tenants must negotiate audit rights contractually. The general written contract statute of limitations under Florida Statutes Section 95.11(2)(b) is 5 years, providing a meaningful recovery window when lease-defined dispute windows are satisfied.
Florida commercial lease law: what tenants can and cannot rely on
Florida Statutes Section 83.45 prohibits commercial landlords from engaging in certain bad-faith conduct, but this provision is not an audit rights statute. It does not compel document production or establish a tenant right to inspect CAM records.
For Florida commercial tenants, the practical framework is:
- Audit rights come from the lease only. Without an audit clause, there is no enforceable right to review landlord records.
- The written contract statute of limitations is 5 years under Florida Statutes Section 95.11(2)(b). A CAM overcharge from a reconciliation delivered in January 2021 has a limitations deadline of approximately January 2026.
- Lease-defined dispute windows are enforced as contractual conditions. A 60-day or 90-day lease dispute window that expired without a written objection typically bars recovery for that year, regardless of the 5-year statutory period.
Florida courts apply standard contract interpretation principles to commercial lease disputes. Ambiguous CAM definitions are construed against the drafter (typically the landlord in institutional lease forms). Florida's economic loss rule does not typically preclude contract-based claims for lease overcharges.
For the complete framework of how CAM audits work in NNN leases, see the guide to NNN lease structure and obligations.
Miami: institutional ownership, Latin American retail, and above-market management fees
Miami's commercial real estate market has distinctive characteristics that drive specific CAM billing patterns. The market has a high concentration of Latin American brand retail in Brickell, Wynwood, Doral, and Coral Gables, with institutional REIT and foreign investor ownership of major retail centers.
Management fee overcharges. Miami institutional REIT ownership generates management fee structures that are systematically more complex than typical US commercial lease billing. Management fee line items in Miami commercial reconciliations frequently include a base management percentage, a "supervision fee," a "leasing administration fee" (not the same as leasing commissions), and a "property management technology fee." Many Miami commercial leases only authorize a single management fee as a percentage of revenues. The add-on charges are overcharges under CAMAudit's Rule 3 when the lease does not separately authorize them.
Insurance overcharges. Florida property insurance costs increased dramatically from 2021 through 2024, with commercial property premiums in Miami-Dade increasing by 40 to 100 percent for many property types. Miami commercial landlords passed these increases through as CAM charges. The CAM billing legitimacy depends on whether the lease authorizes the specific type and scope of insurance. Policies with above-market coverage levels, inland marine coverage, or insurance that covers landlord-specific exposures not related to the building shell are not authorized by standard lease insurance pass-through provisions.
Wynwood and Brickell mixed-use CAM complexity. Miami's mixed-use developments in Wynwood and Brickell blend retail, restaurant, office, and hospitality components under a single CAM pool. Allocation methodology errors in these structures are among the most difficult to identify without systematic analysis. The pro-rata share denominator in a mixed-use building must be defined by the lease, and errors in how the denominator is constructed affect every tenant's allocation.
| Overcharge Type | Miami Frequency | Primary Property Type |
|---|---|---|
| Management fee overcharge | High | Strip center, mixed-use |
| Insurance overcharge | High | All commercial types |
| Gross-up violation | Medium | Mixed-use, class A retail |
| Pro-rata share denominator error | Medium | Mixed-use, power center |
| Excluded service charges | Medium | Institutional REIT properties |
Orlando: seasonal occupancy, tourism corridors, and gross-up violations
Orlando's commercial market is heavily shaped by tourism. The International Drive corridor, the theme park highway (US-192), and the Convention Center district contain dense retail and restaurant space serving tourists rather than local residents. This creates occupancy patterns unlike any other major US market.
COVID-era gross-up violations. Florida tourism collapsed in 2020, and Orlando tourism-adjacent properties operated at dramatically reduced occupancy for extended periods. When landlords applied gross-up calculations in subsequent years using 2020 occupancy figures as a reference, some produced inflated grossed-up expense bases. CAMAudit's Rule 5 (Gross-Up Violation) checks whether the gross-up calculation methodology complies with the lease provision's specified standard.
Seasonal occupancy gross-up. Even outside the COVID period, Orlando tourist-market properties experience significant seasonal occupancy variation. When a landlord uses off-peak seasonal occupancy as the baseline for gross-up calculations, the normalized expense level exceeds what the lease's gross-up provision typically authorizes. The lease's occupancy standard for gross-up purposes is the controlling language.
Management fee overcharges in theme park corridor retail. The theme park corridor contains a number of institutional REIT-owned strip centers and lifestyle centers with complex management fee structures. The same add-on fee patterns seen in Miami appear in this market, compounded by the high management intensity of tourist-traffic properties.
Industrial market (I-4 corridor, Orlando South). Orlando's distribution and logistics industrial market has grown significantly, generating NNN industrial leases with pro-rata share structures. Industrial parks where one tenant occupies a disproportionate share of the space are particularly vulnerable to pro-rata share denominator errors.
Tampa: healthcare, financial services, and suburban retail cap violations
Tampa's commercial market is anchored by healthcare, financial services, and a significant suburban retail footprint in the Westshore, New Tampa, and Brandon corridors.
Healthcare real estate. Tampa has significant medical office building inventory along the Memorial Hospital, Tampa General, and BayCare corridors. Medical office tenants face service charge overcharge patterns similar to those seen in other major medical markets: specialized HVAC, building systems maintenance, and compliance-driven costs sometimes appear in the CAM pool without lease authorization.
Financial services office. Tampa's financial services concentration in Westshore and downtown generates Class A office leases with modified gross structures. These leases typically include base year arrangements and controllable expense caps. The inflation period from 2022 through 2024 pushed operating costs above the caps in many Westshore office buildings.
Suburban retail cap violations. Tampa suburban retail in Brandon, Wesley Chapel, and Riverview contains standard NNN strip center leases with expense cap provisions. Controllable expense cap violations from the 2022 to 2024 inflation period are the most common overcharge category in this segment, as in most major Florida suburban retail markets.
"Florida's insurance cost surge from 2021 through 2024 created a specific CAM billing problem: landlords passing through premium increases that exceed what the lease authorizes or that include coverage types the lease doesn't permit. After testing reconciliation samples from Florida commercial properties through CAMAudit, insurance overcharges appear in a higher percentage of Florida audits than almost any other state." — Angel Campa, Founder, CAMAudit
White-label economics for Florida advisory practices
Florida partner practices benefit from a large base of NNN-leased commercial tenants across restaurant, retail, medical, and industrial segments.
| Bundle Tier | Annual Cost | Credits | Per-Audit Cost | Retail at $750 flat fee | Gross Margin |
|---|---|---|---|---|---|
| Starter | $990 | 25 | $39.60 | $750 | 94.7% |
| Growth | $2,100 | 60 | $35.00 | $750 | 95.3% |
| Scale | $4,500 | 150 | $30.00 | $750 | 96.0% |
| Enterprise | $7,500 | 300 | $25.00 | $750 | 96.7% |
Florida partners with restaurant and retail client concentrations benefit from the high frequency of insurance overcharges in the post-2021 Florida market. The white-label margin calculator lets you model your practice economics at contingency and flat-fee rates. See the full white-label program details for partnership terms.
Highest-fit Florida partner types
CPAs serving restaurant and retail operators. Florida has an exceptionally large restaurant tenant population, concentrated in Miami-Dade, Broward, Palm Beach, Orange, and Hillsborough counties. CPAs who serve these operators see annual occupancy cost data that reveals CAM overcharge patterns. The insurance overcharge category alone justifies a review for most Florida restaurant tenants who signed leases before 2021.
Healthcare advisors and practice consultants. Florida's large medical office tenant population provides a sustained pipeline for healthcare-focused partners. Medical practices and ambulatory surgery centers in Tampa, Miami, and Orlando face specific service charge overcharge patterns in addition to standard management fee and controllable expense issues.
Commercial mortgage brokers. Florida has an active commercial real estate refinancing market. Lenders and brokers working with NNN-leased properties benefit from accurate occupancy cost documentation. CAM audit findings that reduce effective occupancy cost improve DSCR and borrower qualification.
Expense reduction consultants. Florida has an active expense reduction consulting community serving the hospitality and retail sectors. CAM audit is a natural extension for consultants who already review utility contracts, waste management costs, and telecom expenses for commercial clients.
Qualifying Florida tenants for CAM audit
The highest-yield Florida CAM audit candidates share these characteristics:
- NNN or modified gross lease in a multi-tenant property
- Annual CAM charges received between 2021 and 2025 (insurance overcharge window)
- Lease executed before 2022 with controllable expense cap provisions
- Property managed by institutional REIT or regional property management company
- Insurance line item in CAM reconciliation representing more than 15 percent of total CAM charges
For any Florida client meeting two or more of these criteria, the free CAMAudit scan is a low-friction first step that either confirms findings or documents that the reconciliation is clean.
Frequently Asked Questions
Does Florida have statutory CAM audit rights for commercial tenants?
No. Florida Statutes Chapter 83 governs landlord-tenant law in Florida, but the commercial tenant provisions are limited in scope and do not include statutory CAM audit rights. Florida commercial tenants rely entirely on audit rights negotiated in their lease. If the lease is silent on audit rights, the landlord is not required by Florida law to produce CAM supporting documentation.
What is the statute of limitations for CAM overcharge claims in Florida?
Florida applies a 5-year statute of limitations for written contract claims under Florida Statutes Section 95.11(2)(b). A tenant auditing in 2026 can generally recover overcharges from reconciliations delivered as far back as 2021 under the general contract SOL. Lease-defined dispute windows operate as earlier contractual deadlines and must be checked for each reconciliation year.
Why are insurance overcharges especially common in Florida commercial properties?
Florida property insurance markets experienced dramatic premium increases from 2021 through 2024, driven by hurricane exposure, carrier exits, and reinsurance market disruption. Many Florida commercial landlords passed these elevated insurance costs through to tenants as CAM charges. The question is whether the lease authorizes the specific type and scope of insurance being billed. Policies with coverage levels or carrier costs above market norms, and insurance costs that include non-building coverage, are common overcharge categories that CAMAudit's Rule 9 flags.
What CAM overcharges are most common in Orlando tourism-corridor properties?
Orlando tourism-corridor strip centers and retail properties have two primary overcharge patterns. First, gross-up violations from COVID-era occupancy disruptions: when buildings operated at below-normal occupancy in 2020 and 2021, some landlords grossed up expenses incorrectly in subsequent years. Second, management fee overcharges from institutional REIT ownership of I-Drive and theme park corridor retail, where add-on administrative fees appear alongside base management percentages.
What types of Florida partners generate the most CAM audit engagements?
Florida CPAs serving restaurant and retail operators are the highest-volume partner category, given Florida's dense strip center retail footprint. Healthcare advisors serving medical office and ambulatory surgery center tenants are a strong secondary category, given Florida's large healthcare real estate market. Commercial mortgage brokers refinancing NNN-leased properties are a third high-fit segment.
How does Florida's high seasonal occupancy variability affect CAM gross-up calculations?
Florida tourist-market properties experience significant seasonal occupancy fluctuation, with some properties seeing 20 to 40 percentage point swings in occupancy between peak and off-peak seasons. When landlords apply gross-up calculations based on off-peak occupancy periods as the reference point, the grossed-up expenses overstate the tenant's obligation. CAMAudit's Rule 5 (Gross-Up Violation) checks gross-up calculations against the lease provision's specified occupancy reference standard.