JOANOS, Judge.

This appeal is from an order in the nature of a declaratory statement of the Department of Business Regulation, State of Florida, Division of Florida Land Sales, Condominiums and Mobile Homes (Division). Appellants raise the following issues for our review: (1) Whether the Division's declaratory statement should be rejected because its interpretation of sections 718.103 and 718.301, Florida Statutes, yields an absurd result; (2) whether the Division's declaratory statement should be rejected because its interpretation of sections 718.103 and 718.301, Florida Statutes, violates the privileges and immunities clause of the United States Constitution; and, (3) whether the Division incorrectly overruled the legal conclusions of the hearing officer with respect to control of the condominium association. We affirm.

The condominium involved in this action is Winston Towers 600 Condominium, a residential condominium in Dade County, Florida. Between May 1983 and March 1984, appellants, ten limited partnerships (four from Texas and six from Michigan), each purchased a number of units in the condominium from Winston Capital, Inc., the original developer. The units purchased by the joint intervenors were not acquired for the purpose of occupancy by the joint intervenors. None of the joint intervenors have ever offered any of their units for sale. Further, the joint intervenors have not offered any of their units for lease in excess of five years. The units have instead been leased for shorter periods of time.

Appellants obtained control of the condominium association because they owned a number of units as a block, which constituted a controlling interest in the condominium association and allowed them to elect two of the three directors of the association. On August 13, 1984, appellee, Arnold Belkin (who is a unit owner) filed a petition for declaratory statement with the Division. Belkin requested the Division to issue a declaratory statement, 1) declaring the appellants (ten limited partnerships) to be developers within the definition of section 718.103(14), Florida Statutes (1985), and 2) ordering appellants as developers to turn over control of the board of administration of the condominium association pursuant to section 718.301, Florida Statutes (1985). A hearing was held by Division of Administrative Hearings (DOAH) and the hearing officer entered a recommended order to which both parties filed exceptions.

The hearing officer found that a normal, regular and common activity of each of the ten limited partnerships is to offer to lease, and to enter into leases, all condominium units owned by the limited partnerships, in their ordinary course of business. Further, the ten limited partnerships have no business venture or income-producing activities other than attempting to lease their units. The hearing officer determined these entities were developers within the meaning of the definition provided by section 718.103(14), Florida Statutes, which defines developer as one who, inter alia, offers condominium parcels for lease in the ordinary course of business. Further, the hearing officer determined that the turn over of control of the condominium association from the original developer to the appellants, which occurred in 1984, was without legal effect. The hearing officer based his determination on the fact that the appellants and the original developer still own more than 50% of the units and the original developer still owns units for sale in the condominium. Also, the hearing officer concluded that, because the original developer still offered condominium units for sale, the turn over of the association from developer control was not required pursuant to section 718.301, Florida Statutes.

In its final order, the Division rejected these conclusions of law and ruled that the 1984 turn over of control pursuant to section 718.301 could be required regardless of whether the original developer still owned units for sale. Further, the Division concluded, pursuant to section 718.301(1) Florida Statutes, that appellants were not entitled to control since appellants were not offering units for sale in the ordinary course of business. The Division concluded that section 718.301 was designed to insure that unit owners, other than a developer, would ultimately be entitled to control their own affairs.

We affirm the findings of the Division in its final declaratory order. This case poses solely a question of the interpretation and application of section 718.301, Florida Statutes to the facts involved.

In interpreting and applying the definition of "developer" we find it significant that the statute defines developer as one who "creates a condominium or offers condominium parcels for sale or lease. . . ." Therefore the term developer is appropriately only applied to owners like appellants, who own more than one unit, and would not apply to individuals who own one unit in which they live. In light of the wording of this statutory definition, we reject appellants' argument that the Division's interpretation of this definition will cause the absurd result of an owner or lessor losing his eligibility to vote for a majority of the board "regardless of whether he owns one unit or 500." Instead we agree with the Division's argument that the limited partnerships here are developers as defined in section 718.103(14), Florida Statutes. This conclusion, made by both the (DOAH) officer and the Division director, is supported by the record. A real estate expert, as well as two condominium association board members testified that the appellants operate the leasing of the units which they own, comprising over 60% of the entire condominium complex involved. Evidence revealed that the typical leases were for one year, (with possible extension to two years) and the intent of the appellants was to produce equity and gain on investment in real estate. Further, appellants have no other businesses. Also, Ms. Christine Erdody, a general partner in each of the limited partnerships, and one of the board members elected by the partnerships, testified that leasing the units, whether done through a management company as an agent, or by the developers, is an ordinary, common task involved in managing the condominium as a business.

The record also supports the Division's conclusion that the joint intervenors do not sell their units "in the ordinary course of business." See First Federal Savings and Loan Association of Seminole County v. Department of Business Regulation, Division of Florida Land Sales and Condominiums, 472 So.2d 494 (Fla. 5th DCA 1985), wherein the district court interpreted "ordinary" to mean ". . . regularly, normally or commonly offer condominium parcels for sale." 472 So.2d at 496. Further, another board of directors member, Mr. James Sherry, testified that all of the partners planned to sell their units "eventually" in order to recoup the equity accrued. Therefore, the joint intervenors are not developers in the regular business of selling their units. We agree with Division's argument that section 718.301(1)(c) and (d) Florida Statutes, clearly provides on its face that unit owners other than the developers are entitled to elect no less than the majority of the members of the board:

(c) When all of the units that will be operated ultimately by the association have been completed, some of them have been conveyed to purchasers, and none of the others are being offered for sale by the developer in the ordinary course of business; or

(d) When some of the units have been conveyed to purchasers and none of the others are being constructed or offered for sale by the developer in the ordinary course of business, whichever occurs first.

The ability to elect the majority of the board of directors substantially affects non-developer unit owners, as the Division director suggests in his final order. For example, until the non-developer unit owners control the association, the association may not institute, maintain, settle or appeal actions in its name on its behalf. See section 718.111(3), Florida Statutes.

Further, we agree with the Division that the Legislature's qualification of the term "developer," in section 718.502(1), Florida Statutes, with respect to filing documents with the Division, does not require, as appellants suggest, that the qualifier apply to all other provisions regarding developer in the statute. Had the legislature wanted to qualify developers by lease duration in section 718.301 Florida Statutes, it could have easily inserted the same terms it used in section 718.502(1). But no such language is present.

As to issue 2, regarding an alleged violation of the privileges and immunities clause, we find it significant that the statute does not distinguish between types of developers, i.e., non-resident versus resident. Therefore, we disagree with appellants' assertion that the Division's interpretation treats those who qualify as developers differently, based on their residency. Further, we agree with the Division's position that the joint intervenors, as limited partnerships, are not protected by the privileges and immunities clause. The record reveals that appellants were not formed legally into an association, and they did not have a contract requiring them to vote as a block. Therefore, appellants' "fusion of legal identity with its members" theory is also inapplicable here.

The privileges and immunities provisions of article IV, § 2, and of the fourteenth amendment of the United States Constitution, apply only to natural citizens. See 16A Am.Jur.2d § 719. Not only is a corporation excluded from the term "natural citizen," but an unincorporated association is excluded as well. W.C.M. Window Company, Inc. v. Bernardi, 730 F.2d 486, 493 (7th Cir. 1984). Further, the statute speaks to all persons, as appellees contend and prohibits all "leasing developers" from controlling the association. In the order, the Division director explains that at some point the non-developer residents of the condominium are entitled to employ a management company of their own, and this assertion is supported by the statutory provisions which prohibit unit owners other than the developer from acting in a legal capacity until they gain control of the association.

Although the right to hold property is one of the privileges protected by the privileges and immunities clause, appellants have misconstrued the Division director's interpretation of the pertinent statutes, and therefore appellants have not established that the Division's interpretation places a "heavy burden on an out-of-state resident's ownership of condominium property in Florida." Appellants have not explained how the right to control the association impinges on their right to own units or be leasing developers, nor have they established the right to control the condominium association is a fundamental right. Further, appellants have not shown that the statute intentionally operates to the disadvantage of all non-residents while operating to the advantage of all residents.

Finally, a general review of Chapter 718 reveals that it was created to facilitate the transfer of control of the association from the developers to the non-developer unit owners. It was obvious that the legislature intended for the developers to relinquish control, although appellants, the evidence shows, as leasing developers, are trying to maintain control from out of state. Further, the record supports appellees' contention that given the facts of this case, the original developer and the joint intervenors have been acting independently, not interdependently. Therefore, according to appellants' suggested interpretation (as well as the hearing officer's recommended order), where "developer" includes original developer and transfer cannot occur if the original developer still owns units, transfer of control could never occur under sections 718.301(1)(a), (b), (c) and (d). Also, we note that in section 718.111(3) the statute provides that until the unit owners other than the developer obtain the control of the association, they cannot pursue legal action against the developers for misrepresentations.

Further, we find that the Florida legislature built into the statute safeguards to protect the developer's interests in their investments even after transfer of control, contrary to appellants' argument. For those developers that are in the regular business of selling their units, and who still have units for sale, section 718.301(3)(b) Florida Statutes, provides that the association must obtain the developer's approval in writing before it can pursue an action that might be detrimental to the sales of the developer's units.

This court has previously stated its policy regarding agency statutory interpretation:

We are not concerned with whether the Department's implementing interpretation of the critical statutory term is the only one possible; nor are we concerned with whether, by our lights, that interpretation is the most desirable one given the statutory scheme as we perceive it. It is enough that the Department's implementing interpretation is a permissible one, sufficiently expounded by the Department's declaratory statement. (emphasis supplied).

We affirm the Division director's determination that in order to implement the legislative intent of section 718.301 entitled TRANSFER OF ASSOCIATION CONTROL, the word "developer" in this section should be interpreted to mean "subsequent developer", which accurately describes appellants. Therefore, even if the original developer still has units for sale, appellants' leasing arrangements will not act to prohibit transfer of control to the unit owners indefinitely, which is what would happen if the DOAH recommended order was affirmed, a result which, as the Division director states, is not contemplated by Chapter 718.

Applying the Division's interpretation of the pertinent statutes to the facts before us, we find no clear error or conflict with legislative intent, and therefore, affirm the Division's declaratory order.

SMITH, C.J., and WENTWORTH, J., concur.