Enforcement of the Interstate Land Sales Full Disclosure Act (“ILSFDA”) Shifts to the Bureau of Consumer Financial Protection

On July 21, 2011, enforcement of the Interstate Land Sales Full Disclosure Act (“ILSFDA”) shifted from the Office of Interstate Land Sales Registration (“OILSR”), previously a sub-agency at the Department of Housing and Urban Development (“HUD”), to the new Bureau of Consumer Financial Protection (“CFPB”) ...


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Second Circuit Appellate Court Strikes Down Bodansky, Making it Unwise For Developers to Combine ILSA Exemptions

On March 15, 2011, the United States Court of Appeals for the Second Circuit (the “Second Circuit Court”) confirmed the advice we have consistently provided to our condominium developer clients:  it is not prudent for developers selling pre-construction units in condominiums with more than 99 units to rely on a ...


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