Effective March 25, 2015, the sale of condominium units are no longer subject to the registration requirements of the Interstate Land Sales Full Disclosure Act (ILSA) under a new exemption. This new exemption applies only to the sale of condominium units on and after March 25, 2015, but also will include condominium units within projects currently registered with the CFPB that are offered for sale on and after March 25. (Dodd-Frank gave the CFPB rulemaking and other authority under ILSA.)
The new exemption, however, is not a complete exemption from ILSA. Unless another full exemption applies, the sale of condominium units remains subject to the law’s antifraud provisions. For more on the sales exemption and how ILSA’s antifraud provisions may continue to apply, see our legal alert.