Interstate Land Sales Full Disclosure Act

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The CFPB recently announced that it had entered into a consent order with a land-development company and several individuals involved in the company’s operations to settle charges that the respondents violated the Interstate Land Sales Full Disclosure Act (ILSA).  According to the findings of fact and conclusions of law in the consent order which were admitted by the respondents, the respondents made misrepresentations related to the roads in a Tennessee property development in which they were selling “lots” within the meaning of ILSA. … Continue Reading

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. … Continue Reading

In May 2013, we reported that the CFPB’s amicus program scored a victory when the U.S. Court of Appeals for the Second Circuit ruled that the sale of a single-floor condominium unit in a multistory building was subject to the disclosure and reporting requirements of the Interstate Land Sales Full Disclosure Act (ILSFDA). … Continue Reading

As we reported earlier this year, the CFPB was actively investigating a company called 3D Resorts-Bluegrass, LLC for possible violations of the Interstate Land Sales Full Disclosure Act (ILSA). While the CFPB did not publicly announce this investigation, which is the first involving potential ILSA violations, the investigation was disclosed in a proof of claim filed in the U.S.… Continue Reading

The decision of the U.S. Court of Appeals for the Second Circuit in Berlin v. Renaissance Rental Partners, LLC issued on May 6 represents a win for the CFPB’s amicus program. At the court’s invitation, the CFPB filed a letter brief supporting the consumer/appellee’s position that a single-floor condominium unit in a multistory building is a “lot,” thus triggering the disclosure and reporting requirements of the Interstate Land Sales Full Disclosure Act (ISLA). … Continue Reading