Interstate Land Sales Full Disclosure Act: Registration Requirements and Exemptions, Enforcement

Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
- work Practice Area
Real Property - Transactions
- event Date
Thursday, February 2, 2023
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
90 minutes
-
This 90-minute webinar is eligible in most states for 1.5 CLE credits.
This CLE webinar will provide real estate counsel with a review of the statutory framework and the latest developments relating to the Interstate Land Sales Full Disclosure Act (ILSFDA). The panel will discuss its amendments, including a partial exemption for the sale of condo units, how the Consumer Financial Protection Bureau (CFPB) and courts are addressing ILSFDA, and best practices to ensure compliance.
Faculty

Ms. Lee’s real estate practice focuses primarily on issues surrounding common interest projects, including homeowners associations, commercial, residential and mixed-use condominiums, cooperatives, and timeshare resorts. She frequently represents associations after their transition to homeowner management. Ms. Lee leverages that practical operational knowledge to help clients in the formation of these associations.

Mr. Perel is an environmental partner at Troutman Pepper with more than 30 years of vast experience representing clients on all aspects of environmental law, including real estate, environmental regulatory and risk management, and assessment matters. Mr. Perel has specific experience advising on development and redevelopment projects, risk management and insurance, remediation of contaminated properties, environmental compliance and due diligence for real estate financing and corporate transactions, and litigating complex environmental and environmental insurance coverage claims and disputes. Mr. Perel’s clients include financial institutions, real estate developers, redevelopers, REITs, and major players in the insurance, corporate, and hotel and hospitality industries. For his financial institution clients, Mr. Perel counsels on real estate acquisitions, development, and financings, as well as in commercial mortgage backed securities transactions. Mr. Perel currently serves as Vice-Chair of Programs for the Environmental Disclosure Committee of the American Bar Association’s Section of Environment, Energy and Resources.

Ms. Goldman represents national and regional homebuilders with the development of their condominiums and planned development communities, including covenant drafting, special disclosures, Division of Florida Condominiums, Timeshares and Mobile Homes (Condominium) and Consumer Finance Protection Bureau (Interstate Land Sales Full Disclosure Act) filings and secondary mortgage market financing. She is currently serving a two-year term as Commissioner for the City of Sunny Isles Beach, Florida.
Description
Developers of residential property should be aware that there is a federal statute that prohibits the sale across state lines of subdivision lots or units unless they are registered with the CFPB or are exempt from registration. ILSFDA presents complex compliance issues for developers and their counsel. They include the applicability of ILSFDA to specific developments and exemption from ILSFDA registration requirements in several different development scenarios.
An amendment to ILSFDA to partially exempt condominium developments took effect on Mar. 25, 2015. In the years since some applications of the exemption are clear, but some key issues remain unresolved or fraught with ambiguity.
Court interpretations of the Act are inconsistent, and developers must continuously navigate potential legal land mines within ILSFDA. Counsel to developers must ensure properties are properly registered under ILSFDA or are exempt from the Act.
Listen as our authoritative panel of attorneys provides their unique perspectives, overview and analysis of current ILSFDA regulations, guidelines and procedures, including the partial exemption for condo developments, ILSFDA litigation developments, and CFPB ILSFDA-related enforcement activity.
Outline
- ILSFDA statutory and regulatory framework
- 2015 amendment partially exempting condo developments
- The CFPB 2016 electronic filing initiative
- Legal issues with registration statements
- Exemptions and drafting pointers
- Enforcement activity
- Recent private litigation developments
Benefits
The panel will review these and other key issues:
- When is registration required under ILSFDA, and what are the continuing compliance requirements?
- How does the CFPB identify targets for investigation?
- What issues have not been resolved or remain ambiguous in the condo exemption amendment?
- How are courts addressing ILSFDA cases?
- What are the compliance options, alternatives, strategies, and pitfalls for developers under ILSFDA?
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