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

Recording of a 90-minute premium CLE webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Wednesday, February 19, 2020

Recorded event now available

or call 1-800-926-7926

This CLE course 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 recent 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.


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 four years since some applications of the exemption are clear, but several key issues remain unresolved or fraught with ambiguity. Moreover, the amendment did not grandfather in condo developments that were in the sales process before the effective date.

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 new partial exemption for condo developments, ILSFDA litigation developments, and CFPB ILSFDA-related enforcement activity.



  1. ISLFDA statutory and regulatory framework
  2. 2015 amendment partially exempting condo developments
  3. The CFPB 2016 electronic filing initiative
  4. Legal issues with registration statements
  5. Exemptions and drafting pointers
  6. Enforcement activity
  7. Recent private litigation developments


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 recent condo exemption amendment?
  • How are courts addressing ILSFDA cases?
  • What are the compliance options, alternatives, strategies, and pitfalls for developers under ILSFDA?


Lee, Judyann
Judyann M. Lee

McMillan Metro

Ms. Lee’s real estate practice focuses primarily on issues surrounding common interest projects, including...  |  Read More

Lubinski, Joseph
Joey E. Lubinski

Husch Blackwell

Mr. Lubinski is a member of the firm’s Real Estate, Development and Construction team. His varied transactional...  |  Read More

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