Legal Alert: For Real Estate Developers: Major Development in Enforcement of the Interstate Land Sales Full Disclosure Act
As part of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the Consumer Financial Protection Bureau (“CFPB”) has now been charged with the enforcement of the Interstate Land Sales Full Disclosure Act (“ILSA”) as of July 21, 2011. Prior to that time, the Office of Interstate Land Sales Registration (“OILSR”), a sub-agency of the Department of Housing and Urban Development (“HUD”), was tasked with enforcement of ILSA. The CFPB, created to enhance consumer protection and to allow for more effective regulation of the financial and housing markets, is comprised of former HUD officials as well as officials from the Federal Trade Commission, the Treasury Department and the Federal Deposit Insurance Corporation. As such, although ILSA itself has not changed, the CFPB is expected to provide greater protection to consumers and will likely result in significant changes to ILSA in the future.