News & Analysis as of

Senate passes bill exempting condo unit sales from ILSFDA registration

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...more

Second Circuit Sides With CFPB In ILSFDA Case While Applying Auer Deference

On May 6, the U.S. Court of Appeals for the Second Circuit agreed with the CFPB in holding that a single-story unit in a multi-story condominium is a “lot,” as that term is used in the Interstate Land Sales Full Disclosure...more

CFPB files amicus brief in Second Circuit ILSA case

On March 12, 2013, the CFPB filed a new amicus brief supporting the consumer/appellee’s position that the Interstate Land Sales Full Disclosure Act (ILSA) applies to condominium units, even where the unit does not also...more

CFPB reports new investigation

Yet another panel discussion at the ABA Consumer Financial Services Committee just held in Naples, Florida, entitled “Preparing for CFPB Exams and Enforcement” involved two speakers from the CFPB...more

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