The First 100 Days and Beyond: ILSA Now Administered by the Federal Consumer Financial Protection Bureau
Mondaq Business Briefing › United States Law Articles in English (2011)
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The First 100 Days and Beyond: ILSA Now Administered by the Federal Consumer Financial Protection Bureau
Robert Chasnow is a Partner in our Washington, D.C. office
The Dodd-Frank Wall Street Reform and Consumer Protection Act, effective July 21, 2010, focuses extensively on banking and securities. Title X of the Act (codified at 12 U.S.C.A. Section 5511) establishes the Consumer Financial Protection Bureau (CFPB or the "bureau") and grants it extensive authority over banking and securities. In addition, Title X also consolidates under the bureau's authority administration of a number of consumer-oriented financial and real estate laws as of July 21, 2011, including the Interstate Land Sales Full Disclosure Act (ILSA), 15 U.S.C. 1701 et seq. For the past 40 years, ILSA had been administered by the U.S. Department of Housing and Urban Development (HUD). This alert is a continuation of the July 21, 2011 Real Estate alert, Crossing the Rubicon: ILSA Now Administered by the Federal Consumer Financial Protection Bureau, which described the then upcoming transition from HUD to CFPB. The daily operation that is most visible to developers is the CFPB staff review of new or amended registration...See the full content of this document
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