CFPB Provides Flexibility to Land Developers in Response to COVID-19

On April 27, 2020, and as part of its response to the COVID-19 pandemic, the Bureau issued a statement concerning supervisory and enforcement practices against land developers over delays in satisfying certain filing requirements under the Interstate Land Sales Full Disclosure Act (ILSA) and Regulation J.

As of April 27 and until further notice, the CFPB does not plan to take supervisory or enforcement action against land developers for:

• “delays in filing annual reports of activity with the Bureau, which Regulation J requires within 30 days of the annual anniversary of the effective date of a developer’s initial statement of record, provided that developers are making good faith efforts to file these reports within a reasonable time;” and

• “delays in filing financial statements with the Bureau, which Regulation J requires within 120 days of the close of a developer’s fiscal year, provided that developers are making good faith efforts to file these reports within a reasonable time.”

The CFPB’s statement is available here.