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Financial Services Law Insights and Observations

CFPB eases filing deadlines for certain ILSA and Regulation J reports

Federal Issues Agency Rule-Making & Guidance CFPB ILSA Regulation J Covid-19

Federal Issues

On April 27, the CFPB released guidance in order to provide “flexibility and reduce administrative burden” for land developers that are subject to the Interstate Land Sales Full Disclosure Act (ILSA). The Bureau explains that in light of the impacts of Covid-19, it will not take supervisory or enforcement action against land developers for delays in filing financial statements and annual reports of activity, as long as the developers make good faith efforts to submit filings “within a reasonable time.” The guidance notes that all other ILSA and Regulation J requirements must be timely met.