Carmel & Carmel News Updates

New York Guidelines For Advertising Out-Of-State Properties


On August 5, 2015 the Real Estate Finance Bureau of the New York Department of Law (the “Department”) presented a Memorandum pursuant to the State Administrative Procedure Act providing Guidelines for Advertising Out-of-State Real Estate Offerings.  While purportedly applying primarily to Internet Web Sites and Apps, the Guidelines provide ...

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Enforcement of the Interstate Land Sales Full Disclosure Act (“ILSFDA”) Shifts to the Bureau of Consumer Financial Protection


On July 21, 2011, enforcement of the Interstate Land Sales Full Disclosure Act (“ILSFDA”) shifted from the Office of Interstate Land Sales Registration (“OILSR”), previously a sub-agency at the Department of Housing and Urban Development (“HUD”), to the new Bureau of Consumer Financial Protection (“CFPB”) ...

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Second Circuit Appellate Court Strikes Down Bodansky, Making it Unwise For Developers to Combine ILSA Exemptions


On March 15, 2011, the United States Court of Appeals for the Second Circuit (the “Second Circuit Court”) confirmed the advice we have consistently provided to our condominium developer clients:  it is not prudent for developers selling pre-construction units in condominiums with more than 99 units to rely on a ...

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