The Consumer Financial Protection Bureau (CFPB) recently entered
into a consent order against International Land Consultants, Inc.
(ILC), a real estate development company, and four of its employees
involved in the marketing, development and sale of real property in
Tennessee. The enforcement action was based upon violations of the
Interstate Land Sales Full Disclosure Act, 15 U.S.C. §§
1701 et seq. (ILSA), as a result of misrepresentations made by ILC
in reports distributed to prospective and actual property
purchasers.
ILSA, a federal law passed in the late 1960s, regulates the
lease or sale of subdivided land through the use of interstate
commerce. ILSA's scope is expansive and includes advertising
through paper and internet. ILSA authorizes civil monetary
penalties up to $1 million during any one-year period, as well as
additional remedies including the right of buyers to revoke
contracts. Previously administered under the Department of Housing
and Urban
