Interstate Land Sales: Why Do Study Materials Mention Both 25 and 100 Lots?

The numbers 25 and 100 refer to different exemptions under the Interstate Land Sales Full Disclosure Act (ILSA). They are not interchangeable answers to every question about the law.

Fewer than 25 lots

15 U.S.C. 1702(a)(1) provides a general exemption for sales or leases in a subdivision containing fewer than 25 lots, subject to the statute's anti-evasion condition.

Fewer than 100 lots

Section 1702(b)(1) provides an exemption from the specified registration and disclosure requirements for a subdivision containing fewer than 100 lots that are not exempt under subsection (a). This is a different, narrower exemption.

The CFPB's rule explains that the under-100-lot registration exemption does not remove the applicable anti-fraud requirements for sales that are not otherwise exempt.

How to approach a practice question

1. Identify whether it asks about a general exemption, registration, a property report, or anti-fraud duties.
2. Check whether the facts identify another exemption or a common promotional plan.
3. Do not assume that reaching 25 lots automatically requires a property report in every case.

If the question reduces the issue to one unexplained number, send the complete practice item for review. We need the wording and choices to explain which provision applies.

Official sources: 15 U.S.C. 1702(a) and (b) and 12 CFR 1010.6. Other exemptions and conditions can apply; this article explains the study distinction rather than deciding a development's legal obligations.