CFPB & State-AG Enforcement of Contract for Deed

Legal information, not legal advice. Verify against the cited primary sources before acting. The federal consumer-protection posture toward contracts for deed is recent, evolving, and politically contested; confirm the current CFPB position and any pending litigation before relying on it. Last verified: 2026-06-08.

A contract for deed is not a regulatory blind spot. Since roughly 2016 a coordinated enforcement wave — the federal Consumer Financial Protection Bureau (CFPB), a cluster of state attorneys general, and at least one city law department — has treated predatory installment-land-contract programs as consumer-credit and consumer-fraud violations, not as ordinary real-estate sales. The throughline of every action is the same: a CFD secured by a buyer’s home is functionally a mortgage, the seller who runs the program at scale is a creditor / lender, and the consumer-protection statutes that police mortgage lending — TILA, the CFPA’s UDAAP prohibition, the FCRA, ECOA, the Fair Housing Act, and each state’s UDAP / licensing law — apply by their terms. This page maps the federal authority, the landmark actions, and the compliance backdrop they create for any operator selling on terms.

• Authority (CFPB / federal):
  • Consumer Financial Protection Act (CFPA), 12 U.S.C. §§ 5481, 5531, 5536 — defines “credit” (§ 5481(7)), prohibits unfair, deceptive, or abusive acts or practices (UDAAP) by covered persons, and grants the CFPB enforcement authority. Retrieved https://www.law.cornell.edu/uscode/text/12/5481 (2026-06-08).
  • CFPB authority to interpret TILA, 12 U.S.C. § 5512(b)(1) — basis for the 2024 advisory opinion. Retrieved https://www.law.cornell.edu/uscode/text/12/5512 (2026-06-08).
  • CFPB supervisory authority over larger-participant mortgage originators, 12 U.S.C. § 5514(a)(1)(A) — supervision of any covered person who originates consumer loans “secured by real estate.” (Cited in the 2024 advisory opinion at n.28.)
• Authority (TILA overlay these actions invoke): see the companion pages dodd-frank-seller-financing (LO Rule 12 C.F.R. § 1026.36; ATR/QM Rule 12 C.F.R. § 1026.43) and safe-act-mlo (loan-originator licensing). The enforcement wave is the application of those regimes to CFD programs.
• Primary enforcement / guidance documents (each retrieved 2026-06-08):
  • Consent Order, In re Harbour Portfolio Advisors, LLC; National Asset Advisors, LLC; National Asset Mortgage, LLC, CFPB File No. 2020-BCFP-0004 (June 23, 2020). https://www.consumerfinance.gov/policy-compliance/enforcement/actions/harbour-portfolio-advisors-llc-et-al/
  • CFPB Advisory Opinion, Truth in Lending (Regulation Z); Consumer Protections for Home Sales Financed Under Contracts for Deed, 89 FR 68086 (Aug. 23, 2024) (Doc. 2024-18620; issued Aug. 13, 2024; an interpretive rule under CFPA § 1022(b)(1)). https://files.consumerfinance.gov/f/documents/cfpb_contract-for-deed_advisory-opinion_2024-08.pdf
  • CFPB, Report on Contract for Deed Lending (Aug. 2024). https://files.consumerfinance.gov/f/documents/cfpb_contract-for-deed_report_2024-08.pdf
  • Commonwealth of Pennsylvania v. Harbour Portfolio Advisors, LLC, settlement announced by the Pa. Office of Attorney General (restitution for Pennsylvania buyers under the UTPCPL).
  • NY DFS / NY OAG settlement with Vision Property Management, LLC (Jan. 10, 2020; $3.76M; unlicensed-mortgage-lending theory). https://www.dfs.ny.gov/reports_and_publications/press_releases/pr202001101

---

1. The federal theory: a CFD is “credit,” and a scaled seller is a “creditor”

The single most consequential federal development is the CFPB’s 2024 advisory opinion, which the agency styled as an interpretive rule under CFPA § 1022(b)(1) (12 U.S.C. § 5512(b)(1)) and published at 89 FR 68086 (Aug. 23, 2024). It does not create new obligations; it states that existing TILA / Regulation Z duties already attach to contracts for deed. Its operative holdings, quoted from the document:

• A CFD is “credit.” “TILA’s definition of ‘credit’ includes the typical contract for deed.” TILA and Regulation Z define credit as “the right granted [by a creditor to a debtor] to defer payment of debt or to incur debt and defer its payment” — 15 U.S.C. § 1602(f); 12 C.F.R. § 1026.2(a)(14). Because the buyer “receiv[es] exclusive possession of the property … at the outset of the contract in exchange for the obligation to repay the agreed-upon value of that property over time,” the deal “constitutes a debt under TILA.” (Advisory Opinion § I.B.1.a.)

• It is closed-end consumer credit. Where the home is bought primarily for personal/family/household purposes, the CFD is “consumer credit” (12 C.F.R. § 1026.2(a)(12)), and because it is a one-time transaction it is “closed-end credit” (12 C.F.R. § 1026.2(a)(10), (20)), “subject to the applicable requirements of subpart C of Regulation Z.” (§ I.B.1.b.)

• A dwelling-secured CFD is generally a “residential mortgage loan.” TILA defines a residential mortgage loan to include “any consumer credit transaction that is secured by a mortgage, deed of trust, or other equivalent consensual security interest on a dwelling or on residential real property that includes a dwelling” (15 U.S.C. § 1602(dd)(5)). The CFPB reasons that the seller’s retained legal title functions as a security interest (12 C.F.R. § 1026.2(a)(25)), so “the relevant consideration … is not whether State law specifically regards contracts for deed as ‘mortgages,’ but only whether the contract for deed is secured by a … consensual security interest on a dwelling.” (§ I.B.2.) This is the doctrinal hinge that pulls CFDs into the dwelling-secured TILA protections regardless of how a state classifies them (installment-land-contract, equitable-conversion).

• The “creditor” trigger — frequency thresholds. A seller is a TILA creditor only if it “regularly extends credit” (12 C.F.R. § 1026.2(a)(17)). The CFPB recites Regulation Z’s numerical tests: a person regularly extends credit if it did so more than 25 times in the preceding/current calendar year, or more than 5 times for transactions secured by a dwelling, and as few as one time for a high-cost (HOEPA) mortgage. (Advisory Opinion § I.B.3.b, citing 12 C.F.R. § 1026.2(a)(17)(v).) A genuine one-off seller of a non-high-cost CFD is not a TILA creditor; a program operator quickly is. This is the same volume logic that drives the dodd-frank-seller-financing LO-Rule and ATR/QM seller-financer carve-outs (the ≤1 / ≤3-property, 12-month thresholds) — and confirms that scale, not structure, is what triggers federal coverage.

• What attaches once the seller is a covered creditor. General TILA disclosures (amount financed, finance charge, APR — 15 U.S.C. §§ 1631, 1632; 12 C.F.R. §§ 1026.17–.18); for dwelling-secured loans, the ability-to-repay determination and the ban on mandatory pre-dispute arbitration clauses (12 C.F.R. § 1026.43(c); § 1026.36(h)(1)); and for high-cost loans, the full HOEPA overlay (12 C.F.R. §§ 1026.32, 1026.34 — pre-loan counseling, balloon and fee restrictions). The advisory opinion flags that where a seller “assert[s] there is no interest … but … raise[s] the sales price … in an amount equal to imputed interest,” the finance charge is “actively concealed … in violation of the Truth in Lending Act.” (Report § 2 n.6.)

The good-faith-reliance shield of TILA § 130(f) (15 U.S.C. § 1640(f)) protects acts done in conformity with the interpretive rule — a reason for operators to comply with, not ignore, it.

Caveat on durability. The advisory opinion was signed by then-Director Rohit Chopra in August 2024. CFPB leadership and enforcement priorities changed in 2025. Whether the Bureau actively enforces this reading is a policy question that turns on current leadership; the legal analysis (CFD = credit; scaled seller = creditor) rests on the statutory text and is independently invocable by private plaintiffs (TILA, FCRA, and ECOA carry private rights of action) and by state attorneys general, who may enforce TILA/CFPA under 12 U.S.C. § 5552 and their own UDAP statutes regardless of the CFPB’s posture. See needs_verification.

2. The landmark federal action — Harbour Portfolio (CFPB 2020)

Consent Order, In re Harbour Portfolio Advisors, LLC; National Asset Advisors, LLC; and National Asset Mortgage, LLC, CFPB File No. 2020-BCFP-0004 (June 23, 2020). Harbour’s business model — recited in the public record — was to buy foreclosed homes in bulk and cheap from sellers such as Fannie Mae and Freddie Mac and resell them to credit-impaired consumers on contracts for deed; several thousand consumers entered Harbour CFDs between 2012 and 2016.

• What the CFPB charged. The 2020 consent order rested on (1) deceptive acts or practices in violation of the CFPA — when consumers called the servicers (NAA / NAM) about errors on their consumer reports tied to the Harbour financing, they “were sometimes told that they had to file a dispute with the consumer-reporting agency,” a representation the Bureau found “inaccurate”; and (2) a furnishing failure under the FCRA’s Regulation V — NAM lacked adequate policies and procedures to ensure the accuracy and integrity of furnished information.
• Relief. Civil money penalties of $25,000(Harbour)\ast \ast and\ast \ast$10,000 (NAA and NAM jointly), plus injunctive terms barring misrepresentation of how consumers resolve consumer-report errors.
• Why it is the anchor. The penalties are small, but the action is the doctrinal cornerstone: the 2024 advisory opinion repeatedly cites the Harbour consent order as the prior occasion on which the CFPB “applied the CFPA’s … definition of credit” to a CFD program (Advisory Opinion nn.2, 25). Earlier, in CFPB v. Harbour Portfolio Advisors, No. 16-014183, 2017 WL 631914 (E.D. Mich. Feb. 16, 2017), a federal court enforcing a CFPB civil investigative demand held that Harbour’s CFDs “may be credit” because they “obligate the purchaser to pay a principal sum plus interest through deferred monthly payments,” and that an acceleration clause “strongly suggest[s] that Respondents are supplying ‘credit.‘” (Quoted at Advisory Opinion n.26.)

3. The state-AG and municipal front

State attorneys general — who have independent authority to enforce both TILA / the CFPA (12 U.S.C. § 5552) and their own UDAP and lending-licensing statutes — and at least one city pursued the same operators on overlapping theories. These are the verified actions:

• Pennsylvania v. Harbour Portfolio (Pa. OAG). The Pennsylvania Attorney General sued Harbour and its principal (Charles A. Vose III) under the Unfair Trade Practices and Consumer Protection Law (UTPCPL), alleging deceptive “for-sale-by-owner” / “Agreement for Deed” sales of uninhabitable homes to Pennsylvania buyers (at least 80 homes, sold without defect disclosure and on terms charging interest “at almost twice the maximum rate permitted by Pennsylvania law” with a large non-refundable down payment). The OAG announced a resolution returning $500,000 in restitution to affected Pennsylvanians. (Confirmed against the Pa. OAG press release retrieved this run, https://www.attorneygeneral.gov/taking-action/press-releases/attorney-general-josh-shapiro-wins-restitution-for-harmed-pennsylvanians-seeking-home-ownership/; see needs_verification for the exact docket and final consent-decree citation, which were not retrieved verbatim.)

• NY DFS / NY OAG v. Vision Property Management, LLC (Jan. 10, 2020). New York’s Department of Financial Services and Attorney General settled with Vision for $3.76million\ast \ast overan\ast \ast unlicensed-mortgage-lending\ast \ast theory:Visionbought"severelydistressedproperties"andresoldthemonlease-to-own/seller-financingagreementsat\ast \ast 10theDFS/OAGannouncement),and—pertheOA{G}^{\prime }sreportingonthematter—over40theseller-financingagreementsitsignedwithNewYorkconsumersendedinanevictionorsurrenderoftheproperty(the">40materialsbutwasnotontheDFSpressreleaseretrievedthisrun;seeneed{s}_{v}erification).Reliefincluded\ast \ast$600,000 in consumer restitution, transfer of 58 properties with clean title to consumers, and a ban on Vision providing residential-real-estate financing in New York. (A companion settlement with Atalaya Capital Management for $2.77 million addressed its role financing the program.)

• City of Cincinnati v. Harbour Portfolio. The City of Cincinnati Law Department sued Harbour over “predatory” land-contract practices; the reported settlement required Harbour to pay the city $125,000, bring properties into code compliance, disclose known defects in future land-sale contracts, and record all future land-sale contracts with the county recorder — i.e., it converted the abuses into affirmative disclosure-and-recording duties. (Reported via secondary press; the underlying settlement instrument was not retrieved this run — see needs_verification.)

The common UDAP/licensing playbook these actions establish: (a) recharacterize the lease-option/CFD as a disguised mortgage loan, exposing the seller to licensing liability (safe-act-mlo); (b) attack nondisclosure of property condition, title defects, the inflated price, and the forfeiture-on-one-missed- payment term as deceptive; and (c) extract restitution + structural injunctive relief (recording, disclosure, repair, sometimes a financing ban). Note that the Vision matter is technically a lease-to-own program, not a pure CFD — but regulators treated the economic substance identically, which is precisely the risk for operators who believe relabeling the instrument changes the analysis.

4. The empirical backdrop (CFPB Report on Contract for Deed Lending, Aug. 2024)

The CFPB paired the advisory opinion with a research report that supplies the factual predicate enforcers rely on. Its findings, quoted/summarized from the report:

• Resurgence driven by investors. “Over 7.5 million homes were lost to foreclosure between 2007 and 2016”; investors “purchased foreclosed homes in bulk at low prices” and resold them on CFDs — “[s]ome investors sold the same home back to the same family who had previously lost it … at a much higher price.” (Report § 1, citing CoreLogic 2017.)
• Targeting. CFD lending is “disproportionally concentrated in low-income, Black, Hispanic, immigrant, and some religious communities,” continuing a redlining-era pattern (CFDs were “long marketed to Black borrowers” from the 1930s–1960s when FHA financing was unavailable to them); the report notes targeting of Muslim borrowers with “interest-free” framing.
• Structural harms. “[I]nflated home prices and higher interest rates than mainstream mortgages,” “large balloon payments,” no appraisal, no inspection, no title search (Report Table 1A), no transfer of legal title at signing and no ability to sell/refinance/take secondary liens during the term (Table 1C), and no pre-foreclosure review, no foreclosure procedure before seizure, and no surplus to the buyer on default (Table 1D) — the forfeiture problem at the heart of forfeiture-vs-foreclosure and the substantial-equity cases (skendzel-v-marshall-1973, sebastian-v-floyd-1979).
• Market-level harm — “churning.” Sellers “generate profit by repeatedly selling homes without maintaining them,” perpetuating substandard stock and crowding out mainstream mortgage credit. (Report § 5.)
• The CFPB’s own list of federal hooks. The report names the statutes that “may apply to practices associated with contracts for deed”: the CFPA’s UDAAP prohibition, the Fair Credit Reporting Act, the Truth in Lending Act, the Interstate Land Sales Full Disclosure Act (ILSA), the Equal Credit Opportunity Act, and the Fair Housing Act — most with private rights of action — and underscores that state attorneys general independently enforce these plus state/local law. (Report § 1.)

5. The compliance backdrop this creates

For an operator, the enforcement wave converts a list of “predatory” practices into a negative compliance checklist — the conduct that drew restitution and bans is the conduct to avoid:

Practice that drew enforcement	Federal / state hook	Compliant posture
Inflated price with no appraisal/inspection	UDAAP; UTPCPL/UDAP; concealed finance charge under TILA	Appraise; disclose price basis; do not bury imputed interest in price
Single-missed-payment forfeiture of all equity	Substantial-equity / treat-as-mortgage doctrine (forfeiture-vs-foreclosure); UDAP unconscionability	Give statutory cure rights; treat as mortgage where the state requires it
No TILA disclosures / undisclosed APR	TILA §§ 1631–1632; 12 C.F.R. §§ 1026.17–.18 (if creditor)	If you cross the volume threshold, deliver TILA disclosures
No ability-to-repay assessment	12 C.F.R. § 1026.43(c) (dodd-frank-seller-financing)	Document ATR or fit a seller-financer exclusion
Mandatory arbitration clause	12 C.F.R. § 1026.36(h)(1)	Strike pre-dispute arbitration from dwelling-secured CFDs
Operating unlicensed at scale	SAFE Act / state MLO licensing (safe-act-mlo); NY Banking Law (Vision)	License or stay within the de-minimis seller exclusion
Misrepresenting credit-report dispute rights	CFPA deception; FCRA / Reg V (Harbour)	Furnish accurately; honor FCRA dispute procedures
Not recording the buyer’s interest; hiding defects	UDAP; municipal settlements (Cincinnati)	Record the memorandum/contract; disclose known defects

▸ For Sellers / Operators — The enforcement record makes three compliance facts non-negotiable. (1) Scale is the trigger. The 2024 advisory opinion holds that a dwelling-secured CFD is “credit” and generally a “residential mortgage loan,” and that a seller who exceeds Regulation Z’s frequency tests (**>5 dwelling-secured /

25 total in a year, or even once for a high-cost loan** — 12 C.F.R. § 1026.2(a)(17)(v)) is a TILA creditor owing disclosures, an ability-to-repay determination, and the arbitration ban. A genuine one-off sale is different; a program is regulated lending. Pair this with the dodd-frank-seller-financing and safe-act-mlo thresholds — qualifying for one carve-out does not exempt you from the others. (2) Don’t rely on the instrument’s label. Vision was a lease-to-own program and was still recharacterized as unlicensed mortgage lending; Harbour was a CFD program reached through UDAAP/FCRA. Regulators and AGs follow the economic substance. (3) The practices that drew restitution are the checklist above — inflated prices, one-missed-payment forfeiture, no disclosures, no ATR, hidden defects, unrecorded interests, and misrepresenting dispute rights. Compliance (appraisal, TILA disclosure where owed, statutory cure rights, recording, accurate furnishing) is what keeps a deal enforceable and out of an AG’s restitution column — and TILA § 130(f) good-faith reliance rewards conforming to the published interpretation.

▸ For Buyers — Even where a state’s CFD statute is thin, a scaled seller may owe you federal mortgage protections (TILA disclosures, ability-to-repay, no forced arbitration) and may be liable under your state’s UDAP law and (if unlicensed) its lending-license law. TILA, FCRA, ECOA, and the Fair Housing Act carry private rights of action, and your state attorney general can pursue restitution — the routes that returned money and clean title to buyers in the Pennsylvania and New York actions.

Primary sources (retrieved 2026-06-08)

• CFPB Advisory Opinion, Truth in Lending (Regulation Z); Consumer Protections for Home Sales Financed Under Contracts for Deed, 89 FR 68086 (Aug. 23, 2024) (Doc. 2024-18620; issued Aug. 13, 2024; interpretive rule under 12 U.S.C. § 5512(b)(1)) — holds a CFD is “credit” (15 U.S.C. § 1602(f); 12 C.F.R. § 1026.2(a)(14)), closed-end consumer credit, generally a “residential mortgage loan” (15 U.S.C. § 1602(dd)(5)) via the seller’s retained-title security interest (12 C.F.R. § 1026.2(a)(25)); recites the creditor frequency thresholds (12 C.F.R. § 1026.2(a)(17)(v)) and the ATR / arbitration / HOEPA duties. https://files.consumerfinance.gov/f/documents/cfpb_contract-for-deed_advisory-opinion_2024-08.pdf
• CFPB, Report on Contract for Deed Lending (Aug. 2024) — empirical findings on the investor-driven post-2008 resurgence, targeting of underserved communities, inflated prices/balloon payments/forfeiture, and the federal/state legal hooks (CFPA UDAAP, FCRA, TILA, ILSA, ECOA, FHA). https://files.consumerfinance.gov/f/documents/cfpb_contract-for-deed_report_2024-08.pdf
• Consent Order, In re Harbour Portfolio Advisors, LLC; National Asset Advisors, LLC; National Asset Mortgage, LLC, CFPB File No. 2020-BCFP-0004 (June 23, 2020) — CFPA deception (credit-report dispute misrepresentations) + FCRA/Reg V furnishing failure; CMPs of $25,000and$10,000; injunctive relief. https://www.consumerfinance.gov/policy-compliance/enforcement/actions/harbour-portfolio-advisors-llc-et-al/
• CFPB v. Harbour Portfolio Advisors, No. 16-014183, 2017 WL 631914 (E.D. Mich. Feb. 16, 2017) — CID-enforcement order; CFDs “may be credit” because they “obligate the purchaser to pay a principal sum plus interest through deferred monthly payments.” (Quoted in the 2024 advisory opinion n.26; the opinion text itself was not separately retrieved this run — see needs_verification.)
• Consumer Financial Protection Act, 12 U.S.C. §§ 5481, 5512(b)(1), 5514(a)(1)(A), 5531, 5536, 5552 — credit definition, UDAAP prohibition, interpretive authority, supervisory authority, and state-AG enforcement authority. https://www.law.cornell.edu/uscode/text/12/5481 · https://www.law.cornell.edu/uscode/text/12/5512
• NY DFS / NY OAG settlement with Vision Property Management, LLC (Jan. 10, 2020) — $3.76M;unlicensedmortgagelending;10–25$600,000 restitution + 58 properties transferred + financing ban; companion $2.77M Atalaya settlement. https://www.dfs.ny.gov/reports_and_publications/press_releases/pr202001101

Meta

• needs_verification:
  • Commonwealth of Pennsylvania v. Harbour Portfolio — the Pa. OAG press release (Shapiro, “Wins Restitution For Harmed Pennsylvanians”) was retrieved this run and confirms the principal (Charles A. Vose III), the UTPCPL theory, the “at least 80 homes,” the ~2x-cap interest, and the $500,000 restitution. Still unretrieved: the exact case caption, docket number, filing court, and the final settlement / consent-decree instrument with its precise UTPCPL counts (the 2018 complaint is posted at attorneygeneral.gov). Confirm against the primary complaint and final order before citing specific paragraphs.
  • City of Cincinnati v. Harbour Portfolio — the settlement amount ($125,000) and structural terms (code compliance, defect disclosure, mandatory recording) are reported only through secondary press; the underlying settlement agreement / court order was not retrieved. Treat as reported, not confirmed-primary.
  • CFPB v. Harbour Portfolio Advisors, 2017 WL 631914 (E.D. Mich.) — quoted second-hand from the 2024 advisory opinion’s footnote; the slip opinion itself was not independently pulled this run. Verify the quotation against the Westlaw/PACER opinion before relying on its exact wording.
  • Current CFPB enforcement posture (2025–2026) — whether the Bureau under post-2024 leadership is actively enforcing, has rescinded, or has declined to enforce the advisory opinion was not verified against a retrieved 2025–2026 primary document. The statutory analysis is durable and privately/AG-enforceable, but the agency’s current priorities should be confirmed before representing them.
  • NY settlement principal/CEO name and the precise NY Banking Law sections (licensing statutes invoked against Vision) were not retrieved verbatim; the DFS press release (retrieved this run) confirms the unlicensed-lending theory, the $3.76M/$600,000 / 58-property / financing-ban figures, the 10%–25% rate range, and the $2.77M Atalaya companion settlement — but not the “>40% eviction/surrender” statistic (that figure traces to the OAG’s case materials, not the retrieved DFS release) or the section numbers.
  • ILSA (15 U.S.C. §§ 1701–1720) application to CFDs — named by the CFPB report as a possible hook but not analyzed; whether and when a CFD subdivision sale triggers ILSA registration/disclosure (and its exemptions) warrants its own page or federal module on a later pass.
• open_questions:
  • Does the advisory opinion’s “retained legal title = security interest” reasoning survive in states whose CFD statute expressly denies the buyer a security interest or treats the contract as purely executory until completion? The opinion says state classification is irrelevant to the TILA question; litigants will test that.
  • For a small operator straddling the >5 dwelling-secured / 12-month line, how do the TILA creditor test, the dodd-frank-seller-financing ATR/LO carve-outs, and safe-act-mlo licensing thresholds interact in a single deal year? Normalize a worked example.
• cross_links: dodd-frank-seller-financing · safe-act-mlo · garn-st-germain-due-on-sale · forfeiture-vs-foreclosure · equitable-conversion · installment-land-contract · skendzel-v-marshall-1973 · sebastian-v-floyd-1979 · texas · minnesota · pennsylvania · new-york · ohio
• changelog:
  • 2026-06-08 — Page created. Mapped the CFPB/state-AG enforcement wave from primary sources retrieved this run: the 2024 CFPB advisory opinion (89 FR 68086) holding a dwelling-secured CFD is “credit” and generally a “residential mortgage loan,” with its creditor frequency thresholds and TILA/ATR/HOEPA hooks; the Aug. 2024 CFPB report’s empirical findings; the 2020 Harbour Portfolio consent order (File No. 2020-BCFP-0004); the 2017 E.D. Mich. CID-enforcement quotation; the NY DFS/OAG Vision Property Management settlement; and the Pennsylvania UTPCPL and Cincinnati municipal actions (flagged for primary-document confirmation). Built the negative compliance checklist tying each enforced practice to its federal/state hook.

---

Disclaimer. This page is legal information, not legal advice, and may be out of date. The federal posture toward contracts for deed is recent and contested, and enforcement priorities shift with CFPB leadership and litigation. Statutes, regulations, and agency interpretations change; confirm the current text of the CFPA, TILA / Regulation Z, the cited advisory opinion and report, and any pending or settled enforcement action — and that each is still operative — before structuring, selling, or buying on a contract for deed, and consult a licensed attorney in the relevant jurisdiction.