Nevada — Contract for Deed / Land Sale Installment Contract
Legal information, not legal advice. Verify against the cited primary sources before acting. Statutes in this area are frequently amended. Last verified: 2026-06-08.
Nevada occupies an unusual middle position. There is no dedicated land-contract
chapter that lays out a forfeiture-cancellation procedure (no Minnesota-style
statutory cancellation, no Texas-style Subchapter D). Instead, Nevada regulates the
instrument from two directions at once. First, the Deceptive Trade Practices Act
was amended in 2009 (effective Oct. 1, 2009) to make it a deceptive trade practice
for a seller to fail to disclose encumbrances and legal access, to record the
contract within 30 days, to pay the transfer tax, and — most consequentially — to
“include terms … providing rights and protections to the buyer that are
substantially the same as those under a foreclosure pursuant to chapter 40 of NRS.”
NRS 598.0923(1)(f). That last clause is the load-bearing one: Nevada does not flatly
ban forfeiture, but it makes a bare forfeiture clause without foreclosure-equivalent
protections a statutory violation, pushing compliant Nevada CFDs toward a
foreclosure-like default process. Second, Nevada’s courts of equity have for nearly
a century relieved purchasers against harsh forfeitures of a substantial equitable
interest where the default is curable and not willful — Mosso v. Lee (1931),
Slobe v. Kirby Stone (1968). The net effect is a hybrid regime: forfeiture is not
statutorily abolished, but a non-compliant forfeiture clause is a DTPA violation and an
inequitable forfeiture of a substantially-paid buyer will be set aside in equity.
0. Identity & Terminology
- In-state name(s): “land sale installment contract” is the statutory term (NRS 375.010(1)(d), NRS 598.0923); “contract for deed” and “installment land contract” are the common-usage synonyms. Defined as “any agreement between a seller and a buyer of real property located in this State pursuant to which the buyer gives and the seller receives the consideration paid in multiple payments during a specified period and the seller retains title to the real property … until the full contract price is paid, at which time title … is transferred by an instrument in writing from the seller to the buyer.” NRS 375.010(1)(d), https://nevada.public.law/statutes/nrs_375.010. The definition excludes deeds of trust, mortgages, and options.
- Recognition: statutory and common law. The buyer’s equitable interest and the anti-forfeiture relief are common-law doctrines; the disclosure/recording/foreclosure- protection overlay is statutory (DTPA, NRS 598.0923).
- Statutory home: No standalone CFD chapter. The governing pieces are NRS 598.0923 (Deceptive Trade Practices — land-sale-installment-contract duties), https://nevada.public.law/statutes/nrs_598.0923; the definition at NRS 375.010(1)(d); the transfer-tax chapter (NRS Ch. 375); and NRS Chapter 40 (foreclosure/deficiency), imported by reference through NRS 598.0923(1)(f)(5).
- Remedy regime:
hybrid. (a) Statutory layer: NRS 598.0923(1)(f)(5) requires the contract to give the buyer “rights and protections … substantially the same as those under a foreclosure pursuant to chapter 40 of NRS” — a bare forfeiture clause that omits these is a deceptive trade practice. https://nevada.public.law/statutes/nrs_598.0923. (b) Equity layer: Nevada courts relieve a substantially-invested purchaser against forfeiture for a curable, non-willful default (mosso-v-lee-1931; Slobe v. Kirby Stone). There is no statutory cure-period or notice form prescribed specifically for CFDs. See forfeiture-vs-foreclosure.
1. Formation & Mandatory Disclosures
-
Statute of frauds: Writing required. Conveyances of, and contracts for the sale of, real property or any interest in land must be in writing and subscribed. NRS 111.205 (no estate or interest in lands created/granted except by writing) and NRS 111.220 (agreements void unless in writing), https://www.leg.state.nv.us/nrs/nrs-111.html.
-
Mandatory disclosures: required — by DTPA. Under NRS 598.0923(1)(f), a seller commits a deceptive trade practice by knowingly failing, in connection with a land sale installment contract, to:
- (1) disclose in writing any encumbrance or other legal interest in the property, or any condition known to the seller that would affect the buyer’s use of the property;
- (2) disclose the nature and extent of legal access to the property;
- (3) record the contract under NRS 111.315 within 30 calendar days of accepting the first payment (see Recording, below);
- (4) pay the transfer tax imposed under NRS Chapter 375; and
- (5) include terms providing the buyer rights and protections substantially the same as those under a foreclosure pursuant to NRS Chapter 40.
NRS 598.0923(1)(f), https://nevada.public.law/statutes/nrs_598.0923. (Nevada’s separate Seller Real Property Disclosure Form, NRS 113.130, applies to residential resales generally and overlaps where the CFD conveys an existing dwelling.)
- Penalty for omission: a violation is a deceptive trade practice, which (i) gives the buyer a private right of action for actual damages, equitable relief, costs and reasonable attorney’s fees under NRS 41.600(2)(e), (3), https://nevada.public.law/statutes/nrs_41.600; and (ii) exposes the seller to public enforcement by the Attorney General / Commissioner of Consumer Affairs, including a civil penalty of up to 10,000 for violating a resulting court order or injunction (NRS 598.0999(1)), treble damages on the aggrieved party’s losses (NRS 598.0999(3)), and criminal liability (a knowing-and-willful deceptive trade practice is graded by the value of the loss — a misdemeanor where the loss is under $1,200, escalating to a category D, C, or B felony as the loss rises, NRS 598.0999(3)(a)–(e)). NRS 598.0999, https://nevada.public.law/statutes/nrs_598.0999.
-
Recording requirement: required — 30 days, by the seller. The seller must record the land sale installment contract under NRS 111.315 within 30 calendar days after accepting the first payment from the buyer; failure is a deceptive trade practice. NRS 598.0923(1)(f)(3), https://nevada.public.law/statutes/nrs_598.0923. (Recording generally — NRS 111.315 — gives constructive notice and priority, https://www.leg.state.nv.us/nrs/nrs-111.html.)
-
Annual accounting statement: No CFD-specific annual-statement statute. Nevada prescribes no periodic principal/interest/balance accounting duty unique to land sale installment contracts (contrast TX § 5.077 / MN). (Flagged in needs_verification — confirmed absent on the retrieved sources, but a negative is harder to prove.)
-
Prepayment: No CFD-specific prepayment statute. Prepayment rights and any penalty are contract-governed; Nevada imposes no statutory bar on prepayment penalties for non-consumer-mortgage seller financing. (Flagged in needs_verification.)
-
Usury / interest cap: No general usury cap. “Parties may agree for the payment of any rate of interest on money due or to become due on any contract,” provided the rate is stated in writing. NRS 99.050(1), https://nevada.public.law/statutes/nrs_99.050. The only ceiling is the Military Lending Act 36% APR cap for covered servicemembers (NRS 99.050(2)). Applies to CFD financing like any seller-financed balance.
2. Buyer’s Equitable Interest
- Equitable title: Nevada follows the common-law rule that the installment buyer holds equitable title while the seller retains bare legal title as security; the buyer is treated as the beneficial owner. The doctrine underlies the anti-forfeiture relief in Mosso and Slobe (the court protected the buyer’s equitable interest against forfeiture). See equitable-conversion and mosso-v-lee-1931 (§ 8). (A modern Nevada Supreme Court opinion squarely labeling the CFD buyer’s interest “equitable title” is flagged in needs_verification.)
- Equitable conversion: Recognized in substance through the equitable-interest and risk-of-loss case line; see equitable-conversion.
- Recordability / insurability: The buyer’s interest is recordable — indeed NRS 598.0923(1)(f)(3) requires the contract to be recorded, placing the buyer’s interest of record. Title insurance is available on the underlying title; an owner’s policy or a contract-vendee endorsement is the buyer’s practical protection.
- Risk of loss / improvements / waste: Contract-governed in practice; absent a clause the equitable owner in possession typically bears risk of loss consistent with the equitable-conversion line.
3. Default & Remedies → see forfeiture-vs-foreclosure
- Primary remedy: election, constrained by the DTPA foreclosure-protection mandate and by equity. Nevada has no statutory CFD-cancellation procedure with a fixed cure period; the remedies are (i) contractual forfeiture/termination, (ii) suit for the debt / specific performance, or (iii) a foreclosure-style sale where the contract (as NRS 598.0923(1)(f)(5) requires) builds in chapter-40 protections.
- Forfeiture available? — yes, but constrained on two fronts.
- Statutory constraint (DTPA). Forfeiture is not banned outright, but a contract that gives the buyer a bare forfeiture clause without “rights and protections substantially the same as those under a foreclosure pursuant to chapter 40 of NRS” is a deceptive trade practice. NRS 598.0923(1)(f)(5), https://nevada.public.law/statutes/nrs_598.0923. A compliant Nevada CFD therefore must afford foreclosure-equivalent process (notice, opportunity to cure/redeem, and — for owner-occupied housing — the chapter-40/107 protections).
- Equitable constraint (substantial-equity bar). Even with a forfeiture clause and a time-is-of-the-essence provision, Nevada equity will relieve against forfeiture of a substantial equitable interest where the default is curable and not willful and forfeiture would be harsh and inequitable; the court grants the buyer a reasonable time to cure or, where appropriate, favors an action for damages over total forfeiture. mosso-v-lee-1931, 53 Nev. 176, 295 P. 776 (1931); Slobe v. Kirby Stone, Inc., 84 Nev. 700, 447 P.2d 491 (1968). This is Nevada’s common-law analogue to Skendzel (skendzel-v-marshall-1973).
- Substantial-equity bar: exists — judicially. No fixed percentage/payment threshold (contrast Texas’s 40%/48 payments); the bar is the equitable “harsh-and-inequitable / substantial-investment vs. minor-curable-breach” standard of Mosso and Slobe (e.g., Slobe relieved an ~90,000 motel investment).
- Statutory cancellation: None CFD-specific. Nevada has no land-contract statutory-cancellation statute prescribing a cure period, runs-from date, or notice form for CFDs. The fixed-timeline non-judicial process lives in the deed-of-trust statute (NRS 107.080 — e.g., 15-day owner-occupied / 35-day other cure window plus a 3-month period before sale), which a chapter-40/107-compliant CFD sale would track. NRS 107.080, https://nevada.public.law/statutes/nrs_107.080/.
- Judicial foreclosure required when: the contract is written to give chapter-40 foreclosure protections (as NRS 598.0923(1)(f)(5) requires) and the seller elects a judicial sale, or where a court in equity orders a judicial sale of a substantially-paid buyer’s interest in lieu of forfeiture.
- Acceleration: enforceable as contracted, subject to the equitable-relief overlay; no CFD-specific statutory bar located. (Flagged in needs_verification.)
- Restitution offset on forfeiture: Nevada equity, in declining to enforce a harsh forfeiture, conditions relief on the buyer curing/paying the amount due; where forfeiture is allowed the seller generally retains payments as agreed, subject to the penalty/liquidated-damages doctrine (§ 3b). (No CFD-specific restitution statute; measure flagged in needs_verification.)
- Seller’s other remedies: suit on the debt / installments, specific performance, damages, judicial foreclosure / judicial sale, quiet title after termination, and ejectment (the defaulting buyer is an equitable owner, not a tenant — see § 3b).
▸ For Sellers / Operators — Nevada has no tidy forfeiture statute, which is a trap, not a freedom. The deal-defining rule is NRS 598.0923(1)(f): it is a deceptive trade practice — exposing you to the buyer’s damages + attorney’s fees (NRS 41.600), AG civil penalties up to $15,000/willful violation, treble damages, even criminal liability (NRS 598.0999) — to (1) omit written disclosure of encumbrances and legal access, (2) fail to record within 30 days of the first payment, (3) skip the transfer tax, or (4) sell on a bare forfeiture clause instead of building in chapter-40 foreclosure-equivalent protections. Layer on the equity rule: a court will not let you forfeit a buyer who has built substantial equity over a minor, curable default (Mosso, Slobe) — give a real cure opportunity or pursue a judicial sale. Draft the contract to include the chapter-40 protections and a conspicuous cure-and-foreclosure process, and pay the NRS 375 transfer tax at signing.
▸ For Buyers — Your protections are (1) the DTPA disclosure/record/foreclosure- protection duties (NRS 598.0923) with a private action for damages and fees (NRS 41.600); (2) equitable relief from forfeiture if you have substantial equity and a curable default (Mosso, Slobe); and (3) your equitable ownership (§ 2) — you are an owner, not a tenant.
3b. Remedies — Advanced
- Election of remedies: Contract- and equity-driven. A seller who has built chapter-40 protections into the contract (per NRS 598.0923(1)(f)(5)) is channeled toward a foreclosure-style sale; a seller pursuing bare forfeiture risks the DTPA violation and equitable relief against the forfeiture.
- Deficiency: Governed by NRS Chapter 40 anti-deficiency / fair-value framework to the extent the CFD is enforced as a chapter-40 foreclosure; NRS 40.455–40.459 cap a deficiency at the difference between the indebtedness and the property’s fair market value. (Application to a CFD specifically — vs. a deed of trust — flagged in needs_verification.)
- Equitable relief from forfeiture: Courts grant it. Standard: forfeiture of a substantial equitable interest will be set aside where the default is curable and not willful and enforcement would be harsh/inequitable, with the buyer given a reasonable time to cure (mosso-v-lee-1931; Slobe v. Kirby Stone; cf. Benetti v. Kishner, 93 Nev. 1, 558 P.2d 537 (1977), applying the same relief-from- forfeiture principle to a renewal option).
- Ejectment vs. eviction path: A defaulting CFD buyer is an equitable owner, not a tenant; the seller’s possessory remedy is ejectment / quiet title after a valid termination or a judicial sale, not summary landlord-tenant eviction. (Nevada case squarely reclassifying a CFD default out of summary eviction flagged in needs_verification.)
- Quiet title after cancellation: A quiet-title action (NRS 40.010) clears the buyer’s recorded interest after a valid termination/forfeiture; the recorded contract (NRS 598.0923(1)(f)(3)) means the seller generally must clear record title judicially. (Court/timeline specifics flagged in needs_verification.)
- Forfeited payments: Subject to the liquidated-damages vs. penalty doctrine — Nevada equity will treat a forfeiture that operates as a penalty disproportionate to actual loss as unenforceable (the animating logic of Mosso). A reasonable liquidated-damages/forfeiture-of-deposit clause is more defensible than forfeiture of a large accumulated equity.
- Intervening seller-lien risk to buyer: Because the seller holds legal title until payoff, liens/judgments against the seller can attach; the buyer’s recorded contract (mandatory under NRS 598.0923(1)(f)(3)) and the disclosure duty (encumbrances, (1)(f)(1)) are the principal protections.
4. Federal Overlay (as applied in-state) → see dodd-frank-seller-financing, safe-act-mlo
- Dodd-Frank exposure: A Nevada residential CFD is seller financing / “credit” under TILA. The ≤1-property (no balloon, no ATR) and ≤3-property (with ATR) seller-financer exclusions from the loan-originator definition apply the same in Nevada as nationally — see dodd-frank-seller-financing for the 12 C.F.R. § 1026.36(a) thresholds. Volume operators (multiple owner-financed dwellings / 12 months) lose the exclusion and must use a licensed loan originator and meet ATR.
- SAFE Act / MLO licensing: Nevada administers residential mortgage-loan-originator licensing through the Division of Mortgage Lending (NRS Chapter 645B/645F); seller-financers above the federal/state de-minimis thresholds may require an MLO. See safe-act-mlo. (Exact Nevada SAFE-Act section and the precise seller-financer carve-out flagged in needs_verification.)
- State consumer-protection overlay: NRS 598.0923 (the DTPA land-sale- installment-contract provisions) is Nevada’s CFD-specific overlay, enforced through the DTPA remedies (NRS 41.600 private action; NRS 598.0999 public penalties) and consumer- fraud doctrine.
- CFPB enforcement notes: Nevada’s 2009 DTPA amendment predates and parallels the national 2016+ CFPB/state-AG scrutiny of predatory CFDs (Harbour Portfolio era); the chapter-40-protection mandate is Nevada’s structural answer to forfeiture abuse.
5. Title, Recording & Wraps → see garn-st-germain-due-on-sale
- Memorandum / contract recording: Nevada requires recording of the land sale installment contract (not merely a memorandum) under NRS 111.315 within 30 days of the first payment; failure is a deceptive trade practice. NRS 598.0923(1)(f)(3), https://nevada.public.law/statutes/nrs_598.0923; recording effect, NRS 111.315, https://www.leg.state.nv.us/nrs/nrs-111.html.
- Garn-St. Germain due-on-sale: A CFD/wrap is a “transfer” that can trigger a lender’s due-on-sale clause under 12 U.S.C. § 1701j-3; the Garn-St. Germain residential exemptions generally do not cover a sale-on-terms to a third-party CFD buyer, so a Nevada wrap carries acceleration risk. See garn-st-germain-due-on-sale.
- Underlying mortgage / wraps: Permitted but risky. Nevada has no Texas-style § 5.085 fee-simple-or-strict-conditions bar, but the existence of an underlying lien is exactly the kind of “encumbrance or other legal interest” the seller must disclose in writing under NRS 598.0923(1)(f)(1); non-disclosure is a DTPA violation. Wrap CFDs over an existing first lien also carry due-on-sale exposure.
- Deed delivery: Title is conveyed by written instrument at payoff (the definition’s “at which time title … is transferred by an instrument in writing,” NRS 375.010(1)(d)); escrow-held deeds are a common contractual device.
- Marketable title at payoff: The seller must convey marketable title at completion; the buyer’s disclosure and recording protections (above) mitigate intervening-lien risk.
- Title insurance: Available; an owner’s policy or vendee endorsement is the buyer’s practical protection. (Insurer practices flagged in needs_verification.)
- Seller death / bankruptcy effect: The seller’s estate/trustee takes subject to the buyer’s recorded equitable interest; the recording mandate is the buyer’s chief protection.
6. Tax Treatment
- IRC § 453 installment reporting: A Nevada CFD is an installment sale; the seller reports gain ratably as principal is received, subject to the dealer exception (§ 453(b)(2), (l)). See irc-453-installment-sale.
- Property tax: Buyer pays in practice (contract-governed). Nevada has no CFD-specific allocation statute; the equitable owner in possession customarily carries ad valorem taxes.
- Homestead exemption for equitable owner: Nevada’s homestead is a creditor exemption (NRS Chapter 115) available to an owner who occupies the dwelling; an equitable owner under a CFD in possession is generally eligible. (Exact NRS 115 subsection confirming equitable/CFD ownership qualifies flagged in needs_verification.)
- Transfer / documentary tax — due ON the contract. Distinctively, NRS 375.020(1) taxes the land sale installment contract itself, not just the eventual deed: the real property transfer tax applies to a “land sale installment contract, if the consideration or value of the interest or property conveyed exceeds 1.95 per 1.25 county + 1.30/0.65/$500 base). NRS 375.020, 375.023, https://www.leg.state.nv.us/nrs/nrs-375.html. The seller’s failure to pay this tax is itself a deceptive trade practice (NRS 598.0923(1)(f)(4)). (Exact current per-county aggregate rate flagged in needs_verification — confirm with the county recorder.)
- Mortgage registration tax: None in Nevada.
7. Bankruptcy & Death / Divorce
- Buyer bankruptcy: National treatment splits between executory contract (§ 365) and secured debt characterization. Because the recorded Nevada CFD vests equitable ownership in the buyer with the seller holding title as security, a secured-debt characterization (buyer cures/pays through a plan) is well supported, but the question is fact-specific. See forfeiture-vs-foreclosure and the federal pages. (Nevada/9th-Cir. bankruptcy holding on CFD characterization flagged in needs_verification.)
- Seller bankruptcy: Buyer’s recorded equitable interest generally survives; the trustee takes subject to the recorded contract.
- Assignability by buyer: Generally permitted subject to contract terms; anti- assignment clauses are common. (Enforceability authority flagged in needs_verification.)
- Survivorship / divorce: Nevada is a community-property state; the equitable interest is characterized as community or separate property like other realty and passes by estate plan or community-property rules.
8. Case Law (real, verified)
| Case | Year | Topic | Holding (plain English) | Source |
|---|---|---|---|---|
| mosso-v-lee-1931 | 1931 | forfeiture / equitable relief | Even with a forfeiture + time-is-of-the-essence clause, equity relieves a land-contract buyer against forfeiture where the default (here, late taxes and a $33.75 interest installment) is inadvertent, not willful, and forfeiture would be inequitable. | https://www.courtlistener.com/opinion/3568651/mosso-v-lee/ |
| Slobe v. Kirby Stone, Inc. | 1968 | forfeiture / substantial equity | Installment purchaser given a reasonable time to cure an ~90,000 investment; a forfeiture clause does not preclude equitable relief if performance is tendered without unreasonable delay. | 84 Nev. 700, 447 P.2d 491 (1968) |
| Benetti v. Kishner | 1977 | relief from forfeiture (option) | A forfeiture of a contractual right will be relieved in equity absent prejudice where the breach is minor; confirms Nevada’s general anti-forfeiture posture. | https://law.justia.com/cases/nevada/supreme-court/1977/8410-1.html |
- Mosso v. Lee, 53 Nev. 176, 295 P. 776 (1931). Nevada Supreme Court. Good law — repeatedly cited (incl. Slobe, Benetti) as the foundational Nevada relief-from- forfeiture authority for land contracts. Opinion text retrieved via CourtListener.
- Slobe v. Kirby Stone, Inc., 84 Nev. 700, 447 P.2d 491 (1968). Nevada Supreme Court. Good law. Citation confirmed across multiple sources; opinion text not directly rendered this run (flagged below).
- Benetti v. Kishner, 93 Nev. 1, 558 P.2d 537 (1977). Nevada Supreme Court. Good law. An option/lease-renewal case, cited here only for the general relief-from-forfeiture principle, not as a CFD holding.
9. Edge Cases (state-specific notes)
- garn-st-germain-due-on-sale — A Nevada wrap/CFD over an existing first lien risks due-on-sale acceleration; the underlying lien must also be disclosed in writing (NRS 598.0923(1)(f)(1)).
- Bare forfeiture clause = DTPA violation — the single most counter-intuitive Nevada rule: selling on a forfeiture-only CFD without chapter-40-equivalent protections is a deceptive trade practice (NRS 598.0923(1)(f)(5)), not a permitted shortcut.
- Transfer tax due at contract — unlike most states, Nevada taxes the installment contract itself (NRS 375.020(1)); non-payment is also a DTPA violation (NRS 598.0923(1)(f)(4)).
- No statutory cure clock — Nevada prescribes no CFD cure-period/notice form; the protections are the DTPA mandate plus equitable relief from forfeiture.
- Manufactured / mobile homes — sales of manufactured homes implicate the Nevada Housing Division / NRS Chapter 489 titling regime in addition to CFD rules. (Flagged in needs_verification.)
10. Operations
- Where records live: County Recorder real-property records (Clark, Washoe, and the other 15 counties); recording of the contract within 30 days is mandatory (NRS 598.0923(1)(f)(3)).
- Public access: County recorder online portals (e.g., Clark County Recorder, Washoe County Recorder); leg.state.nv.us/nrs for the statutes.
- Who may draft (UPL): Nevada restricts non-lawyer drafting of conveyancing instruments; tailored CFD terms, the deed, and the chapter-40-protection language are typically attorney- or title-company-prepared. Filling blanks in a standard form is generally permitted; drafting bespoke terms risks UPL.
- Costs / timelines: County recording fees; transfer tax at signing (NRS 375); the controlling clock is the 30-day recording deadline. There is no statutory CFD cure clock — any cure/foreclosure timeline comes from the contract’s chapter-40 protections.
- Key agencies: County Recorders; Nevada Division of Mortgage Lending (MLO licensing); Commissioner of Consumer Affairs / Attorney General (DTPA enforcement); Department of Taxation (transfer tax administration).
11. Meta
- sources:
- {type: statute, url: “https://nevada.public.law/statutes/nrs_598.0923”, retrieved: 2026-06-08}
- {type: statute, url: “https://nevada.public.law/statutes/nrs_375.010”, retrieved: 2026-06-08}
- {type: statute, url: “https://nevada.public.law/statutes/nrs_41.600”, retrieved: 2026-06-08}
- {type: statute, url: “https://nevada.public.law/statutes/nrs_598.0999”, retrieved: 2026-06-08}
- {type: statute, url: “https://nevada.public.law/statutes/nrs_99.050”, retrieved: 2026-06-08}
- {type: statute, url: “https://www.leg.state.nv.us/nrs/nrs-375.html”, retrieved: 2026-06-08}
- {type: statute, url: “https://www.leg.state.nv.us/nrs/nrs-111.html”, retrieved: 2026-06-08}
- {type: statute, url: “https://nevada.public.law/statutes/nrs_107.080/”, retrieved: 2026-06-08}
- {type: case, url: “https://www.courtlistener.com/opinion/3568651/mosso-v-lee/”, retrieved: 2026-06-08}
- {type: case, url: “https://law.justia.com/cases/nevada/supreme-court/1977/8410-1.html”, retrieved: 2026-06-08}
- {type: secondary, url: “https://nevadalegalservices.org/land-sale-installment-contracts/”, retrieved: 2026-06-08}
- {type: secondary, url: “https://contractfordeed.uslegal.com/state-laws/nevada-contract-for-deed-law/”, retrieved: 2026-06-08}
- needs_verification:
Direct retrieval of the official leg.state.nv.us text of NRS 598.0923— RESOLVED 2026-06-08: the official leg.state.nv.us/nrs/nrs-598.html chapter text was retrieved verbatim and confirms the structure NRS 598.0923(1)(f)(1)–(5) (land-sale-installment seller duties) and the definition cross-reference at subsection 2(a) → NRS 375.010(1)(d). (Note: the nevada.public.law and some third-party mirrors mis-rendered the subsection numbering; the official chapter text is controlling.)- Confirmation that Nevada prescribes NO CFD-specific annual-accounting-statement and NO CFD-specific prepayment statute (negatives based on absence in retrieved sources).
- A modern Nevada Supreme Court opinion expressly labeling the CFD buyer’s interest “equitable title,” and a case reclassifying a CFD default out of summary landlord-tenant eviction into ejectment.
- Application of NRS Chapter 40 anti-deficiency / fair-value framework specifically to a land sale installment contract (vs. a deed of trust).
- Slobe v. Kirby Stone, Inc., 84 Nev. 700, 447 P.2d 491 (1968) — citation, the ~90,000 motel-investment facts, and the relief-from-forfeiture holding confirmed against primary case-law digests; full reporter opinion text not directly rendered this run (verification adequate; flagged only for completeness).
- Exact current aggregate NRS 375.020/375.023 transfer-tax rate per $500 by county, and the precise large-county breakdown.
- Nevada SAFE-Act (NRS 645B/645F) seller-financer MLO carve-out section and threshold.
- NRS Chapter 115 subsection confirming a CFD/equitable owner qualifies for the homestead exemption.
- Nevada/9th-Cir. bankruptcy characterization (executory contract § 365 vs. secured debt) of a recorded Nevada CFD; enforceability of anti-assignment clauses.
- Acceleration-clause enforceability authority specific to Nevada CFDs.
- open_questions:
- Does NRS 598.0923(1)(f)(5)‘s “rights and protections substantially the same as those under a foreclosure” require a judicial foreclosure, or is a contractually-built chapter-40/107-equivalent non-judicial sale sufficient? No Nevada appellate gloss located.
- Where a seller violates NRS 598.0923 (e.g., bare forfeiture clause), is the forfeiture clause itself void/unenforceable, or does the buyer’s remedy sound only in DTPA damages?
- cross_links: forfeiture-vs-foreclosure, equitable-conversion, dodd-frank-seller-financing, safe-act-mlo, garn-st-germain-due-on-sale, irc-453-installment-sale, mosso-v-lee-1931, skendzel-v-marshall-1973, sebastian-v-floyd-1979
- changelog:
- 2026-06-08 — Initial authoring. Populated all modules from NRS 598.0923 (DTPA land-sale-installment-contract duties), NRS 375.010(1)(d) (definition), NRS 41.600 & 598.0999 (penalties), NRS 99.050 (interest), NRS 111.205/.220/.315 (frauds/recording), NRS 375.020/.023 (transfer tax), NRS 107.080 (deed-of-trust timeline), and verified Nevada relief-from-forfeiture case line (Mosso v. Lee; Slobe v. Kirby Stone; Benetti v. Kishner). Remedy regime classified
hybrid. Created mosso-v-lee-1931 case page. - 2026-06-08 — Adversarial citation-verification pass. Retrieved the official leg.state.nv.us text of NRS 598.0923, 375.010, 375.020/.023, 41.600, 598.0999, 99.050, 107.080, 111.205/.220/.315 verbatim and confirmed every statutory citation and subsection number (incl. 598.0923(1)(f)(1)–(5)). Corrected the AG civil-penalty figure for a willful deceptive trade practice from “15,000** per NRS 598.0999(2) (two occurrences), and corrected the criminal-liability description (loss-value-graded misdemeanor→category D/C/B felony, not “category D felony on repeat offenses”). Confirmed Mosso v. Lee (incl. the 8,320 default / ~$90,000 motel), and Benetti v. Kishner against primary digests — all real, correctly cited, no fabrications. All wiki-links resolve.
- 2026-06-08 — Initial authoring. Populated all modules from NRS 598.0923 (DTPA land-sale-installment-contract duties), NRS 375.010(1)(d) (definition), NRS 41.600 & 598.0999 (penalties), NRS 99.050 (interest), NRS 111.205/.220/.315 (frauds/recording), NRS 375.020/.023 (transfer tax), NRS 107.080 (deed-of-trust timeline), and verified Nevada relief-from-forfeiture case line (Mosso v. Lee; Slobe v. Kirby Stone; Benetti v. Kishner). Remedy regime classified
Disclaimer. This page is legal information, not legal advice, and may be out of date. Contract-for-deed statutes are frequently amended and remedies turn on facts. Consult a licensed attorney in this jurisdiction before drafting, enforcing, or signing an installment land contract.