Accession Law LLC

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Sep 10, 2014

Lease can be regulated financial product

We have received numerous inquiries for clarification (or to argue with the conclusion) that the Dodd/Frank legislation implicates lease/option transactions.

If interested, please see:
4) A transaction which includes a "lease" in which, at the inception of the lease, the intention is to transfer ownership of the property to the tenant is a "financial product or service."

This does not mean that all leases are financial products or that lease/option deals are impossible.  This does mean that lease/option deals may involve a regulated financial product or service in some circumstances.  In those cases, the lease/option deal would need to comply with the applicable regulations.