these Guidelines to permit a developer to wait until the sale of a unit in excess of the first ninety-nine to qualify for an exemption for the remaining units. Grove Towers teaches that exemption eligibility for the subdivision as it relates to a prospective purchaser is determined at the time the sale is made. For these and other reasons, we find HUD’s advisory opinion letter in the instant case unpersuasive. ILSA is a strict liability statute enacted for the purpose of protecting the public and should be liberally construed in favor of the public. The Act is clear that the improved lot exemption does not apply if the method of disposition is adopted for the purpose of evasion of ILSA. See 15 U.S.C. § 1702(a)(2). See also Pigott v. Sanibel Dev. LLC, 576 F.Supp.2d 1258 (S.D.Ala.2008) (<HOLDING>). This court finds that because 200 East failed
holding that various versions of the statute qualify as an exemption 3 statute holding the government waived its argument on appeal that the defendant did not have standing to challenge a search when it failed to raise the argument to the district court holding that two hour rest breaks were compensable sleep time for law enforcement employees that were subject to the exemption under  207k holding that nonsignatories to a contract have no rights under the contract and thus no standing to assert claims under the contract holding developers argument that nine of 108 units were subject to a preconstruction contract obligating the developer to construct within two years operated to circumvent ilsa and thus did not qualify for the improved lot exemption