Key Takeaways
- • Congress has enacted the "Homes Are for People, Not Corporations" provisions as Title X of the 21st Century ROAD to Housing Act, according to Squire Patton Boggs, following its April 2026 client alert.
- • The enacted Act retains the 350-home threshold and the broad "investment control" concept in defining a "large institutional investor" (LII), closely tracking the March Senate bill.
- • Most family offices are unlikely to qualify as LIIs and are not expected to be directly subject to the Act's single-family home purchase restrictions, absent unusual governance or control rights.
- • Family offices acting as limited partners in LII-sponsored funds may face higher management fees or fund expenses as LIIs absorb new congressional reporting compliance costs.
- • A HUD-administered renter outreach program will let renters report disputes and potential violations, with HUD empowered to investigate, request information from covered investors, and publish annual reports.
Summary
Squire Patton Boggs reports that Congress has passed the "Homes Are for People, Not Corporations" provisions as Title X of the 21st Century ROAD to Housing Act (the "Act"), updating the firm's April 2026 client alert. The firm says the key takeaways for family offices remain largely unchanged. The enacted Act closely follows the March Senate bill, retaining both the 350-home threshold and the broad concept of "investment control" in defining a "large institutional investor" (LII). As a result, absent unusual governance or control rights, most family offices are unlikely to be considered LIIs and are not expected to be directly subject to the Act's purchase restrictions.
The enacted version contains two notable developments relating to compliance and enforcement. First, LIIs must submit annual reports to Congress on their single-family home holdings. Although these reporting requirements apply only to LIIs, the firm cautions that family offices invested as limited partners in LII-sponsored funds should anticipate that associated compliance costs may be passed through as higher management fees, fund expenses or similar charges.
Second, the Act establishes a renter outreach program administered by the Department of Housing and Urban Development (HUD). Under the program, renters may report disputes and potential violations involving properties owned by LIIs. HUD is authorized to investigate certain complaints, request information from covered investors, coordinate with other agencies and publish annual reports summarizing information received.
Squire Patton Boggs expects the program, together with the Act's purchase restrictions and congressional reporting requirements, to contribute to heightened regulatory scrutiny and may continue to affect deal flow involving large single-family home portfolios.
The enacted version contains two notable developments relating to compliance and enforcement. First, LIIs must submit annual reports to Congress on their single-family home holdings. Although these reporting requirements apply only to LIIs, the firm cautions that family offices invested as limited partners in LII-sponsored funds should anticipate that associated compliance costs may be passed through as higher management fees, fund expenses or similar charges.
Second, the Act establishes a renter outreach program administered by the Department of Housing and Urban Development (HUD). Under the program, renters may report disputes and potential violations involving properties owned by LIIs. HUD is authorized to investigate certain complaints, request information from covered investors, coordinate with other agencies and publish annual reports summarizing information received.
Squire Patton Boggs expects the program, together with the Act's purchase restrictions and congressional reporting requirements, to contribute to heightened regulatory scrutiny and may continue to affect deal flow involving large single-family home portfolios.
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