Connecticut Wholesaling Laws: PA 25-168 Compliance Guide

Connecticut has enacted one of the most comprehensive wholesaling regulatory frameworks in the country. Public Act 25-168 (HB 7287), in effect since July 1, 2026, requires wholesaler registration, gives sellers a three-business-day cancellation right, caps closing timelines, and bans recording wholesale contracts. It is codified at CGS §§20-329aaa to 20-329hhh. If you wholesale in Connecticut — or plan to — here is exactly what the law requires and how to comply.

This guide is structured as a practical checklist. Each section tells you what to do, when to do it, and what the consequences are for non-compliance. If you are looking for the broader national picture, see our state-by-state wholesaling legal guide.

What PA 25-168 Actually Says

Public Act 25-168 was passed as part of Connecticut's budget bill (HB 7287) and took effect on July 1, 2026. It carried over provisions from the standalone wholesaling bill HB 5572, creating a registration-based framework administered by the Department of Consumer Protection (DCP).

It covers a "real estate wholesaler": a person who enters into a contract with the seller of residential real property to facilitate or orchestrate the sale of that property to a third party, for compensation, without assuming title. The law does five major things:

1. Registration requirement: No one may act as a real estate wholesaler in Connecticut without a DCP wholesaler registration (CGS §20-329bbb). This is not a real estate license — it is a separate registration.
2. Seller cancellation right: Every wholesale contract must give the seller a three-business-day period to review it with an attorney or other advisor and to cancel for any reason, without penalty (CGS §20-329ccc(a)).
3. Closing date cap: No wholesale contract may set a closing date more than 90 days after all parties signed it. Extensions must be in writing and signed by all parties, or the contract automatically terminates at 90 days (CGS §20-329ccc(b)).
4. Disclosures: Before assigning, you must give the third party a written notice of their rights and the seller’s residential condition report. From October 1, 2026, you must also give the seller DCP’s written wholesale disclosure report before signing (CGS §20-329eee).
5. Recording ban: You may not record the contract, a notice of it, or any lien based on it (CGS §20-329fff).

PA 25-168 does not ban wholesaling. It creates a regulated framework that allows compliant wholesalers to continue operating. Any violation is an unfair or deceptive trade practice under the Connecticut Unfair Trade Practices Act (CUTPA) (CGS §20-329hhh).

The Department of Consumer Protection has registration details at portal.ct.gov/dcp. The statute text is on the Connecticut General Assembly website.

Registration with the Department of Consumer Protection

This is the most distinctive feature of Connecticut's law. While most states require only disclosures, Connecticut requires wholesalers to register with a state agency before they can operate.

Who must register: Anyone who acts as a real estate wholesaler for Connecticut residential property, including out-of-state operators. The statute has no volume or one-deal exemption. You may hold a real estate license and a wholesaler registration at the same time.

Registration process: Apply to the DCP in the form it prescribes, with a $285 nonrefundable application fee. A registration lasts up to two years and can be renewed for successive two-year periods for another $285 each time (CGS §20-329bbb). According to the DCP’s registration page, initial registrations expire July 31, 2028.

Consequence of operating unregistered: Acting as a wholesaler without a registration is a CUTPA violation. This exposes you to state enforcement action and private lawsuits.

Seller Cancellation Window

Every wholesale contract must give the seller a three-business-day period to review the contract with an attorney or other advisor, at the seller’s discretion and expense. During that period the seller can cancel without giving a reason and without any penalty or obligation — the only obligation is to return any deposit you paid to the seller.

What this means for your workflow:

1. Put the provision in the contract. The statute says every wholesale contract must include it. Use clear language.
2. Consider waiting to market until the window has expired. The law doesn’t forbid marketing during it, but if the seller cancels, you have nothing to assign.
3. Calendar the expiration carefully. Weekends and state holidays do not count as business days. If you sign on a Friday, the window does not expire until Wednesday (assuming no holidays).
4. Plan for the deposit. If the seller cancels, they return your deposit; nothing more.

90-Day Closing Date Cap

Wholesale contracts cannot set a closing date more than 90 days after all parties signed. This addresses a common complaint: sellers signing contracts with wholesalers who then spent months trying to find an end buyer while the property sat off-market.

What this means in practice:

• Your disposition timeline is finite. From the day the cancellation window expires, you have roughly 87 days to find a buyer and close.
• Extensions must be in writing, signed by all parties. Without a signed written extension, the contract automatically terminates when the 90 days run out. Do not rely on extensions as your primary strategy.
• Start marketing promptly after the cancellation window expires. You do not have the luxury of a leisurely disposition timeline in Connecticut.
• Price deals to move quickly. Tight timelines favor aggressively priced deals. If you are pricing a Connecticut deal at a thin margin, the time pressure of the 90-day cap adds risk.

Assignment vs Double Close — Which Rules Apply

Assignment of contract: You sell your equitable interest — the contractual right to purchase the property — without taking title. This is the core of what PA 25-168 regulates: registration, the cancellation provision, the 90-day cap, the disclosures, and the recording ban all apply. Before assigning, give the assignee a written notice of their rights under your contract with the seller, identifying you as a wholesaler who holds a future interest in the purchase but not title, plus the seller’s residential condition report (CGS §20-329ccc(c)).

Double close: You purchase the property at one closing, take title, then sell to the end buyer at a second closing. Because the law defines a wholesaler as someone who arranges a sale without assuming title, a true double close where you actually take title may fall outside it. Don’t assume so if your purchase contract is really built to hand the deal to someone else; get advice from a Connecticut attorney before relying on the structure.

Penalties for Non-Compliance

Connecticut's enforcement mechanism is the Connecticut Unfair Trade Practices Act (CUTPA). Under CGS §20-329hhh, any violation of the wholesaling sections is an unfair or deceptive trade practice.

• CUTPA violation: Operating without DCP registration, leaving out the cancellation provision, exceeding the 90-day cap, skipping the disclosures, or recording the contract is an unfair trade practice. In an action brought by the Attorney General, a court can impose a civil penalty of up to $5,000 per violation for wilful violations (CGS §42-110o(b)).
• DCP enforcement: The Department of Consumer Protection can investigate complaints and take enforcement action under CUTPA.
• Private right of action: CUTPA allows people who suffer a loss from an unfair trade practice to sue. A prevailing plaintiff can recover actual damages, punitive damages in some cases, and attorney's fees.
• Recorded documents are void: If a wholesale contract, notice, or lien is recorded anyway, it gives no notice to a good-faith buyer or lender, town clerks may refuse it, and the owner can wipe it out by recording an affidavit of facts (CGS §20-329fff).

The combination of state enforcement, private litigation, and the recording ban makes Connecticut one of the riskiest states to operate in without compliance.

Practical Compliance Checklist

Use this step-by-step workflow for every Connecticut residential wholesale deal.

1. Register with the DCP before your first deal. The law has been in effect since July 1, 2026. Apply through the DCP ($285, renew every two years).
2. Before signing (from October 1, 2026): Give the seller the DCP’s written wholesale disclosure report and get it signed. Get the seller’s written residential condition report.
3. At contract signing: Include the three-business-day review-and-cancel provision. Set a closing date no more than 90 days out. Including your DCP registration number in the contract is good practice, though not a statutory requirement.
4. Wait out the cancellation window. Calendar the exact expiration date, accounting for weekends and state holidays. Waiting to market until it passes avoids marketing a deal the seller cancels.
5. Do not record anything. No memorandum, notice, or purchaser’s lien on the land records.
6. Market accurately. State that you are selling contract rights, not the property itself. Mentioning your registration in marketing is good practice, not a statutory requirement.
7. Before assignment: Give the end buyer the written notice of their rights (identifying you as a wholesaler with a future interest, not title) and the seller’s residential condition report.
8. Close within 90 days. If you need an extension, get it in writing, signed by all parties. Otherwise the contract terminates automatically.
9. Document everything. Retain copies of your registration, all contracts, disclosures, cancellation window expiration dates, and closing documents. CUTPA claims can be brought after the fact, and your documentation is your defense.

Frequently Asked Questions

When does PA 25-168 take effect?

It took effect July 1, 2026. The seller disclosure report requirement starts October 1, 2026. If you signed a contract before July 1 that had not closed by then, talk to a Connecticut attorney about how the new rules apply.

Do I need both a real estate license and DCP registration?

They are separate. DCP registration is a wholesaler-specific requirement, and the statute says you may hold a license and a registration at the same time. Having a license does not replace the registration. If you are a licensed agent who also wholesales, plan on needing both.

What if the seller tries to cancel after three business days?

The statutory cancellation right lasts three business days. After that, the contract’s own terms and standard contract law govern. The seller would need other grounds (breach, duress, misrepresentation) to get out of the contract. Separately, the contract terminates automatically at 90 days unless extended in writing.

Can I extend beyond 90 days?

Yes, if the extension is in writing and signed by all parties to the contract. Without one, the contract automatically terminates when the 90 days expire. Do not rely on verbal agreements to extend.

I only do one deal a year in Connecticut. Do I still need to register?

Yes. The standalone bill (HB 5572) proposed a one-deal exemption, but the enacted law has none. Anyone acting as a real estate wholesaler needs a registration.

What about virtual wholesaling — operating from out of state?

Connecticut law applies to Connecticut properties regardless of where you are physically located. If you are assigning a purchase contract on Connecticut residential property, PA 25-168's requirements apply. Register with the DCP and follow the contract requirements even if you never set foot in the state.

Disclaimer

This guide is for informational purposes only and does not constitute legal advice. Laws and regulations change, and the application of any statute depends on the specific facts of your situation. Consult a licensed Connecticut real estate attorney before relying on this information for any particular transaction. Deal Run provides tools and information to help wholesalers operate more effectively — we are not a law firm and do not provide legal services.