Sullivan
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Biography

Will focuses his practice on representing institutional investors in private equity investments, with a concentration in secondaries, LP investments, equity co-investments and private investment fund formation. Will leads the firm’s secondaries group. He also regularly represents financial institutions in secured and unsecured financing transactions. Will has broad experience in advising investment managers in alternative asset classes, with a particular emphasis on timberland and agricultural investing.

Education
  • Boston College Law School (J.D.)
  • Dartmouth College (B.A.)
Bar & Court Admissions
  • Massachusetts
Professional Qualifications
  • Boston Bar Association
Awards & Honors
  • Chambers USA, Ranked in Private Equity: Fund Formation (Massachusetts) (2026)
  • Recommended by The Legal 500 U.S. (2022-2024)
  • Ranked in The Legal 500 Boston Elite for Banking and Finance (Including Restructuring) (2026)
  • "Rising Star," Massachusetts Super Lawyers (2023-2026)
Languages
  • French
Viewpoints
All Viewpoints
Impact of 21st Century ROAD to Housing Act on Institutional Investor Ownership of Single-Family Rental Homes
The U.S. Congress passed the 21st Century ROAD to Housing Act (the “Housing Act”) and presented it to President Trump on June 29, 2026. At midnight on July 10, 2026, the Housing Act became law because the President did not return it to Congress within ten days (Sundays excepted). The Housing Act includes a wide range of housing reforms designed with the goal of making housing more available and affordable.  This alert focuses on the impact of the Housing Act on institutional investor ownership of single-family rental homes.  The Housing Act does not prohibit institutional investor ownership of manufactured homes. The section of the Housing Act impacting institutional investor ownership of single-family rental homes is Section 1001 (the Section is titled “Homes Are for People, Not Corporations”).  The primary impacts under Section 1001 are (i) a prohibition on purchases of single-family homes (with important exceptions) and (ii) the creation of a “Renter Outreach Resource” managed by the federal government.  Section 1001 uses a number of defined terms, which are summarized in Appendix A to this alert.  The defined terms are indicated in this alert in italics.  The most important – and most extensive – defined term is excepted purchase, which includes, among other programs, purchases of single-family homes pursuant to build-to-rent programs and purchases of single-family homes from other large institutional investors. No Requirement to Dispose When the U.S. Senate passed a version of the Housing Act in March 2026, the legislation included a controversial, perhaps even unconstitutional, provision requiring institutional investors to dispose of certain single-family homes not later than seven years after the date of purchase.  A relief to such institutional investors, the Housing Act, as enacted, does not include that requirement to dispose. Prohibition on Purchases (with Several Exceptions) The Housing Act prohibits the purchase of single-family homes by large institutional investors, excluding any excepted purchase or any purchase of a single-family home in connection with a restructuring or other reorganization of ownership of single-family homes that were owned or purchased on or before the date of enactment of the Housing Act.  The prohibition on purchases takes effect on January 7, 2027 (180 days after the date of enactment of the Housing Act) (the “Effective Date”) and is repealed on January 7, 2042 (15 years after the Effective Date). Excepted purchases (i.e., those not prohibited) are described in detail in Appendix A under the defined term “Excepted Purchase”, but generally include many of the common methods by which institutional investors in single-family rental homes acquire such homes, including but not limited to: (i) build‑to‑rent programs, (ii) renovate‑to‑rent programs, (iii) repossessions, (iv) foreclosures, (v) purchases from another large institutional investor, or (vi) combinations of (i) through (v). Enforcement of Prohibition on Purchases The Secretary of the Treasury, or the Attorney General at the request of the Secretary of the Treasury, may bring an action against a large institutional investor that violates the prohibition on purchases for a civil penalty in an amount that is not more than $1,000,000 per violation, or three times the purchase price of the property involved, whichever is greater. Renter Outreach Resource As described in detail below, the Renter Outreach Resource is a comprehensive program that includes direct reporting of rental disputes by renters to Federal agencies, with investigation and reporting requirements imposed on applicable Federal agencies, and (at a minimum) provision of applicable state agency contact information to renters to facilitate state-level investigation.  In addition, large institutional investors must respond to information requests in connection with any investigation and are required to regularly provide certain information regarding the Renter Outreach Resource to their renters. Establishment of Renter Outreach Resource The Secretary of Housing and Urban Development (the “HUD Secretary”) is required, not later than 180 days after the date of enactment of the Housing Act, to establish the Renter Outreach Resource that consists of a toll-free telephone number and a public website designed to assist renters of residential properties owned by a large institutional investor in –  notifying Federal agencies about disputes relating to the rental of such properties, including disputes about potential violations of Federal law; sharing information about such disputes with other Federal agencies, including other Federal agencies that manage similar disputes; monitoring such disputes; and resolving such disputes, to the extent practicable.   Response to Outreach The HUD Secretary is required to establish reasonable procedures to promptly respond, in writing where appropriate, to a renter who provides information to the HUD Secretary about a dispute using the Renter Outreach Resource and document such responses.  Such responses are required to include, where appropriate, information about –  steps that have been taken by the HUD Secretary or another Federal agency in response to the information about the dispute provided by the renter, including determining the appropriate large institutional investor involved as described in the bullet below “Investigation of Potential Violations of Federal Law;” any responses received by the HUD Secretary or another Federal agency from the large institutional investor related to such dispute; and any outcome of the dispute, to the extent practicable.   Investigation of Potential Violations of Federal Law The HUD Secretary is required to promptly process and investigate any information relating to a dispute received through the Renter Outreach Resource about a potential violation of Federal law that is received from a renter of a residential property owned by a large institutional investor through the Renter Outreach Resource, including –  requesting information from a large institutional investor; determining the appropriate large institutional investor involved in the dispute; and sharing information about such potential violation of Federal law with any relevant Federal agencies, as the HUD Secretary may determine appropriate.   Upon request for information made pursuant to the Renter Outreach Resource, the HUD Secretary is required to provide a large institutional investor the opportunity to respond, including regarding whether such large institutional investor currently owns the property described in such request for information.   Information for Appropriate State Authority When the HUD Secretary receives information about a potential violation of State law or about a dispute received through the Renter Outreach Resource, from a renter of a residential property owned by a large institutional investor through the Renter Outreach Resource, the HUD Secretary is required, at a minimum, to provide the renter with contact information for the appropriate, State-specific, State authority authorized to process and investigate such information.   Notice About Renter Outreach Resource Each large institutional investor is required to –  provide to each renter of a residential property owned by such investor at the time such renter first occupies such home and annually thereafter –  written notice about the Renter Outreach Resource; and the name, phone number, and email address of the person or entity responsible for receiving and addressing renter disputes for the large institutional investor, and update the name, phone number, and email address within 30 days if such information changes prior to the subsequent time at which such notice is required to be provided; and   prominently feature information about the Renter Outreach Resource on a public website of such investor that is accessible by such renter.   Annual Notification Not later than 180 days after the date of enactment of the Housing Act, and not later than December 31st of each year thereafter, each person or entity that satisfies the definition of a large institutional investor is required to –  notify the HUD Secretary each year whether such owner is a large institutional investor; and in such notification, identify how many single-family homes such large institutional investor has direct or indirect investment control of as of the date of the submission of such notice, and the city and State where each such single-family home is located, unless such large institutional investor owns ten or fewer single-family homes in such city. Studies on Large Institutional Investors Not later than two years after the Effective Date, and again not later than ten years after the Effective Date, a GAO report and a HUD report are required to be submitted to the House Banking Committee and the Senate Committee on Financial Services. *     *     * Contacts Tax Cameron N. Cosby Carson Durdel Connie Lee Ameek Ashok Ponda Sarah D. Wellings Private Funds William C. Hanson Real Estate Karen J. Kepler Louis A. Monti John M. Steiner Appendix A Defined Terms in Section 1001 of the Housing Act Consumer Reporting Agency:  The term “consumer reporting agency” has the meaning given the term in section 603 of the Fair Credit Reporting Act (15 U.S.C. 1681a)). Excepted Purchase:  The term “excepted purchase” means any purchase of a single-family home that is –  Newly Constructed, For Sale Home Newly constructed, renovated, or a rental conversion for sale by a large institutional investor and not as a residence rented pending sale;   Build-to-Rent Program Pursuant to a build-to-rent program where the large institutional investor purchases newly constructed single-family homes to be managed as rental properties, whether as communities exclusively of renter-occupied single-family homes or as communities of single-family homes that are both owner- and renter-occupied;   Renovate-to-Rent Program Pursuant to a renovate-to-rent program that –  substantially rehabilitates single-family homes that do not meet structural or core system elements of local building codes; and makes improvements in an aggregate dollar amount of not less than 15% of the purchase price of the single-family home;   Homeownership Program Pursuant to a homeownership program that –  requires rental payments and any other fees that are not greater than those collected by the large institutional investor on other similarly situated single-family homes not covered by the eligible homeownership program; is subject to a contract between the large institutional investor and renter that shall be considered a consumer credit transaction secured by a dwelling or real property; provides for positive reporting of rental payments to consumer reporting agencies for any renter, who shall be informed of and opts into such reporting; and requires contribution of meaningful financial support from the large institutional investor, including price concessions, for the purchase of the single-family home by the renter;   Program to Boost Homeownership Pursuant to a program to boost homeownership that –  provides for positive reporting of rental payments to consumer reporting agencies for any renter who is informed of and opts into such reporting; provides for the right of first refusal and a 30-day ‘‘first look’’ period; and may entail the meaningful financial support from the large institutional investor, including price concessions, for the purchase of a single-family home by the renter (whether it is the home the renter occupies or another home);   Repossession In connection with the satisfaction of debts previously contracted in good faith and where the large institutional investor has the right to repossess the single-family home under such contract;   Foreclosure Undertaken by a mortgage servicer, lender, or other entity that has a legal right to a single-family home, for the purpose of loss mitigation or compliance with servicing or investor obligations, and not as a long-term investment strategy, and is solely as a result of –  a foreclosure; a deed-in-lieu of foreclosure; enforcement of a mortgage, deed of trust, or other security interest; or operation of law following borrower default;   Purchase from Another Large Institutional Investor Purchased from another large institutional investor that either owned the single-family home on the date of enactment of the Housing Act or purchased the single-family home in compliance with Section 1001;   Purchase from Investor Not a Large Institutional Investor Purchased from an investor not covered under Section 1001, so long as the purchase occurred not more than two years after the Effective Date;   Newly Constructed Single-Family Home in Senior Community Newly constructed, renovated, or a rental conversion that is intended and operated for occupancy as part of a community for households with one or more members aged 55 years or older, and satisfies visitability standards established by the HUD Secretary; or   Combination of Foregoing Purchases Purchased through a single purchase or combination or series of purchases described in the foregoing bullet points.   Large Institutional Investor:  The term “large institutional investor” means an investment fund, corporation, general or limited partnership, limited liability company, joint venture, association, or other for-profit entity that is a legal entity structured in a manner that is not aforementioned that –  is engaged, in whole or in part, in the business of investing in, owning, renting, managing, or holding single-family homes; and alone or in concert with one or more other entities, beginning after the date of enactment of the Housing Act, directly or indirectly has investment control of not less than 350 single-family homes in the aggregate, not including any single-family home purchased in an excepted purchase made after the date of enactment of the Housing Act.   A large institutional investor does not include any local, State, Tribal, or Federal government entity or instrumentality thereof. For purposes of the definition of “large institutional investor”, an entity has direct or indirect investment control over a single-family home if the entity –  owns, or has primary authority or fiduciary responsibility to make material investment or management decisions relating to, the single-family home; is, or directly or indirectly controls, the general partner or managing member of the entity that owns the single-family home; is or controls the investment manager, management company, or investment advisor of the entity that owns the single-family home; owns or controls more than 25% of any class of equity interests of the entity that owns the single-family home, unless such entity is a passive investor; or otherwise controls the entity that owns the single-family home.   Purchase:  The term “purchase” includes any purchase, transfer, or other acquisition of a single-family home, including through mergers, acquisitions, construction, foreclosures, or bulk purchases, whether or not for cash consideration.   Single-Family Home:  The term “single-family home” means a structure that contains two or fewer dwelling units that are each intended for residential occupancy by a single household.  The term “single-family home” does not include a manufactured home, as defined in section 603 of the National Manufactured Housing Construction and Safety Standards Act of 1974 (42 U.S.C. 5402).
Breaking: FinCEN Removes BOI Reporting Requirements for U.S. Companies and U.S. Persons
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced, on March 21, 2025, that it issued an interim final rule that removes the requirements for U.S. companies and U.S. persons to report beneficial ownership information (BOI) under the Corporate Transparency Act (CTA). The interim final rule narrows the existing BOI reporting requirements by revising the definition of “reporting company” (i.e., companies required to file BOI reports) to include only “foreign reporting companies” (i.e., companies formed outside of a US state or tribal territory but that are registered to do business in the United States). As a result, domestic reporting companies (i.e., companies formed in a US state or tribal territory) are now exempted from the BOI reporting requirements pursuant to the CTA. The rule also provides foreign reporting companies with exemptions from reporting any U.S. persons who are beneficial owners of the foreign reporting company. Foreign reporting companies that are registered to do business in the United States must file BOI reports with FinCEN within 30 days from the date of the rule’s publication in the Federal Register on March 26, 2025. If foreign reporting companies are registered to do business in the United States on or after the date of publication, they must submit BOI reports within 30 days after receiving notice of the effectiveness of their registration. Please see our prior CTA-related client alerts here and here for additional information about the filing requirements and the applicable exceptions, and do not hesitate to reach out to your contacts at Sullivan if you have any questions about CTA compliance or BOI report filing requirements.
Sullivan & Worcester Ranked in Chambers USA 2026 Edition
Boston, MA – Sullivan & Worcester announced that its practice groups and attorneys have been highly ranked by Chambers USA in its annual rankings of the foremost law firms and attorneys in the country. In the 2026 guide, the firm is newly ranked in Banking & Finance in Massachusetts and partner Will Hanson is newly ranked in Private Equity: Fund Formation in Massachusetts. Partner Ameek Ashok Ponda retained a Band 1 nationwide ranking for REITs: Tax and a Band 1 ranking in Massachusetts for Tax. Partner Cameron Cosby retained a Band 1 nationwide ranking for REITs: Tax. Partners Amy Sheridan and David Guadagnoli retained Band 1 rankings in Massachusetts for Employee Benefits & Executive Compensation. Partner Stephanie Monaco retained a Band 1 ranking nationwide in Investment Funds: Regulatory & Compliance. The Chambers USA guide ranks firms and attorneys annually based on in-depth research, as well as client and peer interviews. Chambers evaluates attorneys based on their legal knowledge and experience, ability and effectiveness, and client service. Sullivan Practice Group Nationwide Rankings Registered Funds REITs Sullivan Practice Group Regional Rankings Banking & Finance (Massachusetts) Bankruptcy/Restructuring (Massachusetts) Employee Benefits & Executive Compensation (Massachusetts) Litigation: General Commercial (Massachusetts) Real Estate (Massachusetts) Tax (Massachusetts) Individual Rankings/Client Comments Ashley Brooks – Real Estate (Massachusetts). “Ashley Brooks has a burgeoning Boston-based real estate practice. She routinely assists with matters pertaining to acquisitions and developments. She often works on mixed-use residential and retail projects.” "Ashley has done an excellent job of building Sullivan & Worcester's practice as well as her own reputation and quality of work." Cameron Cosby – REITs: Tax (Nationwide). “Cameron Cosby is commended for his strength across the REIT tax space, with notable experience of formations, M&A and debt and equity offerings.” "He is one of the most well-respected REIT tax lawyers. Cam's decades of experience advising REITs in all asset classes makes him unique among REIT tax lawyers. He is able to navigate complex and contentious transactions with no drama." David Guadagnoli – Employee Benefits & Executive Compensation (Massachusetts). “David Guadagnoli is an accomplished employee benefits practitioner, with notable expertise on the tax aspects of retirement plans and welfare benefits. He is also known for negotiating employment and severance agreements.” "His knowledge and ability to communicate that knowledge is the best I have come across during my years." Will Hanson – Private Equity: Fund Formation. “William Hanson of Sullivan & Worcester advises both sponsors and investors on the formation of private equity funds targeting a wide range of sectors, with a particular focus on the food and beverage industry." Will Hanson is knowledgeable, efficient and listens patiently when we discuss issues. He ensures that what we need is appropriate to our business plan." Richard Jones – Tax (Massachusetts). “Richard Jones provides transactional advice and litigation counsel to his clients across a broad range of sectors. He is noted for his expertise in relation to state and local tax matters.” David Leahy – Registered Funds (Nationwide). “David Leahy is valued for his astute advice to independent trustees and directors of mutual funds, closed-end funds and ETFs.” "David is always knowledgeable, with a plethora of experience." David Mahaffey – Registered Funds (Nationwide). “David Mahaffey is best known for his high-level representation of independent trustees for ETFs and open- and closed-end funds.” "David is an industry exemplar with his breadth of experience and in-depth industry knowledge. He is very much a problem solver with a can-do attitude." Stephanie Monaco – Investment Funds: Regulatory and Compliance (Nationwide). “Stephanie Monaco of Sullivan & Worcester frequently advises both private and registered fund clients on SEC and ’40 Act compliance. She brings experience of working in the hedge funds sector to her private practice.” Louis Monti – REITs (Nationwide). “Louis Monti represents REIT clients in NYSE and NASDAQ-related matters. His work often includes a broad range of tax, corporate and wider finance matters.” Ameek Ashok Ponda – Tax (Massachusetts) and REITs: Tax (Nationwide). “Ameek Ashok Ponda's global transactional REIT practice regularly sees him handling REIT conversions as well as M&A.” "Ameek is a great leader in the industry and helps provide detailed advice – highly trusted." Domenick Pugliese – Registered Funds (Nationwide). “Domenick Pugliese's broad capabilities enable him to handle ETFs and mutual funds matters, with particular expertise in advising independent trustees.” Nicole Rives – Private Equity, Fund Formation (Massachusetts). “Nicole Rives of Sullivan & Worcester has a broad-based private equity practice that sees her acting on behalf of both sponsors and institutional investors.” Gregory Sampson – Real Estate: Zoning/Land Use (Massachusetts). “Gregory Sampson has experience across a range of real estate matters including permitting, developments, entitlements and loans.” "Greg Sampson is super smart. He continues to do wonderful things in land use development." Amy Sheridan – Employee Benefits & Executive Compensation (Massachusetts). “Amy Sheridan has a broad practice and regularly advises on tax compliance, as well as assisting with transactional matters. She is also well-versed in deferred compensation plans.” "Amy is exceptional in all facets of ERISA. I trust her technical skills and professionalism." Douglas Stransky – Tax (Massachusetts). “Douglas Stransky has experience advising on complex domestic and international tax planning for clients across finance, life sciences and other sectors. He leads Sullivan's international tax practice group.” "Doug's deep knowledge of the law is matched by a sharp strategic mindset and exceptional attention to detail." Sarah Wellings – REITs: Tax (Nationwide). “Sarah Wellings is an up-and-coming practitioner at Sullivan & Worcester who is highly regarded for her REIT tax practice. Sarah is active acting as tax counsel in REIT compliance matters.” "Sarah is detail-oriented, proactive and a true partner. She is excellent and patient with educating clients regarding matters." Amy Zuccarello – Bankruptcy/Restructuring (Massachusetts). “Amy Zuccarello focuses her practice on the area of corporate trust. She often serves as counsel to creditors and debtors in Chapter 11 bankruptcies and out-of-court restructurings.” "Amy is always timely, conscientious and practical." Practices/Client Comments Banking & Finance – "The team provided creative advice in complex situations." Bankruptcy/Restructuring – "Sullivan & Worcester have a breadth of knowledge and the ability to provide necessary advice." Employee Benefits & Executive Compensation – "Sullivan & Worcester's attorneys have tremendous knowledge and the ability to share that knowledge in a clear, concise manner that assures understanding." Litigation: General Commercial – "Sullivan & Worcester is exceptional when it comes to complex litigation." Real Estate – "Sullivan's local knowledge, general expertise and good people distinguishes it." Registered Funds – "Sullivan & Worcester's team is very experienced and well-versed in a variety of topics." REITs – "Sullivan & Worcester are always available, proactive and extremely thorough. They provide practical advice, quickly analyzing changes to deal structure and recalling minute details along the way." Tax – "Sullivan & Worcester resolve issues efficiently and shows commitment to client satisfaction." About Sullivan Sullivan & Worcester (Sullivan) is a premier international law firm with lawyers in Boston, London, New York, Tel Aviv and Washington, D.C. Sullivan’s clients, including Fortune 500 companies, leading financial services firms and asset managers, boards of directors, real estate companies, and emerging businesses, rely on Sullivan’s ability to navigate complex legal and operational landscapes, the impeccable judgment of its lawyers, and its commitment to best-in-class client service.
Sullivan Attorneys Selected to 2026 Massachusetts Super Lawyers and Rising Stars Lists
Super Lawyers has selected 15 attorneys from Sullivan's Boston office to its 2026 Massachusetts Super Lawyers and Rising Stars lists. Attorneys are recognized for excellence in the practice of law, rated by a high degree of peer recognition and professional achievement. The recipients of this designation will be featured in Massachusetts Super Lawyers magazine and in The Boston Globe in October. The following Sullivan attorneys have been named to the 2026 Massachusetts Super Lawyers list: Patrick Dinardo - Business Litigation Richard Jones - Tax David Nagle - Tax Ameek Ashok Ponda - Tax Douglas Stransky - Tax Amy Zuccarello - Bankruptcy: Business The following Sullivan attorneys have been named to 2026 Massachusetts Rising Stars list: Matthew Bailey - Real Estate Emily Brewer - Real Estate Steven Cunningham - Estate Planning & Probate William Hanson - Business/Corporate Eric Rietveld - Tax Ryan Rosenblatt - Civil Litigation: Defense Brandon Schneider - Real Estate Ashley Tan - Real Estate Ryan Tompkins - Estate Planning & Probate

William C. Hanson

Will focuses his practice on representing institutional investors in private equity investments, with a concentration in secondaries, LP investments, equity co-investments and private investment fund formation. Will leads the firm’s secondaries group. He also regularly represents financial institutions in secured and unsecured financing transactions. Will has broad experience in advising investment managers in alternative asset classes, with a particular emphasis on timberland and agricultural investing.

Viewpoints
All Viewpoints
Impact of 21st Century ROAD to Housing Act on Institutional Investor Ownership of Single-Family Rental Homes
The U.S. Congress passed the 21st Century ROAD to Housing Act (the “Housing Act”) and presented it to President Trump on June 29, 2026. At midnight on July 10, 2026, the Housing Act became law because the President did not return it to Congress within ten days (Sundays excepted). The Housing Act includes a wide range of housing reforms designed with the goal of making housing more available and affordable.  This alert focuses on the impact of the Housing Act on institutional investor ownership of single-family rental homes.  The Housing Act does not prohibit institutional investor ownership of manufactured homes. The section of the Housing Act impacting institutional investor ownership of single-family rental homes is Section 1001 (the Section is titled “Homes Are for People, Not Corporations”).  The primary impacts under Section 1001 are (i) a prohibition on purchases of single-family homes (with important exceptions) and (ii) the creation of a “Renter Outreach Resource” managed by the federal government.  Section 1001 uses a number of defined terms, which are summarized in Appendix A to this alert.  The defined terms are indicated in this alert in italics.  The most important – and most extensive – defined term is excepted purchase, which includes, among other programs, purchases of single-family homes pursuant to build-to-rent programs and purchases of single-family homes from other large institutional investors. No Requirement to Dispose When the U.S. Senate passed a version of the Housing Act in March 2026, the legislation included a controversial, perhaps even unconstitutional, provision requiring institutional investors to dispose of certain single-family homes not later than seven years after the date of purchase.  A relief to such institutional investors, the Housing Act, as enacted, does not include that requirement to dispose. Prohibition on Purchases (with Several Exceptions) The Housing Act prohibits the purchase of single-family homes by large institutional investors, excluding any excepted purchase or any purchase of a single-family home in connection with a restructuring or other reorganization of ownership of single-family homes that were owned or purchased on or before the date of enactment of the Housing Act.  The prohibition on purchases takes effect on January 7, 2027 (180 days after the date of enactment of the Housing Act) (the “Effective Date”) and is repealed on January 7, 2042 (15 years after the Effective Date). Excepted purchases (i.e., those not prohibited) are described in detail in Appendix A under the defined term “Excepted Purchase”, but generally include many of the common methods by which institutional investors in single-family rental homes acquire such homes, including but not limited to: (i) build‑to‑rent programs, (ii) renovate‑to‑rent programs, (iii) repossessions, (iv) foreclosures, (v) purchases from another large institutional investor, or (vi) combinations of (i) through (v). Enforcement of Prohibition on Purchases The Secretary of the Treasury, or the Attorney General at the request of the Secretary of the Treasury, may bring an action against a large institutional investor that violates the prohibition on purchases for a civil penalty in an amount that is not more than $1,000,000 per violation, or three times the purchase price of the property involved, whichever is greater. Renter Outreach Resource As described in detail below, the Renter Outreach Resource is a comprehensive program that includes direct reporting of rental disputes by renters to Federal agencies, with investigation and reporting requirements imposed on applicable Federal agencies, and (at a minimum) provision of applicable state agency contact information to renters to facilitate state-level investigation.  In addition, large institutional investors must respond to information requests in connection with any investigation and are required to regularly provide certain information regarding the Renter Outreach Resource to their renters. Establishment of Renter Outreach Resource The Secretary of Housing and Urban Development (the “HUD Secretary”) is required, not later than 180 days after the date of enactment of the Housing Act, to establish the Renter Outreach Resource that consists of a toll-free telephone number and a public website designed to assist renters of residential properties owned by a large institutional investor in –  notifying Federal agencies about disputes relating to the rental of such properties, including disputes about potential violations of Federal law; sharing information about such disputes with other Federal agencies, including other Federal agencies that manage similar disputes; monitoring such disputes; and resolving such disputes, to the extent practicable.   Response to Outreach The HUD Secretary is required to establish reasonable procedures to promptly respond, in writing where appropriate, to a renter who provides information to the HUD Secretary about a dispute using the Renter Outreach Resource and document such responses.  Such responses are required to include, where appropriate, information about –  steps that have been taken by the HUD Secretary or another Federal agency in response to the information about the dispute provided by the renter, including determining the appropriate large institutional investor involved as described in the bullet below “Investigation of Potential Violations of Federal Law;” any responses received by the HUD Secretary or another Federal agency from the large institutional investor related to such dispute; and any outcome of the dispute, to the extent practicable.   Investigation of Potential Violations of Federal Law The HUD Secretary is required to promptly process and investigate any information relating to a dispute received through the Renter Outreach Resource about a potential violation of Federal law that is received from a renter of a residential property owned by a large institutional investor through the Renter Outreach Resource, including –  requesting information from a large institutional investor; determining the appropriate large institutional investor involved in the dispute; and sharing information about such potential violation of Federal law with any relevant Federal agencies, as the HUD Secretary may determine appropriate.   Upon request for information made pursuant to the Renter Outreach Resource, the HUD Secretary is required to provide a large institutional investor the opportunity to respond, including regarding whether such large institutional investor currently owns the property described in such request for information.   Information for Appropriate State Authority When the HUD Secretary receives information about a potential violation of State law or about a dispute received through the Renter Outreach Resource, from a renter of a residential property owned by a large institutional investor through the Renter Outreach Resource, the HUD Secretary is required, at a minimum, to provide the renter with contact information for the appropriate, State-specific, State authority authorized to process and investigate such information.   Notice About Renter Outreach Resource Each large institutional investor is required to –  provide to each renter of a residential property owned by such investor at the time such renter first occupies such home and annually thereafter –  written notice about the Renter Outreach Resource; and the name, phone number, and email address of the person or entity responsible for receiving and addressing renter disputes for the large institutional investor, and update the name, phone number, and email address within 30 days if such information changes prior to the subsequent time at which such notice is required to be provided; and   prominently feature information about the Renter Outreach Resource on a public website of such investor that is accessible by such renter.   Annual Notification Not later than 180 days after the date of enactment of the Housing Act, and not later than December 31st of each year thereafter, each person or entity that satisfies the definition of a large institutional investor is required to –  notify the HUD Secretary each year whether such owner is a large institutional investor; and in such notification, identify how many single-family homes such large institutional investor has direct or indirect investment control of as of the date of the submission of such notice, and the city and State where each such single-family home is located, unless such large institutional investor owns ten or fewer single-family homes in such city. Studies on Large Institutional Investors Not later than two years after the Effective Date, and again not later than ten years after the Effective Date, a GAO report and a HUD report are required to be submitted to the House Banking Committee and the Senate Committee on Financial Services. *     *     * Contacts Tax Cameron N. Cosby Carson Durdel Connie Lee Ameek Ashok Ponda Sarah D. Wellings Private Funds William C. Hanson Real Estate Karen J. Kepler Louis A. Monti John M. Steiner Appendix A Defined Terms in Section 1001 of the Housing Act Consumer Reporting Agency:  The term “consumer reporting agency” has the meaning given the term in section 603 of the Fair Credit Reporting Act (15 U.S.C. 1681a)). Excepted Purchase:  The term “excepted purchase” means any purchase of a single-family home that is –  Newly Constructed, For Sale Home Newly constructed, renovated, or a rental conversion for sale by a large institutional investor and not as a residence rented pending sale;   Build-to-Rent Program Pursuant to a build-to-rent program where the large institutional investor purchases newly constructed single-family homes to be managed as rental properties, whether as communities exclusively of renter-occupied single-family homes or as communities of single-family homes that are both owner- and renter-occupied;   Renovate-to-Rent Program Pursuant to a renovate-to-rent program that –  substantially rehabilitates single-family homes that do not meet structural or core system elements of local building codes; and makes improvements in an aggregate dollar amount of not less than 15% of the purchase price of the single-family home;   Homeownership Program Pursuant to a homeownership program that –  requires rental payments and any other fees that are not greater than those collected by the large institutional investor on other similarly situated single-family homes not covered by the eligible homeownership program; is subject to a contract between the large institutional investor and renter that shall be considered a consumer credit transaction secured by a dwelling or real property; provides for positive reporting of rental payments to consumer reporting agencies for any renter, who shall be informed of and opts into such reporting; and requires contribution of meaningful financial support from the large institutional investor, including price concessions, for the purchase of the single-family home by the renter;   Program to Boost Homeownership Pursuant to a program to boost homeownership that –  provides for positive reporting of rental payments to consumer reporting agencies for any renter who is informed of and opts into such reporting; provides for the right of first refusal and a 30-day ‘‘first look’’ period; and may entail the meaningful financial support from the large institutional investor, including price concessions, for the purchase of a single-family home by the renter (whether it is the home the renter occupies or another home);   Repossession In connection with the satisfaction of debts previously contracted in good faith and where the large institutional investor has the right to repossess the single-family home under such contract;   Foreclosure Undertaken by a mortgage servicer, lender, or other entity that has a legal right to a single-family home, for the purpose of loss mitigation or compliance with servicing or investor obligations, and not as a long-term investment strategy, and is solely as a result of –  a foreclosure; a deed-in-lieu of foreclosure; enforcement of a mortgage, deed of trust, or other security interest; or operation of law following borrower default;   Purchase from Another Large Institutional Investor Purchased from another large institutional investor that either owned the single-family home on the date of enactment of the Housing Act or purchased the single-family home in compliance with Section 1001;   Purchase from Investor Not a Large Institutional Investor Purchased from an investor not covered under Section 1001, so long as the purchase occurred not more than two years after the Effective Date;   Newly Constructed Single-Family Home in Senior Community Newly constructed, renovated, or a rental conversion that is intended and operated for occupancy as part of a community for households with one or more members aged 55 years or older, and satisfies visitability standards established by the HUD Secretary; or   Combination of Foregoing Purchases Purchased through a single purchase or combination or series of purchases described in the foregoing bullet points.   Large Institutional Investor:  The term “large institutional investor” means an investment fund, corporation, general or limited partnership, limited liability company, joint venture, association, or other for-profit entity that is a legal entity structured in a manner that is not aforementioned that –  is engaged, in whole or in part, in the business of investing in, owning, renting, managing, or holding single-family homes; and alone or in concert with one or more other entities, beginning after the date of enactment of the Housing Act, directly or indirectly has investment control of not less than 350 single-family homes in the aggregate, not including any single-family home purchased in an excepted purchase made after the date of enactment of the Housing Act.   A large institutional investor does not include any local, State, Tribal, or Federal government entity or instrumentality thereof. For purposes of the definition of “large institutional investor”, an entity has direct or indirect investment control over a single-family home if the entity –  owns, or has primary authority or fiduciary responsibility to make material investment or management decisions relating to, the single-family home; is, or directly or indirectly controls, the general partner or managing member of the entity that owns the single-family home; is or controls the investment manager, management company, or investment advisor of the entity that owns the single-family home; owns or controls more than 25% of any class of equity interests of the entity that owns the single-family home, unless such entity is a passive investor; or otherwise controls the entity that owns the single-family home.   Purchase:  The term “purchase” includes any purchase, transfer, or other acquisition of a single-family home, including through mergers, acquisitions, construction, foreclosures, or bulk purchases, whether or not for cash consideration.   Single-Family Home:  The term “single-family home” means a structure that contains two or fewer dwelling units that are each intended for residential occupancy by a single household.  The term “single-family home” does not include a manufactured home, as defined in section 603 of the National Manufactured Housing Construction and Safety Standards Act of 1974 (42 U.S.C. 5402).
Breaking: FinCEN Removes BOI Reporting Requirements for U.S. Companies and U.S. Persons
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced, on March 21, 2025, that it issued an interim final rule that removes the requirements for U.S. companies and U.S. persons to report beneficial ownership information (BOI) under the Corporate Transparency Act (CTA). The interim final rule narrows the existing BOI reporting requirements by revising the definition of “reporting company” (i.e., companies required to file BOI reports) to include only “foreign reporting companies” (i.e., companies formed outside of a US state or tribal territory but that are registered to do business in the United States). As a result, domestic reporting companies (i.e., companies formed in a US state or tribal territory) are now exempted from the BOI reporting requirements pursuant to the CTA. The rule also provides foreign reporting companies with exemptions from reporting any U.S. persons who are beneficial owners of the foreign reporting company. Foreign reporting companies that are registered to do business in the United States must file BOI reports with FinCEN within 30 days from the date of the rule’s publication in the Federal Register on March 26, 2025. If foreign reporting companies are registered to do business in the United States on or after the date of publication, they must submit BOI reports within 30 days after receiving notice of the effectiveness of their registration. Please see our prior CTA-related client alerts here and here for additional information about the filing requirements and the applicable exceptions, and do not hesitate to reach out to your contacts at Sullivan if you have any questions about CTA compliance or BOI report filing requirements.
Sullivan & Worcester Ranked in Chambers USA 2026 Edition
Boston, MA – Sullivan & Worcester announced that its practice groups and attorneys have been highly ranked by Chambers USA in its annual rankings of the foremost law firms and attorneys in the country. In the 2026 guide, the firm is newly ranked in Banking & Finance in Massachusetts and partner Will Hanson is newly ranked in Private Equity: Fund Formation in Massachusetts. Partner Ameek Ashok Ponda retained a Band 1 nationwide ranking for REITs: Tax and a Band 1 ranking in Massachusetts for Tax. Partner Cameron Cosby retained a Band 1 nationwide ranking for REITs: Tax. Partners Amy Sheridan and David Guadagnoli retained Band 1 rankings in Massachusetts for Employee Benefits & Executive Compensation. Partner Stephanie Monaco retained a Band 1 ranking nationwide in Investment Funds: Regulatory & Compliance. The Chambers USA guide ranks firms and attorneys annually based on in-depth research, as well as client and peer interviews. Chambers evaluates attorneys based on their legal knowledge and experience, ability and effectiveness, and client service. Sullivan Practice Group Nationwide Rankings Registered Funds REITs Sullivan Practice Group Regional Rankings Banking & Finance (Massachusetts) Bankruptcy/Restructuring (Massachusetts) Employee Benefits & Executive Compensation (Massachusetts) Litigation: General Commercial (Massachusetts) Real Estate (Massachusetts) Tax (Massachusetts) Individual Rankings/Client Comments Ashley Brooks – Real Estate (Massachusetts). “Ashley Brooks has a burgeoning Boston-based real estate practice. She routinely assists with matters pertaining to acquisitions and developments. She often works on mixed-use residential and retail projects.” "Ashley has done an excellent job of building Sullivan & Worcester's practice as well as her own reputation and quality of work." Cameron Cosby – REITs: Tax (Nationwide). “Cameron Cosby is commended for his strength across the REIT tax space, with notable experience of formations, M&A and debt and equity offerings.” "He is one of the most well-respected REIT tax lawyers. Cam's decades of experience advising REITs in all asset classes makes him unique among REIT tax lawyers. He is able to navigate complex and contentious transactions with no drama." David Guadagnoli – Employee Benefits & Executive Compensation (Massachusetts). “David Guadagnoli is an accomplished employee benefits practitioner, with notable expertise on the tax aspects of retirement plans and welfare benefits. He is also known for negotiating employment and severance agreements.” "His knowledge and ability to communicate that knowledge is the best I have come across during my years." Will Hanson – Private Equity: Fund Formation. “William Hanson of Sullivan & Worcester advises both sponsors and investors on the formation of private equity funds targeting a wide range of sectors, with a particular focus on the food and beverage industry." Will Hanson is knowledgeable, efficient and listens patiently when we discuss issues. He ensures that what we need is appropriate to our business plan." Richard Jones – Tax (Massachusetts). “Richard Jones provides transactional advice and litigation counsel to his clients across a broad range of sectors. He is noted for his expertise in relation to state and local tax matters.” David Leahy – Registered Funds (Nationwide). “David Leahy is valued for his astute advice to independent trustees and directors of mutual funds, closed-end funds and ETFs.” "David is always knowledgeable, with a plethora of experience." David Mahaffey – Registered Funds (Nationwide). “David Mahaffey is best known for his high-level representation of independent trustees for ETFs and open- and closed-end funds.” "David is an industry exemplar with his breadth of experience and in-depth industry knowledge. He is very much a problem solver with a can-do attitude." Stephanie Monaco – Investment Funds: Regulatory and Compliance (Nationwide). “Stephanie Monaco of Sullivan & Worcester frequently advises both private and registered fund clients on SEC and ’40 Act compliance. She brings experience of working in the hedge funds sector to her private practice.” Louis Monti – REITs (Nationwide). “Louis Monti represents REIT clients in NYSE and NASDAQ-related matters. His work often includes a broad range of tax, corporate and wider finance matters.” Ameek Ashok Ponda – Tax (Massachusetts) and REITs: Tax (Nationwide). “Ameek Ashok Ponda's global transactional REIT practice regularly sees him handling REIT conversions as well as M&A.” "Ameek is a great leader in the industry and helps provide detailed advice – highly trusted." Domenick Pugliese – Registered Funds (Nationwide). “Domenick Pugliese's broad capabilities enable him to handle ETFs and mutual funds matters, with particular expertise in advising independent trustees.” Nicole Rives – Private Equity, Fund Formation (Massachusetts). “Nicole Rives of Sullivan & Worcester has a broad-based private equity practice that sees her acting on behalf of both sponsors and institutional investors.” Gregory Sampson – Real Estate: Zoning/Land Use (Massachusetts). “Gregory Sampson has experience across a range of real estate matters including permitting, developments, entitlements and loans.” "Greg Sampson is super smart. He continues to do wonderful things in land use development." Amy Sheridan – Employee Benefits & Executive Compensation (Massachusetts). “Amy Sheridan has a broad practice and regularly advises on tax compliance, as well as assisting with transactional matters. She is also well-versed in deferred compensation plans.” "Amy is exceptional in all facets of ERISA. I trust her technical skills and professionalism." Douglas Stransky – Tax (Massachusetts). “Douglas Stransky has experience advising on complex domestic and international tax planning for clients across finance, life sciences and other sectors. He leads Sullivan's international tax practice group.” "Doug's deep knowledge of the law is matched by a sharp strategic mindset and exceptional attention to detail." Sarah Wellings – REITs: Tax (Nationwide). “Sarah Wellings is an up-and-coming practitioner at Sullivan & Worcester who is highly regarded for her REIT tax practice. Sarah is active acting as tax counsel in REIT compliance matters.” "Sarah is detail-oriented, proactive and a true partner. She is excellent and patient with educating clients regarding matters." Amy Zuccarello – Bankruptcy/Restructuring (Massachusetts). “Amy Zuccarello focuses her practice on the area of corporate trust. She often serves as counsel to creditors and debtors in Chapter 11 bankruptcies and out-of-court restructurings.” "Amy is always timely, conscientious and practical." Practices/Client Comments Banking & Finance – "The team provided creative advice in complex situations." Bankruptcy/Restructuring – "Sullivan & Worcester have a breadth of knowledge and the ability to provide necessary advice." Employee Benefits & Executive Compensation – "Sullivan & Worcester's attorneys have tremendous knowledge and the ability to share that knowledge in a clear, concise manner that assures understanding." Litigation: General Commercial – "Sullivan & Worcester is exceptional when it comes to complex litigation." Real Estate – "Sullivan's local knowledge, general expertise and good people distinguishes it." Registered Funds – "Sullivan & Worcester's team is very experienced and well-versed in a variety of topics." REITs – "Sullivan & Worcester are always available, proactive and extremely thorough. They provide practical advice, quickly analyzing changes to deal structure and recalling minute details along the way." Tax – "Sullivan & Worcester resolve issues efficiently and shows commitment to client satisfaction." About Sullivan Sullivan & Worcester (Sullivan) is a premier international law firm with lawyers in Boston, London, New York, Tel Aviv and Washington, D.C. Sullivan’s clients, including Fortune 500 companies, leading financial services firms and asset managers, boards of directors, real estate companies, and emerging businesses, rely on Sullivan’s ability to navigate complex legal and operational landscapes, the impeccable judgment of its lawyers, and its commitment to best-in-class client service.
Sullivan Attorneys Selected to 2026 Massachusetts Super Lawyers and Rising Stars Lists
Super Lawyers has selected 15 attorneys from Sullivan's Boston office to its 2026 Massachusetts Super Lawyers and Rising Stars lists. Attorneys are recognized for excellence in the practice of law, rated by a high degree of peer recognition and professional achievement. The recipients of this designation will be featured in Massachusetts Super Lawyers magazine and in The Boston Globe in October. The following Sullivan attorneys have been named to the 2026 Massachusetts Super Lawyers list: Patrick Dinardo - Business Litigation Richard Jones - Tax David Nagle - Tax Ameek Ashok Ponda - Tax Douglas Stransky - Tax Amy Zuccarello - Bankruptcy: Business The following Sullivan attorneys have been named to 2026 Massachusetts Rising Stars list: Matthew Bailey - Real Estate Emily Brewer - Real Estate Steven Cunningham - Estate Planning & Probate William Hanson - Business/Corporate Eric Rietveld - Tax Ryan Rosenblatt - Civil Litigation: Defense Brandon Schneider - Real Estate Ashley Tan - Real Estate Ryan Tompkins - Estate Planning & Probate