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Lucas J. Narducci
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lnarducci@polsinelli.com

 


 

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January 2013

 

An Environmental Alert:

EPA Revises Guidance on Bona Fide Prospective Purchaser Protection for Tenants Under Federal Superfund Law

 

On December 5, 2012, the United States Environmental Protection Agency (EPA) revised its enforcement guidance regarding when tenants may be treated as bona fide prospective purchasers (BFPPs). The revised guidance addresses lessees who were not previously covered by the old guidance because the owner never qualified as a BFPP and the tenant lacked "sufficient indicia of ownership" to be considered an "owner." The new guidance applies to all tenants regardless of the tenant's "indicia of ownership."

To read the full Alert, click here.

 

 

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