TOPA Didn’t Disappear — “Notice of Transfer” Replaced the Offer of Sale

RENTAL Amendment Act of 2025, enacted November 13, 2025. It amends TOPA, it does not repeal it.

For DC 2–4 unit properties, the RENTAL Act of 2025 fundamentally changes who is covered, when TOPA applies, and which transfers no longer trigger a traditional Offer of Sale

Think “TOPA Exempt” means an easy sale? Think again.
This session explains the new Notice of Transfer requirements, the rent registry gatekeeping issues, and the statutory notice and review periods that now affect how exempt 2–4 unit transfers are underwritten and closed in 2026.

⚠️ WARNING: “Exempt” Does Not Mean “Do Nothing”

If you own a duplex, triplex, or fourplex in Washington, DC, you’ve likely heard the headline:

“TOPA is basically gone under the RENTAL Act of 2025”

That headline is incomplete — and relying on it increases the risk of delay or title complications under the RENTAL Act’s new transfer framework.

Here is what the law actually did:

The RENTAL Act did not eliminate compliance — it replaced the process. For many 2–4 unit properties, the law moved owners from the traditional “Offer of Sale and Negotiation” model to a mandatory “Notice of Transfer” workflow, even where TOPA purchase rights no longer apply. If you skip a step, rely on outdated forms, or assume silence is sufficient, Section 403a(f) of the Act creates a rebuttable presumption.

Most owners — and many agents — are walking into this blind.

This seminar explains, with statutory context, how the RENTAL Act of 2025 actually affects small multifamily owners:

• For 2–4 unit properties, whether TOPA applies now depends heavily on how the property is owned, including whether it is held by a business corporation B26-0164-Signed_Act.
• Unit count alone is no longer the full analysis.

• Many exempt transfers no longer begin with an Offer of Sale.
• Instead, the Act requires a Notice of Transfer to tenants and the District in specific circumstances — even when no purchase right exists B26-0164-Signed_Act.
• Using the wrong document can create delay, confusion, or litigation exposure.

• While traditional TOPA timelines may not apply, statutory notice and challenge periods still exist.

• Certain filings and certifications under the Act are tied to DHCD registration status B26-0164-Signed_Act.
• Owners who are not properly registered may find themselves unable to proceed cleanly until compliance issues are resolved.

• Title insurers are no longer relying on assumptions or verbal exemptions.
• Expect requests for: Entity ownership clarification, Statutory exemption support, and Evidence of proper notice or filing
• This session explains what underwriters are actually looking for.

• Owners of DC duplexes, triplexes, and fourplexes
• Multiunit Landlords planning a 2026 sale or refinance
• Multiunit Owners holding property in LLCs or entities
• Anyone who wants a clean closing, not a surprise delay
  

• A 2026 Exempt Transfer & Closing Checklist (PDF)
• Clear understanding of when TOPA applies — and when it doesn’t
• The correct Notice of Transfer workflow

The law changed quietly. The paperwork changed significantly. The risk didn’t disappear — it moved into the process.

If you plan to sell a 2–4 unit property in 2026, understanding this shift before you list can protect your timeline, your buyer, and your equity.

Register now to close with confidence.

About Abel

Abel brings over a decade of extensive experience in the Washington, DC, multifamily market. His expertise has made him a trusted advisor to property owners, sellers, and investors navigating the complexities of real estate transactions in the area.Over the course of his career, Abel has successfully assisted more than 114 multifamily sellers and investors, demonstrating his deep understanding of the unique challenges and opportunities in this sector. He has executed over 390+ TOPA notices and assignments with a TOPA success rate of over 90%, ensuring seamless compliance with the DC Tenant Opportunity to Purchase Act (TOPA) while safeguarding his clients' interests.In addition, Abel has facilitated multiple cash-for-key negotiations between landlords and tenants, skillfully balancing the needs of both parties to achieve amicable solutions. His negotiation skills, market knowledge, and client-first approach have earned him a reputation as a go-to expert in the multifamily space.

Whether navigating complex tenant arrangements, positioning properties for maximum value, or guiding investors through the DC real estate landscape, his dedication and results-driven approach set him apart, he is committed to delivering tailored strategies and exceptional outcomes for every client he serves.

Home Types: Townhouse, MultiFamily, House, Condo, Commercial, Lot/Land

Languages Spoken: English, Russian

Years of Experience: 10

Education: Voronezh State University- Voronezh Russian: Associate in International Law

@dcmultifamilyexpert

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