Who is considered a developer

The following information was taken from "HUD interstate land sales" website
"Who is considered a developer
A developer is an individual or a business entity that, directly or individually sell or leases, or offers to sell or lease, or advertises to sell or lease lots in a subdivision. Since offering or selling lots, rather than physically developing them, is a criteria for determining who is a developer, the following examples, in addition to the traditional developer, may meet the criteria:(1) a bank offering lots obtained through a foreclosure(2) a corporation that acquire groups of lots in an existing subdivision for resale; or (3) an indiviual who buys lots at a tax sale or an auction for resale to others"
In my opinion item (2) above is exactly what the LSPOA is doing!!!!!!!!!!!
Also a past President of the LSPOA bought lots at a tax sale see item (3)
You would think that HUD would enforce the laws on their books!!!!!!!!!!!!!