When you build a multiplex in Vancouver, you may plan to live in one home and sell the others, sometimes before the building is finished. In BC, that sale is covered by the Real Estate Development Marketing Act, often called REDMA, once the building reaches a certain size. This post walks you through when the Act applies to a multiplex, what a disclosure statement is, the 7-day right to cancel, how deposits are held, what changes for a presale, and how the home warranty fits in.
The rules below come from the Real Estate Development Marketing Act (current to September 22, 2026), the Real Estate Development Marketing Regulation (current to September 29, 2026) and the policy statements of BC Financial Services Authority (BCFSA), all read on October 2, 2026. They give the general rule. A disclosure statement is a legal document signed by you and, for a company, by every director. Hire a real estate lawyer before you advertise a single home.
The Act protects people who buy homes from a developer, usually before the homes exist. It says what a developer must have in place before marketing homes, what the buyer must be told, how deposits are held, and when the buyer may cancel.
The person in charge is the Superintendent of Real Estate. Since August 1, 2021, the Superintendent works within BC Financial Services Authority. BCFSA receives disclosure statements, publishes the policy statements that explain the Act, investigates complaints and can order a developer to stop marketing.
Who counts as the developer? Section 1 of the Act defines a developer as a person who owns, leases or has a right to acquire or sell development property. A homeowner who builds a strata multiplex on their own lot and sells some of the homes can be that person, and so can a partnership formed for the project.
The Act applies to "development property". Section 1 lists what that means. For a multiplex, two lines matter:
- 5 or more strata lots in a stratified building. A stratified building is a building on a strata plan, with each home on its own title.
- 2 or more shared interests in land. This is a lot owned by two or more people together, where each owner may use only part of it, such as one home.
So a strata duplex, triplex or fourplex has too few strata lots, and a 5-plex or 6-plex strata is a development property. A fourplex sold as shares of one title is a different case, because only 2 shared interests are needed. If you are thinking about selling homes as shares of one title, ask your lawyer about this before you choose the ownership set-up.
In the REW video about We Killarney, Louis Nguyen, Costar's Director of Sales, describes a multiplex as three to six units with freehold strata titles. A 5-plex or 6-plex in that range is covered by the Act. Two of the multiplexes in Costar's project gallery have 5 or more homes: Quintet Townhomes at 2240 E 40th Ave has five homes, and We Killarney Townhomes at 2333 E 54th Ave has six.
One more rule surprises families. Section 2 says the Act applies even when the developer does not intend to market one or more of the homes. If grandparents keep the ground-floor home and an adult child keeps another, a five-lot strata is still a development property for the three homes that are sold.
Part 2 of the Regulation lists situations where the marketing rules do not apply. The ones a multiplex owner may meet are these:
- Selling the whole project in one deal. Section 2 exempts a developer who markets the development property in a single transaction, for example selling all five homes to one buyer.
- Renting for 3 years or less. Section 4 exempts homes marketed only for leases of 3 years or less, counting any renewal options in the term.
- Commercial use only. Section 3 exempts property zoned and used only for industrial or commercial purposes and advertised only for those uses. A residential multiplex will not fit this one.
The other exemptions cover strata plans filed on or before February 17, 1977, subdivision lots, sales made under a Securities Act prospectus, low-cost co-operative interests and certain Tsawwassen First Nation transactions. Beyond the list, section 20 of the Act lets the Superintendent grant an exemption from all or part of the rules for a specific person, property or sale. Under section 13 of the Regulation, asking for one costs $2,250 for a property with fewer than 10 units, and BCFSA publishes the exemptions it grants.
The Act uses "market" in a wide sense. Section 1 says it means selling or leasing, offering to sell or lease, and any activity that will or is likely to lead to a sale or lease.
BCFSA's Policy Statement 1 gives examples. In the Superintendent's view, letters of intent, priority lists, reservation agreements, rights of first refusal and any similar agreement that gives a right to buy a home are all marketing. File the disclosure statement before you use any of them or take any money.
You may still tell people about your project. The same policy statement allows advertising as long as people do not get the impression that they have a right to buy a home. It recommends that every advertisement show the developer's name and address, a phone number for someone who can give out the disclosure statement once it exists, and a clear statement saying the advertisement is not an offer for sale.
Section 3 of the Act sets out what has to be in place. Here it is as it applies to a strata multiplex in Vancouver.
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Get the Building Permit. Section 5 says a strata lot can be marketed once a building permit is issued for it or the strata plan is deposited at the land title office. In Vancouver, the City issues the building permit.
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Arrange Title and Services. Sections 11 and 12 say the developer must make arrangements so that each buyer will get clear title, and so that the cost of utilities and services is paid. Any mortgage on the land must let a buyer who completes the purchase take title free of it. Your lawyer and lender handle this part.
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Prepare and File the Disclosure Statement. Section 14 says you must prepare a disclosure statement and file it with the Superintendent before marketing. The filing fee under section 13 of the Regulation is $2,250 for fewer than 10 units. BCFSA's FAQ says marketing may begin as soon as the statement is filed, before BCFSA has reviewed it.
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Give Each Buyer a Copy. Section 15 says that before signing a purchase agreement, the buyer must get a copy, have a reasonable chance to read it, and sign a written receipt. You keep that receipt for at least 3 years. You may send the copy by email only if the buyer agrees in writing.
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Keep It Up to Date. Section 16 says that when you learn a statement is wrong or out of date, you must file an amendment right away and send it to every buyer who has not yet received title. An amendment costs $1,200 to file. If the developer itself changes, a new statement is needed.
Section 10 allows earlier marketing when the developer has approval in principle from the city and the Superintendent's permission. Policy Statement 5 says when that permission is treated as given. It describes approval in principle as the city giving third reading to a bylaw that rezones the site, or an equivalent step. If your multiplex is built under existing zoning, ask your lawyer whether early marketing is available to you.
When it does apply, the conditions are strict. The estimated date for the building permit must be 12 months or less after filing. Marketing must stop after 12 months unless an amendment with the building permit details is filed. Each purchase agreement must let the buyer cancel for 7 days after receiving that amendment if the permit changes the size or layout of their home or of the development. The buyer may also cancel if the amendment has not arrived within 12 months. Until the permit is disclosed, a deposit can be no more than 10% of the price.
The Act says a disclosure statement must plainly disclose all material facts, without misrepresentation. A material fact is anything that affects, or could reasonably be expected to affect, the value, price or use of a home, plus the identity of the developer. For a strata building of 5 or more lots, BCFSA's Form 1 in Policy Statement 1 sets the order of the sections. If a section does not apply, it must say "not applicable". These are the main parts:
- The developer: who it is, its directors, and any conflicts of interest.
- General description: the building, the permitted use and any phasing.
- Strata information: unit entitlement, voting rights, common property, limited common property such as a private yard, the bylaws, parking, the interim budget, utilities, any strata management contract and insurance.
- Title and legal matters: the legal description, ownership, mortgages and other charges on title, any litigation, and environmental matters.
- Construction and warranties: an estimated date range of no more than three months for the start and the end of construction, and a description of construction and equipment warranties.
- Approvals and finances: the building permit or other approval, and the construction financing.
- Deposits and the purchase agreement: the trustee who will hold deposits, and the form of purchase agreement.
The second page must show the buyer's right to cancel in large, clear type. Section 9 of the Regulation says the statement is signed by every developer and, for a company, every director. Strata rules show up here because the owner developer has duties under the Strata Property Act too. Our post on strata life in a small multiplex covers those duties, including the interim budget and the first meeting.
Since April 1, 2025, Policy Statement 14 adds more for homes that are not yet built. The developer attaches BCFSA's Summary of Pre-sale Risks and Buyer Rights in front of the cover page. The form lists risks such as construction delays, a changed closing date, the developer cancelling the contract, and the deposit coming back without interest. The buyer initials it. The purchase agreement must be attached, and the statement must describe how the agreement can be ended, extended or assigned, and who receives interest on the deposit.
Under section 21(2) of the Act, a buyer may cancel the purchase agreement by serving written notice on the developer within 7 days after the later of two dates: the day the agreement was made, and the day the developer got the buyer's signed receipt for the disclosure statement.
Section 11 of the Regulation says how notice is served: a signed copy delivered in person or by registered mail to the developer, or to the developer's brokerage, at the address shown in the disclosure statement or the purchase agreement. Once served, section 21 says the developer must tell the deposit holder right away, and the deposit holder must promptly return the deposit.
Other rights to cancel exist too. A buyer who was entitled to a disclosure statement and never got one may cancel at any time. BCFSA's purchaser rights page lists these, along with the early marketing rights above. BCFSA says that when a buyer cancels, all deposits, including any interest earned, must be returned promptly.
Section 18 of the Act says a developer who receives a deposit must promptly place it with a brokerage, lawyer or notary public, who holds it in a trust account at a savings institution in BC. That trustee holds the money for both sides. It is released to the developer only when the conditions in section 18 are met, such as the strata plan being deposited, the approvals for occupancy in place and the buyer's title registered.
A developer who wants to use deposits to help pay for construction has one route. Section 19 requires a deposit protection contract with an insurer, and section 10 of the Regulation requires the disclosure statement to name the insurer, its business address and the date the insurance takes effect. Without that insurance, the deposits stay in trust.
For a family, this matters when you plan the money. Deposits held in trust stay there until the conditions above are met, so plan to pay for construction with your loan and your own equity, and talk to your lender early.
BCFSA's Policy Statement 14 defines a pre-sale unit as a home whose strata plan has not been deposited, or whose building or services are not yet finished. That covers most homes sold before they are built.
Buyers of presales often want the right to assign, which means selling their contract to someone else before completion. Part 2.1 of the Act says that, unless the developer bans assignments, every purchase agreement for a strata lot must include set terms: no assignment without the developer's consent, and a notice that the developer will collect information about each party to the assignment. Section 20.4 requires the developer to file that information with the Province's property transfer tax administrator. Your lawyer will add this wording to the purchase agreement.
Our post on property transfer tax and GST on a new home or multiplex unit covers what a buyer pays on the purchase itself.
The Act puts the risk on the developer and its directors. Section 17 says the Superintendent has no duty to check whether a disclosure statement is accurate. Section 22 says that if a filed statement contains a misrepresentation, every buyer is treated as having relied on it and may sue the developer, its directors and the people who signed it. Section 23 says a purchase agreement may be unenforceable against the buyer if the developer broke the marketing rules.
Section 40 sets the penalties. Under it, an offence can bring a fine of up to $1.25 million on a first conviction, and an individual can also face up to 2 years in jail. Policy Statement 1 adds that, after a hearing, the Superintendent may order an administrative penalty of up to $500,000 for a company or $250,000 for an individual. This is the reason we send every owner to a lawyer before the first advertisement.
Every new home in a multiplex must be registered for home warranty insurance before construction, unless an exemption applies. Section 22 of the Homeowner Protection Act says a person must not build a new home unless it is registered for coverage with a warranty provider. Section 30 says the City of Vancouver may issue the building permit only after the applicant shows the home is covered and will be built by a licensed residential builder. Under section 1, "residential builder" includes a developer.
This connects to the Act. The building permit is usually what allows marketing of a strata lot to begin, and the permit needs the warranty first. Form 1 then asks the developer to describe the warranties in the disclosure statement, and BCFSA's FAQ says the statement must briefly explain the home warranty. Section 22(1.1) of the Homeowner Protection Act also says a new home may not be sold while it is being built, or within 10 years of first occupancy, unless it is covered by home warranty insurance or exempt.
For strata homes, BC Housing lists the coverage limits: for each strata home, the lesser of the first owner's purchase price and $100,000, and for common property, the lesser of $100,000 per unit and $2.5 million per building. Coverage on a strata home starts at first occupancy or transfer of title, whichever comes first. Our post on the BC home warranty explains the three tiers and how to check a builder on BC Housing's registry.
A strata duplex, triplex or fourplex has fewer than 5 strata lots and falls outside the Act. The Strata Property Act gives the owner developer its own duties, such as the interim budget for each buyer and the first annual general meeting, and the home warranty rules above apply to every new home. Ask your own lawyer how to set up the sale and the deposit terms.
Decide the Number of Strata Lots Early. Four lots and five lots follow different laws, so settle the count during design.
Choose Your Ownership Set-Up With a Lawyer. Strata titles and shares of one title are counted differently under the Act.
File Before You Start a Waiting List. A priority list or reservation counts as marketing, so file the disclosure statement first.
Arrange the Warranty Before the Permit. The City needs warranty evidence before it issues the building permit, and the permit is what allows marketing to begin.
Plan the Money Without the Deposits. Deposits stay in trust unless you buy deposit protection insurance.
Keep Every Receipt. Keep each buyer's signed receipt for the disclosure statement for at least 3 years, as section 15 requires.
At Costar, a construction manager coordinates the trades, orders materials and checks the finished work against the plans. Our process page describes the project binder we hand over with manuals, warranties and trade contacts. On a multiplex that will be sold, that same paperwork supplies facts for the disclosure statement: the construction dates, the warranty details and the list of what each home includes. The Quintet project page tells buyers to check the plan they are buying against the disclosure statement, because the floor areas in the sales material and in the measurement reports differ.
In the REW video, Louis also says the goal is a home that is easy to sell and gets the owner the best value in the future. Clear paperwork from day one is part of that. If you are still deciding how many homes your lot allows, start with our guide to multiplex zoning and permits in Vancouver.
We would be glad to meet with you and your lawyer to plan the build and the sale together. Tell us about your project today.
Related on this site: Multiplex construction in Vancouver · Quintet Townhomes, a five-unit multiplex in Vancouver · Book a one-hour project consultation
