That is his opinion and interpretation.

Tenants heard the "good news" from the government and they made their own interpretation of them.

There are always limits and how the law is normally interpreted when it's not clear is - would a reasonable person think it's reasonable.So, would a reasonable person think it was reasonable to charge a tenant $800 for breaking a month to month agreement before a year was up? 

Protecting Tenant at Foreclosure Act was re-instated in 2018:https://www.federalreserve.gov/supervisionreg/caletters/caltr1804.htmhttps://www.nolo.com/legal-encyclopedia/protections-for-tenants-after-a-landlord-s-foreclosure.htmlhttps://nlihc.org/article/congress-permanently-authorizes-protecting-tenants-foreclosure-acthttps://www.nhlp.org/wp-content/uploads/2018/01/6-Cases-of-Note-Interpreting-the-PTFA.pdf

Two very well educated and experienced advisors disagree about how to interpret this!

By no means should this be interpreted as an anti-BRRRR post.  

At least that was my interpretation after reading a few pages of the complaint but attorneys tend to throw everything at these things hoping something will stick.  

Different people can interpretate the policy differently.

That's why I don't like arguing contract law because there is room for interpretation. 

The standard of needing to file this form...isn't at least "more likely than not" (50/50) it would be overturned, and position has a "reasonable basis"  - which is interpreted as greater than a 10% chance of success of being upheld in a challenge.  10%!!!!