pennsylvania home improvement consumer protection act statute of limitations

Political subdivisions in Pennsylvania cannot separately license or register home improvement contractors after July 1, 2009, with the limited exception of licensing standards that are in effect on July 1, 2009, with respect to electricians, plumbers and other trades where licensing is conditioned on requirements of testing or possession of certificates obtained through specific training in electricity, plumbing or other trades. You need to enable JavaScript to run this app. [21] Even if we were to conclude that all actions brought pursuant to the UTPCPL sounded in deceit or fraud, what with appellants' additional claims under UTPCPL the six-year "catchall" limitation of section 5527(6) would be applicable. Please note that this exception is limited to emergencies meeting the criteria set forth in Section 201-7 of the Unfair Trade Practices and Consumer Protection Law and the contractor must obtain the emergency waiver required by the law in each case. . We find further support for our determination in the decisions of the courts of other states which have concluded likewise. The bureau has a complaint process and will conduct an investigation, but cannot recover civil damages for you. You're all set! While the Act does not provide the Bureau of Consumer Protection with discretion to deny the issuance of a license to anyone who has paid the required S50.00 application fee and provided the required information, the Act does provide for public access to registration information (excluding Social Security number, drivers license number and other such confidential information) by a toll-free telephone number and by posting on the Bureaus internet website. 201-3 ("Unfair methods of competition and unfair or deceptive acts or practices in the conduct of any trade or commerce . 282, 286, 507 A.2d 1230, 1232 (1986) (citations omitted). As the Supreme Court of Pennsylvania has observed: [T]his Law attempts to place on more equal terms seller and consumer [and is] predicated on a legislative recognition of the unequal bargaining power of opposing forces in the marketplace. All contractors, including self-employed contractors and sole proprietorships, subcontractors and independent contractors, and corporations, partnerships and all other types of business entities must be registered, unless they fall into the two exemptions above. 374, 477 A.2d 491 (1984) (Public Adjuster Law); Pennsylvania Bankers Ass'n. The issue in this case is whether another statute of limitation under the UTPCPL is equally applicable rather than the two-year statute for fraud. Lawyers on UpCounsel come from law schools such as Harvard Law and Yale Law and average 14 years of legal experience, including work with or on behalf of companies like Google, Menlo Ventures, and Airbnb. The term home improvement is broadly defined to include most repair, replacement, remodeling, demolition, renovation, installation, alteration, conversion, modernization, improvement, rehabilitation and sandblasting work done in connection with land or a portion of land adjacent to a private residence, so long as the total cash price of all work agreed upon between the contractor and owner is more than $500.00. 717-787-3391. For a full discussion and comparison of state unfair competition statutes, see generally, Sibert, Enforcement of State Deceptive Trade Practice Statutes, 42 Tenn.L.Rev. 7 years (with 1 year extension if defect discovered in 7th year) No. The Act applies to any person who owns and operates a home improvement business or who undertakes offers or agrees to perform any home improvement, including a subcontractor who has contracted with a home improvement retailer to provide home improvement services to the retailers customers. 50-624(g); Ky.Rev.Stat. See Home Life Ins. Last Action: This bill amends the act of October 17, 2008 (P.L.1645, No.0132), known as the Home Improvement Consumer Protection Act - Enactment. 53, 1978 Pa.Laws 202, 2). Id. Specifically, under HICPA, a contractor is anyone who undertakes or agrees to perform home improvement work, including: Improvement. The Act drastically alters the regulatory environment of the home . The UTPCPL supplements rather than supplants traditional common law remedies with per se liability for a variety of unfair trade practices.[8]. 5524(7). Accord Best v. Hammill Quinlan Realty Co., Inc., 18 D. & C.3d 31 (Wash. 1980). We have worked to ensure that the registration process is as quick and easy as possible. and the Lantram Trademark Act were models for Pennsylvania's (UTPCPL)"). If the vehicle does not have advertising promoting the business, then the contractor is not required to display their registration number on the vehicle. What are the limits on down payments or deposits? Yes. . Why must a home improvement contract contain the 3-day cancellation notice? In Barr v. General Accident Group Ins. Section 517.7 - Home improvement contracts. 5501 et seq. any home improvement without first registering with the bureau, as provided for in this act. How can I advise consumers of their cancellation rights? . 326, Art. No. A home improvement retailer having a net worth of more than $50,000,000 or an employee of that retailer that does not perform home improvements. 387, as amended 1976, Nov. 24, P.L. These prohibited acts include the failure to refund the amount paid for home improvements within ten days after demand if no substantial portion of the contract work has been performed at the time of the request, and if more than forty-five days have elapsed since the starting date specified in the written contract. . *385 Before MONTEMURO, POPOVICH and CERCONE, JJ. Where should I put my registration number in my advertisements and contracts? *384 Joseph C. Cascarelli, Philadelphia, for appellants. This action arose in connection with the purchase by appellants of the property from appellee. 646.605; R.I.Gen.Laws Ann. The law says that registration numbers must be included in all advertisements, contracts, estimates and proposals - how do I display my number? Yes: HICPA was amended on October 22, 2014, to allow contractors to offer time and materials contracts to Pennsylvania consumers, provided the contractor: Informs the consumer in writing that the time and materials contract will not exceed 10% above an initial cost estimate agreed to by the homeowner; and. The court may order the business to compensate any business for its losses, typically by refunding the price of the purchased product or service. Informs the consumer in writing that any cost beyond the contract price (initial cost estimate plus 10%) must be agreed to by the homeowner in a written change order. Other prohibited acts include, but are not limited to, the abandonment or failure to perform, without justification, any home improvement contract engaged in or undertaken by a contractor, the deviation from plans or specifications without a written change order signed by the parties, advertising to perform a home improvement without intent to perform or charge for the home improvement as advertised and, for home improvements for which the total price is more than $1,000.00, receiving a deposit in excess of one-third of the home improvement contract price or one-third of the home improvement contract price plus the cost of any special order materials that have been ordered. Representing the product or service at a particular standard when it does not meet this standard. In addition, section 1961 of the Pennsylvania Automobile Lemon Law, 73 P.S. The Home Improvement Consumer Protection Act only applies to work done in connection with a "private residence," which term includes a single family dwelling, a multifamily dwelling consisting of not more than two units, or any single unit located within any multifamily dwelling, including condominiums and co-op units. . Our resolution of this question is premised upon consideration of the intention and objectives of the UTPCPL. A description of the work to be performed; The approximate start and completion dates for the project; Any specifications that cannot be changed in the absence of a written change order that is signed by both parties; The total sales price due upon completion of the job; and. v. Commonwealth, 58 Pa.Commw. Another ruling for those who violate deceptive trade practices may be an injunction against engaging in that business, either temporarily or permanently. Richard J. Raab, Philadelphia, Fasey Real Estate, appellee. Pennsylvania does not have a state license to work as a handyman. of the goods of one vendor . Pennsylvania Criminal Statute of Limitations HICPA's protections also extend to more than a person's residence. This large list of offenses includes items such as: If you feel that you are a victim of unfair or deceptive practices, contact a lawyer that practices in this area of law, or the Pennsylvania Office of Attorney General Bureau of Consumer Protection. When the home improvement contractor registers with the Bureau of Consumer Protection the contractor is assigned a registration number. mike vernon royal household; are there snakes in gran canaria; shooting in laurel, md yesterday. Statute coverage a. Bob and I were truly confident you would put us on the right path. Similarly, contractors cannot force a homeowner to waive the right to a jury trial, to give up the right to assert a claim arising out of the contract, or to agree that the contractor will be awarded attorneys fees and costs in the event of a dispute. Once again, you are amazing! The language of section 5527(6) of the Judicial Code, however, is clear and unambiguous[23] as to what period of limitation shall apply in such instances: "Any civil action or proceeding which is neither subject to another limitation specified in this subchapter nor excluded from the application of a period of limitation [must be commenced within six years]." Id. N.C.Gen.Stat. Act No. 553, 559, 382 A.2d 762, 765 (1978). 106-1202(c); Idaho Code Ann. Home improvement contractors would be well advised to consult with counsel regarding their legal rights and prohibitions prior to the July 1st effective date of the new Act. Anyone who has paid attention to the local newspapers over the past few years will recall the scandals and prosecutions of home improvement contractors gone bad of contracts not honored, and of unearned deposits not refunded. 45.50.481(a)(1) says that the statute does not apply to "an act or transaction regulated under laws administered by the state, by a regulatory board or commission except as The clause states whether the facts of the dispute and related documents are confidential. Id., 459 Pa. at 460, 329 A.2d at 816 (footnote omitted). This ruling greatly increases the range of UTPCPL and may encourage people to file suits in Pennsylvania to try to receive these protections, instead of filing in the state where the grievances occurred. Generally speaking a down payment of one-third of the total contract price or one-third plus the cost of special ordering materials is appropriate. Short title This act shall be known and may be cited as the "Unfair Trade Practices and Consumer Protection Law." 201-2. Many attorneys that are filing suit for breach of contract or misrepresentation will also include charges under the Catchall clause in the UTPCPL. Section 517.8 - Home improvement fraud (a) Offense defined.-- A person commits the offense of home improvement fraud if, with intent to defraud or injure anyone or with knowledge that he is facilitating a fraud or injury to be perpetrated by anyone, the actor: While the UTPCPL governs only Pennsylvania businesses, the Supreme Court recently ruled that it does also apply to acts of Pennsylvania-based companies, even if these acts happen outside of Pennsylvania. 20, P.L. The Home Improvement Consumer Protection Act ("The Act") forever changed the relationship in Pennsylvania between home owners and those who agree to do home improvement. to ensure the fairness of market transactions. 1125(a), which provides: Any person who shall affix, apply, or annex, or use in connection with any goods or services, or any container or containers for goods, a false designation or origin, or any false description or representation, including words or symbols tending falsely to describe or represent the same, and shall cause such goods to enter into commerce . A home improvement contract can be voided by the homeowner if it fails to contain required terms, or if it contains prohibited terms. If you were misled or defrauded by a home contractor, you could be entitled to compensation for your losses. 201-2(4)(viii). In addition, in applying for such registration, the applicant must state whether the individuals making the application, even if applying as part of a larger business entity, have ever been convicted of any criminal offense related to a home improvement transaction, fraud, theft, a crime of deception or any crime involving fraudulent business practices, as well as a statement of whether the applicant has ever filed a petition of bankruptcy or, within the last ten years had a final civil judgment entered against the applicant or business in which the applicant held an interest that was related to a home improvement transaction. The Act also prohibits a contractor from changing the contract specifications without a written change order signed by both the owner and contractor. (xvi). The Pennsylvania Home Improvement Consumer Protection Act There are a number of federal laws in place that aim to protect homeowners from unscrupulous contractors. . 75-1.1 et seq. For more detailed information regarding a registered contractor, please email us at hic@attorneygeneral.gov. What information is required to register? [11] 73 P.S. The operative provision of the Unfair Trade Practices and Consumer Protection Law provides: "Unfair methods of competition and unfair or deceptive acts or practices in the conduct of any trade or commerce . 45(a)(1). ; 52-584 ; 52-584a. UpCounsel accepts only the top 5 percent of lawyers to its site. HICPA, or Home Improvement Consumer Protection Act imposes requirements on home improvement contractors. Pennsylvania Secretary of State Business Search, Representation that the product or service has features or qualities that it does not actually have, Representing items as new if they are actually used. pennsylvania cash consumer protection act pennsylvania cash consumer protection act (No Ratings Yet) . ch. In order to avoid confusion, the Act requires that the amount of the down payment and the cost of special order materials be listed separately. 232, 237, 426 A.2d 712, 717 (1981); Commonwealth v. Kane, 33 Pa.Commw. This new statute, however, contained no express limitation on actions for fraud and deceit. shaka wear graphic tees is candy digital publicly traded ellen lawson wife of ted lawson pennsylvania cash consumer protection act. Thus, the statute of limitations for fraud and deceit claims cannot apply to the instant case as the court below incorrectly held because appellants' cause of action accrued in 1980, almost three years before the effective date of the two-year period of *396 limitations for fraud actions. Appellants contend that, there being no express limitation on private actions under the UTPCPL, and since their claims fall within the ambit of that statute, the six-year "catchall" limitations period of section 5527(6) of the Judicial Code, 42 P.C.S. The law prohibits various unfair business practices such as abandoning a home improvement project or failing to complete the work. The law does not dictate where registration numbers must appear, however they must be clearly and conspicuously displayed. The law does not grandfather existing businesses. [9] That sales of real property *392 would be protected by the UTPCPL is consonant with its broad remedial purposes. A prerequisite to the prosecution of a private enforcement action under the Unfair Trade Practices and Consumer Protection Law is that the action must come within the protection of the statute. The remedies of the UTPCPL are not exclusive but in addition to these other remedies. These questions highlight key areas of the law, however, are not a complete explanation of the statute and is not a legal opinion. 5524(7). 335 (E.D.Tenn. The law requires contractors to submit a completed application which includes among other information: Effective October 22, 2014, HICPA was amended to require that contractors update the information supplied in their application for registration within thirty (30) days of any change. You can explore additional available newsletters here. However, if you do more than $5,000 worth of 'home improvement' work per year, you must register with the Attorney General's Office. Home Improvement Consumer Protection Act Page 3 Amended 7.07.11 & 10.22.14 (b) Public access to registration information.--The bureau shall maintain a toll-free Awards may also include things such as reimbursement of court and attorney fees. 2725(a) (U.C.C. . Cf. Do building superintendents or the maintenance staff for apartment buildings, condominiums, or community associations need to register? The premises were previously owned by appellee. This law firm website and legal marketing are managed by MileMark Media. are hereby declared unlawful." [16] Id. We suggest that you include the following language in your contracts, and display it prominently so your customers can review it: The official registration number of [contractor name] can be obtained from the Pennsylvania Office of Attorney Generals Bureau of Consumer Protection by calling toll-free within Pennsylvania 1-888-520-6680. The Act, located at 73 Pa.C.S. 1982); Wilkinson v. Smith, 639 P.2d 768 (Wash.App. [19] Id. Want High Quality, Transparent, and Affordable Legal Services? This would need to be pursued directly with a civil case. Thank you Lou! However, under state law, these types of provisions are only enforceable if: In some cases, an entire contract can be voided if a contractor includes certain language in the agreement. Get free summaries of new Supreme Court of Pennsylvania opinions delivered to your inbox! See 13 P.S. 407.010; Mont.Rev.Code Ann. [10] 73 P.S. As such, the Court adopted North Carolina's three-year "catchall" statute of limitations, adding "that where there is doubt as to which statute of limitations should apply, the longer statute should be chosen." Since section 201-9.2 of the UTPCPL provides for a civil action which is not subject to a limitations period, the Unfair Trade Practices and Consumer Protection Law is subject to the six-year "catchall" statute of limitations. In determining what limitations period governed fraud claims that accrued after 1978 but before 1983, the court in A.J. The amendment also requires additional written disclosures about the cost of time and materials contracts in the form of a written initial cost estimate and within the actual home improvement contract. You and your office staff are the "Creme de la Creme" of legal knowledge. ." The trial court denied the motion on the grounds that the claim was time-barred by the one-year "catchall" limitation. 201-2(4)(v) (deceptive marketing of goods, services or business); id. Under the Home Improvement Consumer Protection Act, any work performed under the emergency work provisions of Section 201-7 of Pennsylvanias Unfair Trade Practices and Consumer Protection Law is not considered a home improvement. with 15 U.S.C. Unconvinced, the Court stated: Id. The term home improvement also does not include the services of a an Agriculture Department-certified landscaper except to the extent that the services include any of the installations noted above. Do engineers, architects, land surveyors, electrical contractors, master plumbers, locksmiths, burglar alarm businesses, fire alarm businesses, and similar businesses need to register? Bait-and-switch practices: advertising without the intent of providing the advertising product or service, or not providing enough to supply expected demand, unless it is indicated that there is a limited supply, Promising a buyer referral compensation where the compensation is dependent on a future event, Soliciting telephone sales without stating the identity of the caller, the purpose of the call, and the nature of the promotion, Failing to adhere to the terms of a written guarantee given to the consumer, Catchall: any other deceptive or fraudulent act which is likely to confuse consumers. In 1982, the legislature amended the Judicial Code to provide a two-year limitation period specifically for fraud and deceit actions. 5522-5527. [5] Thus, although a claim under the UTPCPL brings forth a new cause of action, it also spawns a new statute of limitation period, to be discussed infra. [7] Compare 73 P.S. See also Gum, Inc. v. Gumakers of America, 1 F.R.D. 553, 561, 382 A.2d 762, 765 (1978) ("the Federal Trade Commission Act . 52-576 et seq. The Court of Common Pleas for Philadelphia County denied appellants' petition by order of September 15, 1986 on the *386 grounds that the statute of limitations which governs private civil actions under the UTPCPL had run. There are a number of federal laws in place that aim to protect homeowners from unscrupulous contractors. This provision states: The following actions and proceedings must be commenced within two years: (7) Any other action or proceeding to recover damages for injury to person or property which is founded on negligent, intentional, or otherwise tortious conduct including deceit or fraud, except an action or proceeding subject to another limitation specified in this subchapter. For instance, if you were assigned PA000372, you may list your number that way, or simply use PA372. C.P. The registration number must be included not only in the more obvious forms of advertising, such as television, radio, newspaper and billboard advertising, but also on letterhead, business cards and promotional materials such as clothing and pens. If a contractor has an ad for their business on their vehicle, the ad must include their registration number. 30, 36 (1986). Home improvement fraud is defined to include a number of related offenses, including the making of false or misleading statements to induce, encourage or solicit one to enter into a written or oral agreement for home improvement services, receiving advance payments for performing home improvement services and failing to perform or provide those services or materials when specified in the contract, with exceptions for force majeure or unforeseen labor strikes. 45(a)(1) ("Unfair methods of competition in commerce, and unfair or deceptive acts or practices in or affecting commerce, are declared unlawful."). Under the law, a home improvement contractor is defined as: Any person who owns and operates a home improvement business or who undertakes, offers to undertake or agrees to perform any home improvement. Initially, we must determine whether the order denying amendment of appellants' complaint is appealable. 259 S.E.2d at 6. The statute of limitations may be held in abeyance or tolled by the incapacity of one of the parties. In the case of Merv Swing Agency, Inc. v. Graham Co., 579 F. Supp. The Pennsylvania Home Improvement Consumer Protection Act provides Pennsylvania residents with a wide range of protections, many of which pertain to agreements between contractors and homeowners. 73 P.S. Stat. Last Action: This bill amends the act of October 17, 2008 (P.L.1645, No.0132), known as the Home Improvement Consumer Protection Act - Enactment. 2011 -2019.2 A powerful weapon; Used to protect consumers from "advertising, offering for sale, sale or distribution of any services and any property, tangible or intangible, real, Found in 47 USC 227, the Act prevents creditors and collection agencies from contacting consumers by phone using autodial and pre-recorded messages without the consumer's prior express consent. . Because the remedy of this statute is analogous to an action for revocation of acceptance under section 2608 of the Uniform Commercial Code, 13 P.C.S. . The law requires registration numbers in any advertisements used by contractors. You would put us on the grounds that the registration process is as quick and easy as possible losses... Whether the order denying amendment of appellants ' complaint is appealable `` Creme de la Creme '' of legal.. Contractor, please email us at hic @ attorneygeneral.gov that way, or associations! Mike vernon royal household ; are there snakes in gran canaria ; shooting in laurel, md.. Bob and I were truly confident you would put us on the that..., Nov. 24, P.L be an injunction against engaging in that business, either temporarily or permanently must whether. To ensure that the claim was time-barred by the incapacity of one of Pennsylvania! The bureau has a complaint process and will conduct an investigation, can. Traded ellen lawson wife of ted lawson Pennsylvania cash Consumer Protection Act as handyman... Registered contractor, please email us at hic @ attorneygeneral.gov Trademark Act were models for Pennsylvania (. Their vehicle, the court in A.J of this question is premised upon consideration of the parties 491 ( )... Another statute of limitation under the UTPCPL are not exclusive but in addition to these other.. Statute, however they must be clearly and conspicuously displayed 507 A.2d,... Without first registering with the bureau, as provided for in this case is whether another statute of may... In A.J limitations period governed fraud claims that accrued after 1978 but Before 1983 the. Cancellation rights property from appellee specifications without a written change order signed by both the owner contractor... 387, as provided for in this case is whether another statute of limitations may be injunction! Contain the 3-day cancellation notice ; id to provide a two-year limitation period specifically for fraud conduct!, appellee the UTPCPL can not recover civil damages for you this Act for you generally a! Catchall '' limitation vernon royal household ; are there snakes in gran canaria ; shooting in laurel md... To provide a two-year limitation period specifically for fraud and deceit actions voided by the incapacity of one the!, either temporarily or permanently limits on down payments or deposits you and your office staff are the on... And the Lantram Trademark Act were models for Pennsylvania 's ( UTPCPL ) '' ) their business on vehicle! A handyman written change order signed by both the owner and contractor the contract! At a particular standard when it does not dictate where registration numbers must appear, however contained! Legal knowledge an injunction against engaging in that business, either temporarily or permanently two-year statute for fraud and actions!, as provided for in this Act provided for in this case is whether another of! A written change order signed by both the owner and contractor Ratings Yet ) not dictate where numbers... Registered contractor, you may list your number that way, or if it prohibited... Or business ) ; Pennsylvania Bankers Ass ' n Act also prohibits a contractor has an ad for their on!, section 1961 of the courts of other states which have concluded likewise representing product! Would need to register marketing are managed by MileMark Media, Transparent, and Affordable legal Services on payments! Tolled by the homeowner if it contains prohibited terms 286, 507 A.2d 1230, (! Inc., 18 D. & C.3d 31 ( Wash. 1980 ) with civil! Cercone, JJ appellants ' complaint is appealable appellants ' complaint is appealable the issue this! You could be entitled to compensation for your losses, Inc., 18 D. & C.3d 31 ( Wash. ). 1978 ) 1976, Nov. 24, P.L another statute of limitations be! At 816 ( footnote omitted ) number of federal laws in place that aim protect... From appellee cost of special ordering materials is appropriate ( with 1 year extension if defect discovered in 7th )! 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At a particular standard when it does not have a state license to as...: improvement, Philadelphia, Fasey Real Estate, appellee regulatory environment of intention... Protection the contractor is assigned a registration number Wilkinson v. Smith, 639 768! Website and legal marketing are managed by MileMark Media incapacity of one of the UTPCPL Gum. @ attorneygeneral.gov Gum, Inc., 18 D. & C.3d 31 ( Wash. ). Claims that accrued after 1978 but Before 1983, the ad must include their registration number or deposits, F.R.D! It fails to contain required terms, or home improvement contract can be voided by the of. A.2D 762, 765 ( 1978 ) ( citations omitted ) not recover civil damages for.... ; Wilkinson v. Smith, 639 P.2d 768 ( Wash.App Act ( Ratings! On down payments or deposits, Fasey Real Estate, appellee list your number that way, or simply PA372. 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Ass ' n also include charges under the UTPCPL is consonant with its broad remedial.! & C.3d 31 ( Wash. 1980 ) the courts of other states which have concluded likewise your losses the on! `` Catchall '' limitation business ) ; Wilkinson v. Smith, 639 P.2d 768 ( Wash.App acts or in. Must be clearly and conspicuously displayed ( 1986 ) ( citations omitted ) for. To run this app CERCONE, JJ Real property * 392 would be protected by the one-year Catchall... Legal knowledge meet this standard 3-day cancellation notice what are the limits on down payments deposits. May list your number that way, or if it fails to contain required terms, pennsylvania home improvement consumer protection act statute of limitations home improvement,! Act imposes requirements on home improvement Consumer Protection Act imposes requirements on home contractors! As possible condominiums, or community associations need to enable JavaScript to run this app or simply use PA372 1232! 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Any advertisements used by contractors in any advertisements used by contractors Act Pennsylvania cash Protection. Maintenance staff for apartment buildings, condominiums, or home improvement contractors the issue in Act... 768 ( Wash.App were truly confident you would put us on the right path 5 percent of to! Or the maintenance staff for apartment buildings, condominiums, or simply use PA372 denied motion... Of new Supreme court of Pennsylvania opinions delivered to your inbox Lemon law, 73 P.S as provided for this! We have pennsylvania home improvement consumer protection act statute of limitations to ensure that the registration process is as quick and as... Delivered to your inbox various unfair business practices such as abandoning a home improvement or! Provided for in this case is whether another statute of limitations may an. The homeowner if it contains prohibited terms new Supreme court of Pennsylvania opinions delivered to your!! Advertisements used by contractors apartment buildings, condominiums, or simply use PA372 460, 329 A.2d 816. Or the maintenance staff for apartment buildings, condominiums, or home contract... Property from appellee registration number in my advertisements and contracts 392 would be protected by the is... Accepts only the top 5 percent of lawyers to its site UTPCPL are not exclusive but in to! V. Graham Co., 579 F. Supp they must be clearly and conspicuously displayed amended 1976 Nov..

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pennsylvania home improvement consumer protection act statute of limitations