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July 2026 JULY 2026 | ISSUE NO. 32

NEWSLETTER

OFFICIAL LOCAL NEWSLETTER OF YOUR LOCAL REAL ESTATE INVESTOR ASSOCIATION

NEWS INSIDE:

Navigating Shift & Power of Proximity

WHY NETWORKING MATTERS

Success in real estate is about the information you leverage

Page 2

plugged into a sharp local community is what separates a

“ASSISTANCE ANIMAL” QUALIFICATIONS ARE CHANGING Page 4

DISCOUNTS FOR RENTAL SOFTWARE Page 8

KOBLE VS. MARQUARDT UPDATES Page 9

and the network you build. In a shifting market, staying thriving portfolio from a stagnant one. This month, we are breaking down changing "Assistance Animal" qualifications, the critical Koble vs. Marquardt case, and exclusive member discounts on top-tier websites and software. Plus, we look ahead to our upcoming Expo to show you why strategic networking is the ultimate secret weapon for scaling your business. Grab a coffee, dive in, and let’s build some wealth. Note: This newsletter contains a few affiliate links. If you click, and purchase, we may receive a small commission at no extra cost to you.

Why Networking Is the Secret Weapon of Every Successful Real Estate Investor When it comes to real estate investing, knowledge is power, but relationships are leverage. Whether you're a seasoned pro or just getting started, your ability to connect with the right people can open doors that money or experience alone simply can’t. Deals get done through conversations, trust is built through shared stories, and the best opportunities often come from a simple, “Hey, I know someone who might be a good fit for that.” That’s the power of networking. And there’s no better place to build your network this year than at the 2025 REIA Expo & Tradeshow, happening Tuesday, July 8th in Milwaukee. Real Estate is a Relationship Business You’ve probably heard it before: “Your network is your net worth.” It’s more than just a catchy phrase it’s the reality of how deals are sourced, funded, and closed in this industry. The right connection can mean a private lender who helps you scale faster, a contractor who actually shows up and does quality work, or a mentor who’s been through multiple market cycles. It could be a wholesaler who keeps you in the loop on upcoming deals, or a joint venture partner that helps you go bigger than you could on your own. And it all starts by being in the right room. Stop Networking Like It’s 2010 Let’s be honest—swapping business cards and collecting LinkedIn connections only goes so far. Real networking is about real conversations. It’s about showing up consistently. It’s about being known in your local investing community. If you’ve ever said to yourself, “I wish I had more deal flow,” “I’m looking for good contractors,” “I need funding for my next flip,” or “I want to meet more investors like me,” then this is your room. Your moment. Your advantage. Let’s Get Face-to-Face There’s only one way to build meaningful relationships in this business, and that’s to get off social media, step away from your spreadsheets, and show up in person. So don’t miss your chance to be part of the biggest networking event of the year for local real estate investors.

👉 Scan the QR Code to Sign up! 📅 Tuesday, July 14th - Doors open at 5:45 pm

Upcoming Events

JOIN IN WITH SOME LOCAL EVENTS!

JUL 7

Volunteer Info & Training Night

JUL 11

Online Masterclass: How to Plan and Control Your Rehab

JUL 14

2026 REIA Expo

JUL 22

Investor Breakfast Club

JUL 25

Online Masterclass: How to Get Started in New Construction

JUL 28

Office Hours

JUL 30

W.I.N.G.S. Luncheon

Dave Graf | 920-203-6087 | dave@gsifoundations.com

Jodi Graf | 414-395-5478 | jgraf@premierpointrealty.com

Taylor Rens | 414-296-6225 | taylor.rens@zrlaywers.com

John Newland | 414-852-0921 jnewland@terranova-realestate.com

Book of the Month

414-276-7378 | membership@aasew.org

Dan Farsht | 262-208-4708 | info@reiahardmoney.com

Tanya Holland | 414-507-4418 | tholland@prisimtitle.com

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“Assistance Animal” Qualifications Are Changing BY: JEFFERY S. WATSON VIA REALESTATEINVESTINGTODAY.COM

Landlords and housing providers, please read this carefully, and you will see that positive change is on the horizon. New guidance from the U.S. Department of Housing and Urban Development limits the types of Fair Housing Act complaints the agency will accept regarding assistance or service animals. Those who have followed me for some time have seen my previous articles over the years about this, based on my experiences with legislation and litigation in Ohio. The litigation was the most telling because the analysis that the Court of Appeals followed is very similar to what is laid out below and what the U.S. Department of Housing and Urban Development is doing. They are going back to a strict reading of the actual law. Let me give you a quick review. The Americans with Disabilities Act (ADA) protects people with disabilities. Disabilities are defined as something that interferes with an essential daily activity. Service or assistance animals must be able to address that disability. The two biggest examples I can quickly recall are guide dogs and dogs trained to prevent injury to a person experiencing a sudden seizure or a drop in blood sugar. In recent years, this has become a wide-open, exploited area with multiple online cottage industries springing up to provide fake certifications for emotional support animals. This resulted in a stretch way beyond the bounds of what the ADA encompassed, and emotional issues are not frequently connected to essential activities of daily living. Continue to the next page for more

I’m not talking down to anybody who has anxiety, but anxiety is a symptom of a bigger condition. If you’ve been diagnosed with post-traumatic stress disorder, anxiety is a symptom, and PTSD is a disability. But anxiety in and of itself is not a disability and does not qualify someone for a service or assistance animal. After years of litigation and hundreds of thousands of dollars in legal expenses, the landlord in an Ohio case related to this was vindicated (Helen Grybosky v. Ohio Civil Rights Commission, 2017-Ohio-7125). The U.S. Department of Housing and Urban Development is sharply limiting which types of animals people with disabilities who are renting a home or apartment can claim as a “reasonable accommodation.” For the accommodation to be reasonable, it must relate to a condition that interferes with an activity of daily living. New guidance indicates that the FHA will only consider “animals trained to provide disability-related assistance” as an accommodation for people with disabilities under the Fair Housing Act. Previously, animals that provided emotional support qualified even if they didn’t have any specialized training. As a result, landlords generally could not charge a pet fee or deny housing to an individual with an emotional support animal. The directive to HUD’s Office of Fair Housing and Equal Opportunity staff late last month does not change existing law, but it does influence enforcement by curtailing what types of Fair Housing Act complaints the agency will take up. It replaces guidance that was issued in 2020. Per the new guidance, HUD will more closely align its standard for determining which animals qualify as reasonable accommodations with the Americans with Disabilities Act. One notable difference, however, is that the housing agency will recognize any species with proper training while the ADA definition is limited to dogs and miniature horses. Under the ADA, service animals are predominantly dogs and, with few exceptions, miniature horses, but no other creatures. HUD is going to continue to recognize many other species of animals with proper training as assistance animals. Proper training must actually occur. It can’t be manufactured by visiting a website, printing a couple of forms, and then claiming training is complete. As I write these words, my mind returns to the moment one of my former tenants entered with a “service animal” on a leash and wearing a muzzle. The dog lunged and snarled at me. Clearly, that German shepherd was untrained.

“While requests to waive pet policies for animals trained to perform specific disability-related services are presumptively reasonable, requests to waive pet policies for untrained ESAs are not,” reads the memorandum from Craig W. Trainor, Assistant Secretary for Fair Housing and Equal Opportunity. “By prioritizing the most meritorious cases involving trained assistance animals, (the Office of Fair Housing and Equal Opportunity) can responsibly utilize its enforcement discretion to deploy enforcement resources consistent with the best reading of the law.” All open cases related to emotional support animals will be reviewed by Acting Deputy Assistant Secretary for Enforcement and Programs, Robert A. Doles, and will be determined on a case-bycase basis, HUD said. The agency noted that its regulations on this topic have not been updated in 35 years and indicated that it plans to propose updated rules that are more consistent with those under the ADA. For people with emotional support animals, the new guidance means that “filing a complaint with HUD is no longer a meaningful option,” according to the Disability Rights Education & Defense Fund. “That removes a significant deterrent that previously helped keep landlords from denying ESA requests or charging pet fees,” the group said. What has not changed is the Fair Housing Act itself. The law still says landlords must make reasonable accommodations for disabled people. And today, based on the changes that we anticipated a year and a half ago, we know that HUD will focus on the letter of the law and what defines a true disability. Jeffery S. Watson is an attorney who has had an active trial and hearing practice for more than 25 years. As a contingent fee trial lawyer, he has a unique perspective on investing and wealth protection. He has tried over 20 civil jury trials and has handled thousands of contested hearings. Jeff has changed the law in Ohio four times via litigation. Read more of his viewpoints at WatsonInvested.com.

Milwaukee REIA Vendor Highlight

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Market Update FOR MILWAUKEE COUNTY

711 Sold Homes

853 New Listings

AVG Days on Market

$384k AVG Sale Price

$349k

102.3%

AVG Listing Price

Sales Price Ratio

$789k

102.2%

FOR WAUKESHA COUNTY

412 Sold Homes

543 New Listings

AVG Days on Market

$653k AVG Sale Price

AVG Listing Price

Sales Price Ratio

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Wisconsin Supreme Court Issues Koble Investments vs. Elicia Marquardt Decision This blog post was drafted by Atty. Tristan Pettit and Atty. Gary Koch, and edited by Atty. Jennifer Hayden, all of Pettit Law Group S.C. At long last (oral arguments were held back in September of 2025!), the Wisconsin Supreme Court has issued its decision in the Koble Investments vs. Elicia Marquardt case. The wait has been worth it! The Landlord prevailed on all issues, and the Wisconsin Supreme Court reversed the prior decision by the Court of Appeals. Just to bring you back up to speed, tenant Elicia Marquardt sued her landlord, Koble Investments, claiming that her rental agreement contained a prohibited rental provision which was allegedly a violation of Wis. Stat. 704.44 - one of the “10 Deadly Sins” - that voided her lease. She argued that because her lease was void, all rent she paid to her landlord under the void lease needed to be returned to her, doubled (because of consumer protection statutes), and that Koble would need to pay HER attorney’s fees. She also argued that the Wisconsin Consumer Act should apply to residential rental agreements. The Wisconsin Court of Appeals agreed with her! For a more in-depth analysis of the history, please see our prior blog posts: ATTENTION LANDLORDS: Wisconsin Court of Appeals case of Koble v. Marquardt Is Now Law Update on the Koble Investments vs. Elicia Marquardt Case at the Wisconsin Supreme Court Oral Arguments on Koble Investments v. Marquardt Case To Be Heard by the Wisconsin Supreme Court on September 9, 2025 Koble appealed to the Wisconsin Supreme Court, which issued its written decision earlier today. In its opinion, authored by Justice Bradley and joined by 6 of the 7 Justices, along with two concurring opinions, the Wisconsin Supreme Court unanimously reversed the Court of Appeals' decision! First, the Wisconsin Supreme Court held that the Wisconsin Consumer Act’s (WCA) prohibited debt collection practices statutes do not apply to residential rental agreements, for multiple reasons. The Concurring opinion of Justices Bradley and Ziegler argued that the majority opinion should have gone further and held that the WCA doesn't apply to residential landlord-tenant law at all.

The majority opinion noted that, “[f]or the first time since the legislature enacted the WCA in 1971, the court of appeals held that a residential lease is a ‘consumer transaction’ with ‘an agreement to defer payment’ governed by the WCA.” The Court quickly corrected the Court of Appeals’ error, holding that the prohibited practices portion of Wisconsin Consumer Act “does not govern a residential lease . . .” Justice Bradley and Ziegler’s concurrence stated, “The same reasoning underlying the court’s conclusion that 427.104 does not cover residential leases applies with equal force to the entire WCA. The history and application of the WCA verify its plain meaning: the WCA does not apply to residential leases. For the benefit of the public, the regulated community, and the executive branch, the court should say so.” This is great news!‍But the news gets even better. Second, the Supreme Court found that the rental provision rendering Ms. Marquardt’s rental agreement void did not cause her to suffer any pecuniary loss and therefore, she has nothing to recover, including her attorney’s fees. The Court did not address the root question of whether Koble’s rental agreement provision was prohibited absent the Domestic Abuse Protection language because Ms. Marquardt did not show that the alleged violation of 704.44 (9) caused her any damages. The majority wrote: “While Marquardt did pay rent, the law does not allow a tenant to occupy premises rent-free simply because the lease is void and unenforceable. Under Wisconsin law, a tenant occupying a premises under a void and unenforceable lease becomes a ‘periodic tenant’ under Wis. Stat. 704.01(2) obligated to pay rent on whatever basis she had been paying rent under the lease - in this case on a monthly basis.” The Court held that there MUST be a causal connection between the prohibited practice and any potential damages to the tenant. The majority wrote, “A party asserting a pecuniary loss for the purposes of Wis. Stat. 100.20(5) must show that there is a causal connection between the prohibited trade practice. . . and the damages incurred.” Take a few moments to read the decision and concurrences – they are good reading, and have quite a few memorable quotes.‍ This decision is a collective relief for the entire rental housing industry. T+G+J ‍This blog post was drafted by Atty. Tristan Pettit and Atty. Gary Koch, and edited by Atty. Jennifer Hayden, all of Pettit Law Group S.C.