Aaron C. Dunlap

Aaron Dunlap brings a multifaceted perspective to advising real estate developers, financial institutions and lenders, and clients with real estate interests or that regularly interact with state and local administrative agencies throughout Florida on real estate developments. With private practice, state agency, and local government experience, Aaron has an insider's understanding of private party and governmental priorities that helps him find common ground across both the public and private sectors to benefit his clients.

Aaron has two decades of experience representing real estate developers on homeowners association and condominium association matters, including turnover of association control, and drafting amendments and revisions to declarations and restrictive covenants for clubs, amenities, and build-to-rent communities. Combining his land use and development experience, Aaron also represents banking and private equity in land use and condominium due diligence for acquisition and construction loans worth billions of dollars a year.

His experience also includes land use and zoning matters before elected officials and local government boards, drafting zoning code and comprehensive plan amendments, and navigating the public hearing process in municipalities throughout Florida, including specialty areas such as remnants of developments of regional impact and areas of critical state concern.

He also has significant state administrative challenge experience in bid protests, environmental permit challenges, and development order and comprehensive plan amendment challenges.

Aaron is board certified in city, county, and local government law by the Florida Bar.

• Advises clients on zoning and land use regulations, including state and local approval processes for permitting and development approvals, rezonings and comprehensive plan amendments, and areas of critical state concern.
• Assists clients with zoning and statutory interpretation in all facets of real estate development regulations, including concurrency, impact fees, and proportionate share issues.
• Drafts local government code and charter provisions and amendments, affordable housing ordinances, and general development regulations.
• Routinely provides land use counsel related to large-scale development projects throughout Florida, including in areas of critical state concern and the Florida Keys.

• Represents institutional lenders and private equity in loan due diligence for zoning and land use, condominium and homeowners association structures, and documentation for client loans related to acquisition, construction, and equity positions in residential, condominium, commercial, and industrial real estate projects in dozens of loans a year, for billions of dollars of lending.
• Routinely provides advice on local government law requirements for project implementation, along with risk analysis concerning project viability.

• Advises community developer and condominium developer clients on the applicability and interpretations of master community documents, existing homeowners association documents, condominium association documents, and commercial mixed-use restrictive covenants for the development or redevelopment of property, including significant litigation experience.
• Drafts developer-focused amendments to homeowners association and condominium association declarations, including issues related to clubs and amenities, build-to-rent communities and subdivisions, and amendments for additional phases of construction in existing communities post-turnover of developer control.
• Represents developers in both homeowners association and condominium association turnover of control.
• Provides analysis to prospective developers and financial institutions on outstanding community development district (CDD) bonds and financials.

• Served as lead or second-chair counsel in numerous administrative challenges through final order issuance, including environmental permit applications and challenges, state-level bid protests, affordable housing finance challenges, and development order and comprehensive plan challenges, including within the Florida Keys area of critical state concern.
• Advises clients on procurement issues related to RFPs, RFQs, and bid selections.
• Advises and represents client interests before Florida state agencies in the capacity of lobbying agencies and the Florida Legislature, facilitating discussions with agency staff, and working with agencies to accomplish client goals.

• Represented state agency in public records litigation and successful appeal to overturn attorneys' fee award against the agency.
• Drafts and tailors public records requests to all Florida state and local agencies and governmental bodies to obtain relevant documents for clients' particular needs.
• Assists clients in determining the scope and applicability of public records laws to documents submitted to the government for applications, grant applications, and other submissions, including the applicability of statutory exemptions and exclusions.

• The Best Lawyers in America, Government Relations Practice, Land Use and Zoning Law, Real Estate Law (2026–2027)

• American Bar Association
  • Real Property, Trust, and Estate Law Section
    • Council Member (2026–present)
    • Co-Chair, Corporate Sponsorship Committee (2023–present)
    • Chair, Land Use and Zoning Committee (2023–2026)
    • Government Submissions Committee (2025–present)
    • Vice Chair, Governmental Incentives Committee (2022–2023)
• The Florida Bar
  • Governmental Advocacy Committee (2022–present)
    • Chair (2025–2026)
    • Vice Chair (2024–2025)
    • Executive Subcommittee (2022–present)
    • Director of Outreach (2022–2024)
• Association of Florida Community Developers

• "Live Local, Build Local: Recent Changes in Local Development Regulations," 45th Annual Legislative and Case Law Update, The Florida Bar Real Property, Probate, and Trust Law Section, Palm Beach, FL (August 22, 2025)
• "HOA Reserve Funding: Obligations & Strategies for Developers and HOAs," 49th Ralph E. Boyer Institute on Condominium and Cluster Development, University of Miami School of Law (September 26, 2024)
• "Ownership and Investment of Real Property by Foreign Principals: Florida Legislation and Its Nationwide Effects" and "Avoiding Public Hearing Pitfalls: Preparation, Presentation, and Legal Challenges," American Bar Association Real Property, Trust, and Estate Law Section Land Use and Environmental Group Presentation (March 21, 2024)
• "Avoiding Public Hearing Pitfalls: Preparation, Presentation, and Legal Challenges," Annual Environmental Permitting Summer School, Florida Environmental Network, Marco Island, FL (2019–2026)
• "Brownfields Redevelopment and Remediation in Underprivileged Communities: Coalescing Developer Goals, Development Incentives, and Community Benefits," American Bar Association Real Property, Trust, and Estate Law National CLE Conference, Washington, D.C. (May 10–12, 2023)

Prior speaking topics also included: Drafting Open Meetings and Public Records Legislation (2022); Policy Directions for Growth Management (2021); Concurrency, Impact, and Mobility Fees (2021); Opportunity Zones (2020); and Sector Planning (2016).

• Assistant Village Attorney, Village of Wellington, Wellington, FL (2015–2017)
• Assistant General Counsel, Florida Department of Economic Opportunity, Tallahassee, FL (2014–2015)
• Litigation Associate, Shubin & Bass, P.A., Miami, FL (2007–2011)