Cox

Opinion of the Court by Guerrero, C. J.

The Subdivision Map Act (the Act; Gov. Code, §§ 66410– 66499.41)1 “is ‘the primary regulatory control’ governing the subdivision of real property in California.” (Gardner v. County of Sonoma (2003) 29 Cal.4th 990, 996 (Gardner).) In general, the Act requires a landowner wanting to divide real property to first seek local governmental approval of a map detailing various aspects of the proposed subdivision. (Gardner, at p. 997.) Such approval can only be obtained after a local agency conducts an “extensive review” of the proposed subdivision with respect to numerous land use and development criteria. (Ibid.) To enforce the important public policies furthered by such review, the Act prohibits the sale, lease, or financing of any parcel of subdivided real property until an approved map is recorded. (Gardner, at p. 999.) The filing of such a map was formerly only required when dividing land into five or more parcels during a one-year period. (See, e.g., Stats. 1929, ch. 837, § 1, p. 1791.) But the Legislature amended the Act, effective March 4, 1972, to require the filing of a “parcel map” when dividing land into fewer than five parcels. (Stats.…