Skolnik Thiele Real Estate Agent Liability - Grllp

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KEEPING CURRENTFebruary 16, 2016 www.grllp.comREAL ESTATE AGENT LIABILITY:HIGHLIGHTING THE POTENTIAL CAUSESOF ACTION AGAINST THEMBy Bryan Skolnik and Stephen Thiele1Founded in the 1920s,Gardiner Roberts LLPhas grown to become astrategically placed midsized business law firm witha diverse client base whichincludes two of Canada’slargest banks, severalmedium to large-sizedmunicipalities, agencies,boards and commissionsand other governmententities, high tech andsoftware companies, realestate developers, lendersand investors.A number of our lawyershave enjoyed in-housecorporate positions andbeen appointed as boardmembers of tribunals oras judges.Bryan n TIONA real estate agent can be defined as anyindividual who is licensed to represent a buyeror a seller, and sometimes both in the case ofdual agency, in a sales transaction involvingresidential, commercial or vacant land.Within this general definition, real estateagents are often subcategorized as either a“listing agent” or a “selling agent”.A “listing agent” is the agent of the seller. Thelisting agent and the seller in general enterinto an agreement under which the agent willmarket the seller’s property for a fixed periodof time. Among other things, this agreementwill also establish the rate of commission andestablish when a commission by the agentcan be claimed.A “selling agent” is an awkward term sincehe or she, in general, represents the buyer.The “selling agent” is the agent who presentsan offer of purchase and sale to the vendor.Regardless of these sub categorizations, thelicensing requirement, which is establishedby statute, results in real estate agents beingviewed as a profession.As members of a profession, real estateagents must act accordingly whenrepresenting their clients.Like any other profession, when a real estateagent fails to meet his or her duties andobligations vis-à-vis a client, he or she canface professional liability.GARDINER ROBERTS LLPBay Adelaide Centre – East Tower22 Adelaide St. W, Suite 3600, Toronto, ON M5H 4E3T 416 865 6600 F 416 865 6636 www.grllp.comReal estate agents can be held liable forbreach of contract, negligence, includingnegligent and fraudulent misrepresentation,and breach of fiduciary duty.While whether the conduct of a real estateagent will attract liability in any particularcase is, of course, a matter of the factualcircumstances at issue, the kinds of casesin which real estate agents have been heldliable offers some guidance to someoneassessing if a cause of action exists againsta real estate agent in another set of uniquefactual circumstances.Based on the foregoing, the purpose ofthis paper is to highlight the main causesof action that are usually brought againstreal estate agents and to identify some of themost common themes in which courts haveheld real estate agents liable. In highlightingthe main causes of action and the commonthemes, this paper will further delineate thosecases in which a real estate agent has beenheld liable to a vendor and those cases inwhich the agent has been held liable tothe purchaser.BREACH OF CONTRACTAs a matter of law, the relationshipbetween an agent and his or her principal iscontractual. Accordingly, the agent is requiredto comply with the duties and responsibilitiesfound in the contract. He or she may alsobe required, however, to comply withimplied terms.One of the terms normally implied into theagency contract is that the agent will carry out

his or her services with a reasonable degreeof skill, care and diligence.2 Indeed, this is thegeneral duty every agent possesses vis-àvis his or her principal. As noted in Phelan v.Realty World Empire Realty Ltd., citing fromsecondary sources on the law of agency:Every agent acting for reward isbound to exercise such skill, care anddiligence in the performance of hisundertaking as is usual or necessary inor of the ordinary or proper conduct ofthe profession or business in which heis employed, or is reasonably necessaryfor the proper performance of theduties undertaken by him.3The requirement to provide services with areasonable degree of skill, care and diligenceapplies to both listing agents and sellingagents, and will be part of both writtencontracts and oral contracts.With respect to written contracts, in thebuying and selling of real estate the onlywritten contract which generally exists isthe listing agreement. With respect to theseagreements, many of the disputes betweenthe contracting parties revolve around theentitlement to a commission. A typical case iswhere the listing agreement expires, but thevendor eventually sells the property to a buyerwho was introduced to the vendor duringthe period of the agreement. These cases,however, generally involve the real estateagent bringing a claim against the vendor andare beyond the scope of this paper.In other cases, vendors have attempted toargue that one of the implied terms in thecontract with the listing agent is that thelisting agent is required to obtain the bestprice possible for the property to be sold.In Phelan, however, the court rejected thatsuch a term could be implied into the listingagreement. In this case, the vendors claimedentitled to damages as a result of believingthat their home had been sold for a price thatwas less than its actual value.At the time of entering the listing agreement,GARDINER ROBERTS LLPBay Adelaide Centre – East Tower22 Adelaide St. W, Suite 3600, Toronto, ON M5H 4E3T 416 865 6600 F 416 865 6636 www.grllp.comthere was a discussion between the vendorsand the listing agent with respect to price.The agent advised the vendors that a listingprice of 200,000 was reasonable, but thatat this price the home would take a long timeto sell. Accordingly, a lower listing price wasrecommended and eventually the vendors’home was listed for sale at 190,000. Thehome sold for 186,000. Even though thevendors accepted the offer at this price, theyclaimed that this was not the best possibleprice they could have obtained. Monthsafter the sale, the vendors commissioned anappraisal which valued their property at thetime of sale at 235,000. This appraisal waslater revised to a value of 220,000.The theory of the vendors was that the dutyof a real estate agent was to obtain thehighest possible selling price for his principaland that where the best possible selling pricewas not obtained, the agent breached thecontract. The court simply disagreed.4 Therewas no express term that the agent agreedto obtain the highest possible selling pricefor the vendors and no such term could beimplied into the contract.In a more recent case5, a developer of landsought to sue the listing agent for a portionof costs incurred to market and advertisea commercial condominium project whichnever ultimately proceeded. Although themain responsibility of the agent under thelisting agreement was to market and sell thecommercial condominium units that were tobe built, the court rejected the developer’sargument that the agent was required toreimburse it for the costs of marketingmaterials it had independently contracted witha third party to produce and had provided noinformation to the agent about.In rendering its decision, Justice Edwardsmade some significant general commentswith respect to listing agreements andtheir interpretation. The judge stated thatlisting agreements are to be interpreted inaccordance with sound commercial principlesand practice.6 Furthermore, the interpretationof the agreement was subject to the usual

rules of contractual interpretation. Citing fromthe decision of Justice Winkler in Salah v.Timothy’s Coffees of the World Inc.:The basic principles of commercialcontractual interpretation may besummarized as follows. Wheninterpreting a contract, the court aimsto determine the intention of the partiesin accordance with the language usedin the written document and presumesthat the parties have intended whatthey have said. The court construesthe contract as a whole, in a mannerthat gives meaning to all of its terms,and avoids an interpretation thatwould render one or more of its termsineffective. In interpreting the contract,the court must have regard to theobjective evidence of the “factualmatrix” or context underlying innegotiation of the contract, but not thesubjective evidence of the intention ofthe parties. The court should interpretthe contract so as to accord withsound commercial principles and goodbusiness sense, and avoid commercialabsurdity. If the court finds that thecontract is ambiguous, it may thenresort to extrinsic evidence to clear upthe ambiguity.7While the failure of a real estate agentto exercise reasonable care, skill anddue diligence in representing a clientcan result in a claim for breach of contract,the usual circumstances in which realestate agents have been held liable toa vendor or purchaser involve findingsof negligence, including negligent andfraudulent misrepresentation, and breachof fiduciary duty.measured by the standard of a reasonablycompetent real estate agent.8 This generalstandard, is a question of law, not a questionof fact, and therefore it does not vary fromcase to case.Real estate agents can also be held liable fornegligent misrepresentation and fraudulentmisrepresentation. The required elements fora successful claim with respect to each ofthese torts is well-established.To succeed in a claim for negligentmisrepresentation:1. there must be a duty of care based ona “special relationship” between therepresentor and the representee;2. the representation in question must beuntrue, inaccurate or misleading;3. the representor must haveacted negligently in making saidmisrepresentation;4. the representee must have relied in areasonable manner on said negligentmisrepresentation; and5. the reliance must have been detrimentalto the representee in the sense thatdamages resulted.The leading authority in Canada with respectto negligent misrepresentation is Queen v.Cognos.9NEGLIGENCE AND MISREPRESENTATIONWherever there is a duty of care, there isan ability to sue the party who breachessuch duty.Similarly, to succeed in a claim for fraudulentmisrepresentation, the following elementsmust be established:1. that the defendant made a falserepresentation of fact;2. that the defendant knew the statementwas false or was reckless as to its truth;3. that the defendant made therepresentation with the intention that itwould be acted upon by the plaintiff;4. that the plaintiff relied upon thestatement; and5. that the plaintiff suffered damages asa result.10With respect to real estate agents, it iswell-established and accepted that such anagent owes a duty of care to his or her client,Claims against agents by purchasersIn general, buying a residential home probablyrepresents the most significant purchase anGARDINER ROBERTS LLPBay Adelaide Centre – East Tower22 Adelaide St. W, Suite 3600, Toronto, ON M5H 4E3T 416 865 6600 F 416 865 6636

individual will ever make. Accordingly, it is notsurprising that in this area of law there aremany cases where purchasers have claimeddamages for defects to their “newly” acquiredproperty. Indeed, one of the leading cases inthis area of law involves such a scenario.In Krawchuk v. Scherbak11 a purchaser suedboth the vendors and her agent, who alsohad acted on behalf of the vendors under adual agency, for serious latent structural andplumbing defects discovered post-closing. Atthe time of sale, the vendors had completeda Seller Property Information Sheet (“SPIS”)in which they stated, in response to whetherthey were aware of any structural problems,that the northwest corner was settled andthat they had not had any further problemsin 17 years. With respect to whether theywere aware of any plumbing problems, thevendors answered “No”. These answers,however, were inaccurate to the knowledgeof the agent, who as a matter of fact, amongother things, was aware that the househad a reputation of experiencing settlementproblems, and that the house was beingoffered at a price that reflected thesettlement concerns.On viewing the property, the purchaseridentified certain structural problems withthe home and made specific inquiries tothe agent about her observations. Yet theagent only repeated the information thathad been provided by her other clients, thevendors. The purchaser alleged that theagent had negligently misrepresented thefact that there were no structural problems,that she failed to recommend that she have aqualified inspector provide an opinion aboutmaterial issues affecting the house and failedto explain the risks of not making her offerconditional on a home inspection.The Ontario Court of Appeal determinedthat the real estate agent was liable for theproblems encountered by the buyers as aresult of defects. The court found that basedon numerous case law a buyer’s agent had aduty to verify a vendor’s information about aproperty. In this case, the agent had to eitherGARDINER ROBERTS LLPBay Adelaide Centre – East Tower22 Adelaide St. W, Suite 3600, Toronto, ON M5H 4E3T 416 865 6600 F 416 865 6636 www.grllp.comverify the assurances made by the vendorsherself or recommend, in the strongestterms, that the buyer get an independentinspection either before submitting her offer ormaking the offer conditional on a satisfactoryinspection. The failure to do either was anegregious error.12In MacDonald v. Gerristen13 a real estateagent acting on behalf of purchasers wassimilarly held liable for defects discoveredafter closing. In this case, the buyers hadattended the offices of the brokerage thathad listed the property at issue for sale.The buyers made it known after viewingthe property that their biggest concern waswhether the house had any water problems.While the buyers noticed a crack in the floorand water staining on an exterior wall, theywere assured by their agent that they shouldnot worry. There were no qualifications placedon her statements and despite the concernsexpressed by the buyers, the agent failed toinclude a clause in the agreement that wouldhave made the offer conditional on a nonleaking basement or further inspection.Three weeks after closing a massive rainstormresulted in severe flooding in the basement ofthe home.In the circumstances, the court held theagent liable for negligent and fraudulentmisrepresentation. The court determined thatthe agent had misrepresented crucial factsto the buyers which were sufficient to inducethem to make an offer to buy the property.Among other things, she lied about herexperience and that the fact that the househad been re-inspected to determine if it hadbeen soundly constructed. She gave theimpression that she had knowledge of theparticular house, the vendor and the area ingeneral. Lastly, although not duly qualified,she instructed the purchasers on what tolook for to determine if there was any waterdamage and provided an explanation for all oftheir inquiries to allay any concerns that theyhad respecting water in the basement ofthe house.14

In Blais v. Cook15 the purchasers’ real estateagent was held liable for failing to inform hisclients about the special risks of a transaction.In this case, the buyers purchased a homethat was supplied by water from a well anda cistern. While the water in the well was“salty” (something that the buyers expresslydid not want), this fact was never broughtto the attention of the buyers by their agent.Instead, the buyers’ agent had undertakento test the well water and revealed to themthat following a test the water was “okay” or“zero zero”. Based on this advice, the buyerswaived a condition to satisfy themselves asto the “quality and quantity of water” beingproduced by the well.However the well water had been tested forbacteria only. Furthermore, the agent did notdiscuss with his clients the significance of thefact that the water was “salty” and that thepresence of the cistern and additional wellson the property was an indicator of potentiallypoor water quality or quantity problems.He also did not discuss with the buyers thewell record.In the circumstances, the court determinedthat the agent was negligent for not fullyapprising the purchasers about the problemsof salt in the water supply and the difficultythat the purchasers might face on re-sale ofthe property.Just like the quality and quantity of wateravailable on the property, re-sale was animportant factor in this case since thepurchasers were members of the military whowere frequently posted both in and outsideCanada.16 This fact was known to the agent.Agents can also be held liable for failing toensure that appropriate terms are included inan agreement of purchase and sale, therebyleaving their clients unprotected againstcertain events. In Wemyss v. Moldenhauer17,the court stated that a real estate agent hasa duty to act with reasonable care and skill inreviewing the terms of a purchase agreementwith his or her client. That duty includes theobligation to specifically draw to the client’sattention, any provisions in the agreementGARDINER ROBERTS LLPBay Adelaide Centre – East Tower22 Adelaide St. W, Suite 3600, Toronto, ON M5H 4E3T 416 865 6600 F 416 865 6636 www.grllp.comthat are contrary to the client’s interest orinstructions given by the client.18In this case, prior to entering into anagreement to buy a residential property thebuyer noticed a large area in the backyardnear a septic system which was wet andsoggy despite the fact that it had not rained indays. The buyer discussed this situation withhis real estate and told him that he wantedto be able to get out any deal if there was aproblem with the septic system. Although thebuyer’s real estate agent inserted a broadlyworded inspection condition clause intothe offer to protect his client, the seller, ona counter-offer amended the clause to onlypermit the buyer an out where there were nostructural defects.A problem with the septic system did notconstitute a structural defect.The court found that the buyer’s agent neverbrought the change to his client’s attention,and thus committed an act of negligence. Inthe context of the case, the court found that:it was incumbent upon [the agent] notonly to show his client the change,but to specifically advise him thatthe inspection clause had beenfundamentally altered. He should alsohave specifically explained to him thatthis amendment could mean that hemight not be able to get out of thedeal even if the inspection disclosed aproblem with the septic system.19In Wong v. 407527 Ontario Ltd.20 thepurchasers of a commercial building suedtheir real estate agent for failing to negotiateadequate security for a warranty on rentalincome given by the vendor, a numberedcompany. While the agent had included aclause that warranted the gross rental ofthe income from the property for the year tobe a specific amount, in the year followingclosing the buyers had lost rental income. Thebuyers turned to the numbered company forcompensation, but the numbered companywas unable to satisfy the warranty.

The court concluded that the buyer’s agentshould have recognized the special risk posedby contracting with a numbered company.The agent should have explained the dangerof accepting an unsecured warranty from theseller and sought instructions from the buyersto try to obtain security.21 By failing to do anyof these things, the conduct of the agent fellbelow the requisite standard of care.Unlike a claim for breach of contract, a claimin negligence is not hampered by the issue ofprivity of contract. Accordingly, a listing agentcan be held liable for negligence or negligentmisrepresentation to a buyer even though heor she is not considered to be thebuyer’s agent.In Paglia v. Triolet22 a listing agent was heldliable for negligent misrepresentation to abuyer even though it was determined thatthe buyer was not his client. The facts of thiscase showed that when listing two vacantlots for sale, the listing agent posted a signon the lots which stated that they were “fullyserviced”. With respect to hydro servicing,the listing agent had made this determinationindependently by viewing the immediateneighbourhood and noticing that hydropolls ran across the front of the lots andthat adjacent homes were serviced fromthese polls.The buyer, who purchased the lots withoutthe benefit of an agent, relied on this signto enter into an agreement of purchase andsale. However after constructing a home onone of the vacant lots, the buyer discoveredthat hydro service thereto could only beobtained by running a line some distanceaway from the lot. The cost of this line wasover 10,000.In finding that the listing agent was liable fornegligent misrepresentation the court foundthat pursuant to the REALTOR Code, thelisting agent owed a duty of care to prospectivebuyers and that the statement made on theagent’s sign was inaccurate and misleading.Furthermore, the buyer reasonably relied onthe sign and suffered damages.GARDINER ROBERTS LLPBay Adelaide Centre – East Tower22 Adelaide St. W, Suite 3600, Toronto, ON M5H 4E3T 416 865 6600 F 416 865 6636 www.grllp.comWith respect to whether the listing agentspecifically committed an act of negligence,the judge found that the agent had a clearobligation to ensure that the advertising wasaccurate and to avoid misrepresentation.Moreover, the manner by which the listingagent reached the conclusion that the lotswere “Fully Serviced” was negligent. Theagent had not been told that the lots werefully serviced, and he never made inquiriesto verify what services to the lot wereimmediately available.Claims against agents by buyersAlthough there appear to be more instanceswhere buyers sue real estate agents fornegligence, sellers have also successfullybeen able to sue their listing agents in tort.In Krawchuk, for example, the courtdetermined that sellers who had madenegligent misrepresentations in their SPISand were accordingly liable to the buyers,had a valid negligence claim of their ownagainst their agent. They alleged that whencompleting the SPIS, the listing agent hadfailed to provide them with adequate adviceconcerning their obligations to complete it.The court agreed.As a basic proposition, the court stated that areal estate agent has duty to provide a certainlevel of guidance when a client is filling outor receiving a property disclosure statement.Such guidance includes warning the sellerthat an SPIS may be providing informationthat the seller is not legally obligated toprovide. Further, if the seller chooses tocomplete an SPIS, the agent must emphasizethe importance of providing information thatis complete and accurate. Where the agentplays a role in the completion of the SPIS, theagent must exercise reasonable care and skillin ensuring its accuracy.23The listing agent was held liable to the sellersin this case because the agent had beenput on inquiry about structural defects inthe house, yet did nothing to question themfurther about those issues. She also failed toappropriately counsel the sellers with respect

to the implications of the representationsmade in the SPIS.In Lovell v. Century 21 Dome Realty Ltd.24 thecourt held that a listing agent was liable innegligent misrepresentation to his seller clientby insisting that the seller’s home was wortha certain value, which was below its actualvalue. While the seller had asked to list hisproperty for 40,000, the agent asserted thathe would never get that price and that therewas not a hope. As a result, the property waslisted for 34,900, and sold for 34,000.Less than three months later, the listingagent marketed the property for sale again.However this time, without evidence that theproperty had been renovated, the listing pricewas 49,900. It sold for 42,500.The court found that the listing agent knewabout the property values and that it wasincumbent upon him to fully explain the lowvalue of 30,000. Yet, he was unable todo so with any evidence. The court furtherfound that if the listing agent had not madehis representations about the value of theproperty, which were relied upon by the seller,the seller would have listed it for much morethan 34,900 and sold it for morethan 34,000.In the circumstances, the court questionedwhether the listing agent was really workingfor the buyer and re-seller rather than theoriginal homeowner.25The facts in Lovell are disturbing, particularlyat a time of hot real estate markets wherehomes are bought and sold at a rapid paceand the listing of a property attracts multipleoffers. Rogue agents can certainly profit inthis kind of market. Indeed, recently the B.C.government has opened an investigationinto how real estate agents in Vancouver areprofiting from speculation. According to aninvestigation conducted by the Globe andMail, real estate agents and speculators aremaking significant profit, flipping Vancouverarea homes, by finding buyers willing topay more for properties before deals close.GARDINER ROBERTS LLPBay Adelaide Centre – East Tower22 Adelaide St. W, Suite 3600, Toronto, ON M5H 4E3T 416 865 6600 F 416 865 6636 www.grllp.comThrough a series of contract assignments,the last buyer takes over the contract andpays more than the original seller receives.Meanwhile real estate agents and otherspeculators are making millions.26 As will bediscussed below this kind of conduct on thepart of a real estate agent may attract liabilityfor breach of fiduciary duty.BREACH OF FIDUCIARY DUTYAs a matter of law, the relationship betweena real estate agent and his or her clientattracts fiduciary obligations. Indeed, it iswell-recognized that the relationship ofprincipal and agent is presumed to carrywith it such obligations.27The presumption is rebuttable, and thereforein assessing in any given case whether a realestate agent stands in a fiduciary relationshipwith a client a court will examine certaincharacteristics, including whether:1. the fiduciary has scope forthe exercise of some discretionor power;2. the fiduciary can unilaterallyexercise that power or discretionso as to affect the beneficiarieslegal or practical interests; and3. the beneficiary is peculiarlyvulnerable to or at the mercy ofthe fiduciary holding the discretionor power.28As stated in Valiquette v. Re/MaxRealty Specialists,Even though real estate agents fallwithin the traditional category offiduciaries in their relationships withvendors, one cannot characterize alllegal claims arising out of their legaldealings with the vendor as a breachof fiduciary duty [s]ome actions maylegitimately trigger claims of breach offiduciary duty, while others will liein negligence.29It has further been noted that the cases inwhich fiduciary duties have most often beenfound in this area of law occur when an agent

acts for both the vendor and the purchaser.In an article about the duties of real estateagents, now Justice Perell wrote:[T]he situation [of dual agency] isinherently problematic for the agentbecause of his or her contract,tort, and fiduciary obligations owedsimultaneously to both the vendor andthe purchaser. An obvious problem isthat a dual agent has two masters, whothemselves have conflicting aims – thevendor to maximize his purchase price,and the purchaser to minimize it – andtherefore it may be impossible for theagent to properly serve and be loyal toboth masters. Another obvious problemof dual agency is that they may beconflicts between the fiduciary’s dutiesto keep confidences and his or her dutyto disclose information. Typically thecompeting parties would like to keeptheir own confidential informationsecret while obtaining disclosure oftheir rival’s information.30CLAIMS MADE BY VENDORSAs stated above, the most obvious case inwhich a vendor might have a claim for breachof fiduciary duty against his or her agentis where the vendor’s property is “flipped”shortly after sale and the vendor’s real estateagent makes an additional commission or,potentially a profit.In D’Atri v. Chilcott31, the court stated:1. that the relationship between a realestate agent and the person whohas retained him to sell his propertyis a fiduciary and confidential one;2. that there is a duty upon such anagent to make full disclosure of allfacts within the knowledge of theagent which might affect the valueof the property;3. that not only must the price paid beadequate but the transaction mustbe a righteous one and the priceobtained must be as advantageousto the principal as any otherGARDINER ROBERTS LLPBay Adelaide Centre – East Tower22 Adelaide St. W, Suite 3600, Toronto, ON M5H 4E3T 416 865 6600 F 416 865 6636 www.grllp.comprice that the agent could, bythe exercise of diligence on hisprincipal’s behalf, have from a thirdperson; and4. that the onus is upon the agent toprove that those duties have beenfully complied with.32In circumstances where a listing agent isinvolved in the purchase of his or her client’sreal estate, and then flips the property it isarguable that such a transaction may not be“righteous one”.In Phelan, the court, in rejecting a breachof fiduciary duty claim against an agent,essentially highlighted the “red flags” thatshould be looked for when assessing whethera vendor has a claim against his or heragent for breach of fiduciary duty in thefollowing passage:Although breach of fiduciary duty hasbeen alleged, no one has suggestedthat Realty World, or Allen and Cirillo(the agents), had any conflict of interest,or put their own interests ahead of theinterests of the Phelans (the sellers).There is no evidence of a secretcommission or secret profit. There isno evidence of any special relationshipbetween Realty World and the Archers(the buyers). There is no evidence thatthe Archers “flipped” the property fora profit, or even that the Archers haveresold the property at all. There isno suggestion that the Phelans wereoperating under any disability, or didnot understand the bargain they made.There is no evidence that Mr. Allenor Mr. Cirillo used any high-pressuresales tactics, behaved unethically, orexerci

a real estate agent in another set of unique factual circumstances. Based on the foregoing, the purpose of this paper is to highlight the main causes of action that are usually brought against real estate agents and to identify some of the most common themes in which courts have held real estate agents liable. In highlighting

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