Thank you for the opportunity to comment.  

The new language in 18VAC48-50-15 (A) Necessity for licensure of firms and certification of employees seems to highlight the available exemptions under § 54.1-2347 from CIC Manager licensing requirements.  

1. Is it the CIC Boards intent to further highlight the exemptions available under § 54.1-2347?
2. If yes, as it applies to § 54.1-2347. (A)(9), is it the intent of the Board to further highlight the exemption for "firms" (further real estate brokerage firms)?
3. If not, is it the intent of the Board to require duly licensed real estate brokerage firms, brokers, and salesperson to also be licensed with the CIC Board when providing management services to CIC's? 
4. Will the CIC Boards enforcement standards for firms who are required to be licensed change  if/when the new regulations take effect?