18VAC135-20-10?Definitions.

• Under the definition of "Active" the term "in good standing" is not defined anywhere in the regulations.
• Under the definition of "contact information" the term " digital advertising" is not defined anywhere and could cause consumer/licensee confusion.
• "Moral turpitude" is defined and used in the regulations. New legislation enacted 7/1/25 prohibits using this term. 
• Under the definition of "principal to a transaction" the terms "assignor" and "assignee" have been added. An assignor legally transfers his/her rights to the assignee and would no longer be a principal. The assignee would effectively become the buyer. With the current confusion in the market over assigning real estate contracts and wholesaling, we think the addition of these two terms will only further confuse licensees and both terms should be removed from the definition.

18VAC135-20-30?Qualifications for?individual?licensure.

• Use of the term "moral turpitude" is now prohibited. 

18VAC135-20-165?Duties of supervising broker 

4. Respond in a timely manner to inquiries from the public, cooperating brokers, and licensees affiliated with the supervising broker’s firm regarding existing or contemplated transactions.

• This could cause consumer and licensee confusion and lead to a flood of complaints because someone took too long to return a phone call. It will be very difficult to enforce. Another option would be rewording to "Act with reasonable diligence and promptness in responding to . . ."

 18VAC135-20-170?Maintenance of licenses  

B. Discharge or termination of active status. 

• The language in 1. should be clarified to say that the termination is effective upon notification to the Board, not the processing. If there is a delay in the processing a licensee could be liable for continuing under a problem broker, or a broker could be liable if a problem licensee continues under their supervision.