These proposed revisions will not improve clarity of the regulations, will not ensure consistency with current board practices and legal requirements, and blatantly disregarded standards of practice in the industry. 

Just exactly what are the Real Estate Board Regulations found at 18 VAC 160-20?  The recent Small Business Impact Review was obligatory at best.  This Board has removed due process.

What should be even more insulting to the public is where the Assistant Attorney General appears to certify,

"The regulations do not appear, on their face, to conflict with
the Constitution of the United States or the Constitution of the Commonwealth of Virginia, nor do they appear to conflict with federal or state law currently in effect." 

Will the Attorney General ever review this proposed text to ensure it's written in a comprehensible manner, was authorized by statute, and can be certified consistent with other law?  If not, then why not? Who else will be consulted to determine there's no conflict with the Constitution of the United States or the Constitution of the Commonwealth of Virginia?  Will the Federal Trade Commission be contacted for an opinion? 

This Board is serving two masters as evidenced by the necessity and creation of two new chapters, while failing to eliminate the statutory and regulatory inconsistencies with § 54.1-2301 of the Code of Virginia.

Start over and stop aiding and abetting a regulation that no longer protects public health, safety, and welfare.