24. Fraudulent Act v. Fraudulent Practices

156 DOS 92 Matter of Gotshall - Landlord not advised of payment, which tenant thought was additional rental payment, but broker kept as additional fee for assisting in securing cooperative's approval of subtenancy (i)fraudulent act = misrepresentation of material fact with intent to deceive consumer reliance and injury; (ii)fraudulent practice does not require intent to defraud Revocation and restitution, if broker ever reapplies

6 DOS 93 Matter of Cornell Associates Realty -broker/developer retains deposit despite failure to produce contract indicating that broker/developer had countersigned change of buyer's contract to new address - misled buyer to believe she had binding agreement

47 DOS 93 Matter of DOS v. Jackson - forgery and false notarization; professional misconduct is necessarily a fraudulent practice

5 DOS 94 Matter of DOS v. Gafni - fraudulent practice in retaining $5,000 payment when only obtained consumer credit report; did not obtain appraisal; improper extraction of mortgage brokerage commission when the predicate mortgage commitment was not forthcoming; corporation is vicariously responsible for actions of its representative broker; representative broker and corporation each fined $1,000 plus order of restitution of $17,400 less cost of credit report

1 DOS 94 Matter of ERA Faza Realty - DOS is not divested of jurisdiction by voluntary surrender of license or expiration of license if action occurred while licensed, while an applicant for a license, or while eligible to automatically renew per RPL §441(2); requirement of informed consent to dual agency; concealment, misrepresentation and failure in seeking to purchase for own account (2 transactions arranged - sale to licensee and resale at profit to customer, who was qualified for mortgage, but who seller was told had failed to qualify); disgorge profit and commission; fee not related to performance of legitimate service; representative broker must be corporate officer and is vicariously liable for wrongful act of associated salesperson under RPL §442-c; restitutionnot attributed to corporate broker where no proof that funds illegally obtained were collected by or in any way benefitted the corporation; DOS has no power to assess damages; representative broker not required to supervise another representative broker and not liable for misconduct of another representative broker who meets test of RPL §442-c; complaint dismissed as to other representative broker

96 DOS 94 Matter of DOS v. Demasi - failure to use RPL §443 disclosure notice for sales or rentals of 1-4 family house (33 rentals); reliance on MLS form no defense to or excuse for not using form in rental transactions; broker presumed to know the law; lack of knowledge, unlawful motive or fraudulent intent considered in assessing sanction; $500 fine

CRC #586 Matter of DOS v. Sbarra, Consent Order - falsifying information in applying for mortgage; misrepresentation by omission of disqualifying information; invasion of client escrow accounts; commingling escrow deposits; forgery; 6-month suspension and fine of $10,000; upon timely payment, complaint in this matter and other matter (CRC #309) withdrawn and discontinued without prejudice

113 DOS 94 Matter of Carroll - DOS has jurisdiction to determine fraud or fraudulent practice or untrustworthiness and incompetence as to activity which could be violation of other law, such as Labor Law; no jurisdiction of respondent who was unlicensed when alleged unlawful acts occurred and not licensed when notice of hearing and complaint served; DOS fails to prove fraud or misrepresentation in disclosure notices; failure to prove time correlation of work as salesperson and collection of unemployment insurance; failure to prove false statement to collect unemployment insurance; fraudulent practice doesn't require intent; General Business Law §349(a) deceptive act or practice; failure of proof of violation of RPL §443(e)(5)

117 DOS 94 Matter of Fried - fraudulent practice in procuring loan from client, to be repaid out of commission when transaction closed; failure to disclose outstanding debts owing to broker for commission advances previously received; inability to repay is no defense; restitution not available in licensing proceeding, it is incidental to primary purpose of licensing; application for renewal denied

14 DOS 95 Matter of Myers - broker who assists buyer in obtaining mortgage on other property to facilitate down payment is agent of buyer; broker is seller's agent in purchase transaction; as buyer's agent, depositing of down payment in his operating account violates 19 NYCRR §175.1; as seller's agent, depositing in operating account does not violate 19 NYCRR §175.1; conversion of deposits, but no proof of grand larceny as no proof to permanently deprive; fraudulent practices in failing to forward deposit; where only commission is for mortgage, no proof of unearned commission; vicarious liability of corporate licensee for acts of representative broker; restitution of money to which not entitled, with interest

15 DOS 95 Matter of Gafni - jurisdiction of DOS; deposit money continues to be property of prospective buyer until contract condition is achieved; unlawful retention is larceny; fraudulent practice of illegal retention of deposits, but no proof of criminal intent essential to prove fraud; failure of proof of retention of unlawful commission; vicarious liability of corporation for acts of representative broker; no authority to award damages; restitution with interest is required ($2,500; $3,000; $1,250 and $2,500)

24 DOS 95 Matter of Seplow - disciplinary charge jurisdiction where licensee's renewal has been previously denied; proof of service of process; agency relationship and duties; fraud in sale of cooperative apartment, including false information about particular sale and willful non-disclosure of material information; failure to obey buyer's obvious intent to have deposit treated as funds to be held in escrow as payments to seller; conversion; rules applicable to supplemental pleadings - absent surprise or prejudice, motion to file and serve could be granted on day of hearing, but here respondent doesn't appear, so supplemental complaint dismissed without prejudice; DOS fails its burden of proof as to extortion and retention of unlawful commission and unauthorized practice of law; when respondent became optionee to purchase subject matter, agency relationship ceased to exist; fiduciary duty precludes respondent from acting simultaneously as agent and principal in a transaction; restitution of $35,000 deposit plus interest at legal rate for judgments

47 DOS 96 Matter of DOS v. Maneri - felony conduct; pleadings amended to conform to proof; notarization; participation in scheme to fraudulently convey real property demonstrates untrustworthiness; it is irrelevant that licensee's actions were not within scope of activities as licensee where such actions clearly indicate licensee cannot deal fairly with the public; renewal of license after DOS learned of licensee misconduct does not collaterally estop DOS action to revoke or suspend license; Correction Law Act 23-A applies only to applications and not actions by DOS to suspend or revoke license; notary public acts unlawfully when he notarizes a document without the purported signatory being present; felony conviction bars commission as notary public in absence of executive pardon or Certificate of Good Conduct; broker's license revoked; notary commission revoked

242 DOS 97 Matter of DOS v. Hinds - deposits; proper business practices; fraudulent practices; due process; exparte proceeding is proper where there is evidence of proper service of process; unlawful retention of deposit monies constitutes larceny; illegal exercise of right of ownership over principals’ funds is conversion; broker’s illegal retention of deposit monies of principals in four, separate real estate transactions is a fraudulent practice; broker’s failure to pay lawfully obtained judgments without a showing that he is unable to do so is a demonstration of untrustworthiness; license revocation; restitution with interest

247 DOS 97 Matter of DOS v. Abreu Realty - dual agency; deposits; fraudulent practice; vicarious liability; broker illegally acted as dual agent without full disclosure and informed consent of buyer and seller in a regulated real estate transaction; broker required to maintain separate, special bank account for the deposit of escrow funds (19 NYCRR 175.1); broker commingles client funds; refusal to return escrow funds constitutes larceny; illegal exercise of right of ownership over principal’s funds is conversion; broker’s failure to establish escrow account, commingling of client funds and illegal retention of escrow monies constitutes fraudulent practice; corporate broker is vicariously liable for the acts of a corporate officer where there is actual knowledge of the misconduct and after notice thereof, the corporate broker retains the benefits, profits and proceeds of the transaction; revocation of corporate broker’s license and representative broker’s license

274 DOS 97 Matter of DOS v. Fee - due process; laches; fraudulent practice; duty to supervise sales associates; disclosure of agency relationships; vicarious liability; DOS is not estopped from proceeding with investigation after issuing letter to broker advising that DOS was contemplating no further action and was closing the file; broker’s defense of laches fails where broker fails to establish substantial prejudice arising out of the delay; DOS fails to establish salesperson’s conduct was a fraudulent act where, although salesperson knew representations were false and she intended purchasers to act on the misrepresentation, DOS failed to establish that purchasers detrimentally relied on misrepresentations; salesperson engaged in fraudulent practice by making misrepresentation to purchasers (salesperson misrepresents reasons for previous purchasers not going forward with transaction); DOS fails to establish violation of RPL §443 by failing to establish that disclosure form presented in evidence was the disclosure form related to the sale of the subject property; inconsistency in complaint is immaterial where complaint gives respondent sufficient notice of the charges; corporate broker and representative broker demonstrated incompetency by employing unlicensed associate broker; representative broker’s reliance on unofficial lists of licensees supplied by County Board of Realtors is misplaced and demonstrates incompetency; representative broker and corporate broker are vicariously liability for misconduct of salesperson and associate brokers where they have actual knowledge of the misconduct; commission arising out of unlicensed activity of associate broker is unearned; corporate broker and representative broker fined $1,000.00 and directed to disgorge commission of $6,125.00, plus interest; salesperson fined $1,000.00; unlicensed associate broker fined $500.00 and directed to disgorge unearned commission of $6,125.00, plus interest

287 DOS 98 Matter of DOS v. Uqdah Realty & Management Corp. -- deposits; jurisdiction; fraudulent practices; failure to pay judgment; vicarious liability; notary public; disclosure of agency relationship; broker violated 19 NYCRR 175.1 when he deposited escrow funds into his operating account; broker committed conversion when his operating account fell below deposit amount; broker engaged in fraudulent practices when he illegally retained buyer’s trust funds and attempted to qualify prospective buyer for mortgage by falsely stating their employment; broker failed to disclose his agency relationship to his client; failure to pay judgment; corporate real estate broker vicariously liable and charged with actual knowledge of violation of law because of representative broker’s cognizant misconduct as corporate officer; broker is not required to deposit a refundable commission in an escrow account unless contractually demanded; corporate broker and representative broker’s license revoked; restitution of deposit of $12,000 plus interest; notary public commission revoked based on misconduct as a real estate licensee

CRC #95-0532 Matter of DOS v. Vaccarielli, Consent Order -- broker engaged in fraudulent practices where he represented to one party that he was the owner and landlord of property when he was not and represented to another party property did not contain a swimming pool when in fact it did; 1 month suspension of broker’s license and restitution to each party in the amounts of $521 and $979

122 DOS 98 Matter of DOS v. Hazor -- proper business practices; sales associate as officer of company; corporate broker dissolved by proclamation may only carry on business required for winding up its affairs; engaging in licensed activity and submitting license renewals after dissolution by proclamation constitutes fraudulent practices; failure to comply with DOS request to appear and for production of documents along with failure to comply with subpoena violates RPL §442-e (5); licensed salesperson violates RPL §441-b(2) when he serves as an officer of the corporation; brokers and salesperson’s licenses revoked

314 DOS 98 Matter of DOS v. Eng - due process; failure to appear at hearing; accounting to client; bad checks; fraudulent practice; ex parte hearing is permissible upon proof of proper notice of hearing; broker acting in capacity as managing agent for a rental building violated 19 NYCRR 175.2 and engaged in fraudulent practice when he failed to account to his principal for money collected; issuance of bad checks pursuant to settlement agreement demonstrates untrustworthiness and incompetency; failure to respond to or claim from post office letters from investigator constitutes failure to cooperate with DOS investigation; broker’s license revoked, reapplication conditioned upon proof of payment of restitution with interest

27 DOS 99 Matter of DOS v. Finke - fraudulent practice; dual agency; unearned commission; broker became principal and agent in same transaction when broker agreed to be co-mortgagee on a first mortgage on sale of seller client’s property; broker fails to make proper disclosures regarding implications of his acting as both agent and principal in the same transaction; broker fails to disclose material information to the seller client regarding adverse financial condition of purchaser; broker engaged in fraudulent practice by placing his interests (as first mortgagee) ahead of those of his seller client, when he failed to advise his client that his prior advice that client’s second mortgage could be sold was inaccurate; misconduct so changed the transaction as to eliminate any entitlement to commission; broker’s license is suspended for six months plus further suspension until broker submits proof of refund of $3,500.00 commission plus interest

79 DOS 99 Matter of DOS v. Pagano - disclosure of agency relationships; failure to appear at hearing; proper business practices; unauthorized practice of law; unearned commissions; vicarious liability; fraudulent practice; jurisdiction; ex parte hearing may proceed upon proof of proper service; DOS has jurisdiction after expiration of respondents’ licenses as acts of misconduct occurred and the proceedings were commenced while the respondents were licensed; licensee fails to timely provide seller client with agency disclosure form prior to entering into listing agreement and fails to timely provide agency disclosure form to buyer upon first substantive contact; broker fails to make it clear for which party he is acting; broker violates 19 NYCRR 175.24 by using exclusive right to sell listing agreement without mandatory definitions of “exclusive right to sell” and “exclusive agency”; broker breaches fiduciary duties to seller clients by misleading them as to buyer’s ability to financially consummate the transaction; broker breaches his fiduciary duty to seller by referring seller to the attorney who represented the buyers when he knew or should have known such attorney could not properly protect seller’s interests; improper for broker to use listing agreements providing for broker to retain one half of any deposit if forfeited by buyer as such forfeiture clause could, by its terms, allow broker to retain part of the deposit when broker did not earn a commission; broker must conduct business under name as it appears on license; broker engaged in the unauthorized practice of law in preparing contracts for purchase and sale of real estate which did not contain a clause making it subject to the approval of the parties’ attorneys and were not a form recommended by a joint bar/real estate board committee; broker demonstrated untrustworthiness and incompetency in using sales contract which purported to change the terms of the listing agreement to include a higher commission; broker demonstrated untrustworthiness and incompetency in using contracts of sale which were unclear, ambiguous, vague and incomplete; broker failed to amend purchase agreement to reflect amendment to increase deposit amount; broker demonstrated untrustworthiness in back-dating purchase agreements; broker demonstrated untrustworthiness in participating in scheme to have seller hold undisclosed second mortgage and to mislead first mortgagee about the purchaser’s financial ability to purchase; broker demonstrated untrustworthiness by claiming unearned commission and filing affidavit of entitlement for unearned commission; DOS fails to establish by substantial evidence that respondent acted as undisclosed dual agent; corporate broker bound by the knowledge acquired by and is responsible for acts committed by its licensees within the actual or apparent scope of their authority; corporate and individual brokers’ licenses revoked, no action taken on application for renewal until proof of payment of sum of $2,000.00 plus interests for deposits unlawfully retained

83 DOS 99 Matter of DOS v. Dhanraj - failure to appear at hearing; fraudulent practices; prior misconduct; forgery; unlicensed activity; ex parte hearing is permissible upon proof of proper service; conviction of felony (larceny in conducting real estate transactions) bars licensure as salesperson where no proof licensee has been granted an executive pardon, a Certificate of Relief from Disabilities, or a Certificate of Good Conduct; licensee engaged in fraudulent practices by brokering transactions without the knowledge of his supervising broker and defrauding clients out of deposit money; unlawfully holding self out to be a real estate broker without first procuring a license therefore; use of a forged license is an aggravating factor; DOS fails to prove licensee conducted a regulated real estate transaction while not licensed to do so; salesperson’s license revoked

13 DOS 01 Matter of DOS v. Parkin - forgery; fraudulent practices; jurisdiction; mortgage application; notarization; licensee demonstrates untrustworthiness by causing a deed bearing a forged signature to be recorded; licensee demonstrates untrustworthiness and incompetency by using various social security numbers other than his own on various documents prepared by him including license application, mortgage application and various bankruptcy petitions; failure to cooperate with DOS investigation by failing to supply requested and agreed to documents and lying to investigator about his knowledge of a fraudulent notary public; DOS retains jurisdiction where, although license has expired, two applications are pending, one for renewal and one for a new license; broker’s license revoked and pending applications denied

481 DOS 01 DOS v. Harris - deposits; failure to appear at hearing; failure to cooperate with DOS investigation; fraudulent business practice; jurisdiction; notary public; unearned commissions; ex parte hearing may proceed against non-appearing respondent upon proof of proper service; in the absence of an agreement to the contrary, rental broker is entitled to compensation only after procuring a rental agreement between tenant and landlord; broker fails to deposit $950.00 lease deposit in special escrow account; broker commingled funds and converted deposit; broker failed to cooperate with DOS investigation by failing to truthfully answer all questions put to him, by providing DOS with misleading statements and by failing to provide requested documents; providing DOS with untrue and misleading statements indicates broker lacks sufficient honesty to be entrusted with duties of a notary public; DOS fails to prove that broker was unauthorized to show apartment; DOS retains jurisdiction after license expires where renewal may be had merely by submitting application and paying applicable fees; the claim of the right to retain and the retention of an unearned commission is a fraudulent business practice; broker receiving money to which he is not entitled may be required to return it; broker fined $1,000.00 and required to refund $950.00 deposit; broker’s commission as a notary public revoked; charges against non-appearing salesperson dismissed for DOS’s failure to provide proof

103 DOS 02 DOS v. Cheng – fraudulent business practice; vicarious liability; failure to appear at hearing; ex partehearing may proceed upon proof of proper service; broker charged in indictment of committing criminal offenses directly relating to fitness to perform duties as a real estate broker; reasonable cause exists to believe broker committed criminal offenses charged by virtue of grand jury indictment; broker charged with defrauding HUD in a mortgage fraud scheme; corporate real estate broker charged with actual knowledge of and is vicariously liable for representative broker’s cognizant misconduct as a corporate officer; broker’s license revoked

734 DOS 01 DOS v. Turyan - disclosure of agency relationships; business broker; a transaction that consists of negotiations and subsequent purchase of a business does not involve a regulated real estate activity; agency law forbids a fiduciary from acting concurrently as an agent for the seller and as the principal-buyer of the subject matter of the agency; agent must terminate the agency relationship before assuming the role of buyer of the subject matter of the agency; seller’s agent breaches fiduciary duty of confidentiality by disclosing to the buyer the price that the seller would accept below the asking price; broker misrepresents material existing facts which constitutes fraud; concealment of information which broker has a duty to communicate is misrepresentation when done with intent to defraud; where broker committed a fraudulent act, the broker necessarily engaged in a fraudulent practice; DOS fails to prove that broker engaged in forgery; Real Property Law §443 does not apply to a lease of commercial property or to a transaction that does not involve a regulated, real estate activity; brokers license revoked

2 DOS APP 02 Matter of Turyan v. DOS - decision of administrative law judge upheld where broker violated numerous fiduciary duties including advancing her own interests above those of her client, negotiating a contract to buy her client’s business without their permission and failing to disclose material facts relating to the sale of a business; brokers license revoked

315 DOS 03 DOS v. Brady – appraisers; fraudulent practices; broker misrepresented his status as either licensed or certified as a real estate appraiser; broker compounded his misconduct by breaching his fiduciary duties of honesty and full disclosure by misrepresenting his status as either licensed or certified as a real estate appraiser on appraisals and invoices; such conduct constituted fraudulent practices; broker’s license revoked

714 DOS 03 DOS v. Podolsky - fraudulent practice; unearned commission; vicarious liability; listing broker breached its fiduciary duties to its client when, in a flip transaction, the listing broker either misrepresented who the purchaser was or, when without clearly disclosing that the original purchasers were out of the picture, that the purchaser was substituted with a non-licensed corporate entity which was solely owned by the representative broker and that the unlicensed entity wished to assume the benefit of the bargain of the original purchaser; after obtaining a contract to purchase the listed property and after having advertised the property for resale, broker advised his client that the property was worth significantly less than its true value and what the broker resold the property for; corporate broker is responsible for the acts committed by its representative broker; corporate broker’s license and representative broker’s license suspended for three months

818 DOS 03 DOS v. Phifer - fraudulent practices; commission issues; forgery; associate broker commits gross act of dishonesty and commits fraudulent practice by attempting to steal a commission from her broker; departing associate broker who is going to set up her own firm advises salesperson not to inform broker of pending transaction and forges broker’s signature in an attempt to have commission check paid to her new firm; broker’s license revoked

515 DOS 05 DOS v. Duroseau - failure to appear at hearing; fraudulent business practices; deposits; commissions; unlicensed activity; disclosure of agency relationships; jurisdiction; DOS retains jurisdiction where alleged unlawful acts occurred during licensure and where after license expired licensee was eligible to automatically renew his license; salesperson engaged in fraudulent business practices by failing to refund deposit monies to a principal, illegally retaining deposit funds, retaining an illegal commission, failing to provide agency disclosure form to principal and by acting as an unlicensed real estate broker; DOS fails to prove non-cooperation with investigation where salesperson submitted two written responses to DOS’s requests; salesperson ordered to refund $2,300.00 plus interest, any future application for licensure will not be considered until refund made

711 DOS 05 DOS v. All Island Estates Corp. - availing of license; duty to supervise sales associates; fraudulent practice; unlicensed activity; motion to dismiss at conclusion of DOS case; post hearing submissions; DOS charges corporate broker and representative brokers with unlicensed activity, availing of broker’s license to salesperson, employing and authorizing unlicensed persons to engage in regulated real estate activities and failing to properly supervise associated salespersons; broker’s motion to dismiss the proceeding on the close of complainant’s case for failure to prove the essential allegations of the complaint is dismissed and hearing continues; DOS fails to prove by substantial evidence the allegations made in the complaint; complaint dismissed.

719 DOS 05 DOS v. Choi - forgery; fraudulent practices; unlicensed activity; salesperson forged buyer’s name on two binders and repeatedly lied about the forgeries to DOS’s investigator; salesperson appeared at closing and asked the seller’s attorney to issue her a check for her share of the listing broker’s commission directly from the seller’s proceeds; salesperson acted and held herself out a real estate salesperson after her license had expired and prior to it’s renewal; salesperson engaged in fraudulent practices; salesperson’s license revoked.

956 DOS 06 DOS v. Maneri- listing and advertising of home in violation of local zoning; failure to disclose ownership interest; fraudulent practice defined; breach of fiduciary duty, untrustworthiness and incompetence, revocation; Realtor (LIBOR) ethics decision not considered as no showing whether hearing is fair and provided due process

1021 DOS 06 Matter of Godard – fraudulent practices, altered check, unlicensed corporation, restitution, 6-month suspension

591 DOS 07 Matter of Noonan- salesperson application for broker license denied; false and fraudulent documentation, forgery of essential signature; involvement in unlicensed brokerage business while unlicensed; failure to prove sufficient creditable experience; failure to cooperate

1163 DOS 07 Matter of Posa- Broker; fraudulent advertisement; false statement on renewal; failure to reveal revocation of insurance license; false advertisement stating a NYS broker is associated with ads without broker consent; fraudulent inducement to make deposits; failure to refund deposits; failure to pay judgment; commingling funds; untrustworthy action as insurance broker; tends to establish unfitness; revocation and requirement to pay judgment if ever reapplies for real estate license

1245 DOS 07 Matter of Jerome- Salesperson, forged signature of broker regarding qualifying experience on application for broker’s license and on change of association card; failure to cooperate with investigation; revocation

1343 DOS 07 Matter of Campbell-Appraiser Assistant; adjournment of hearing; request denied due to improper appraisal; fraudulent representation of being properly licensed, and failure to prove 1 year of lawful qualifying experience; applicant failed to appear and fails to meet burden of proof; certification denied

1517 DOS 07 Matter of Bizzari- Broker; fraud and breach of fiduciary duty re deposit; bad check; commingling (19 NYCRR §175.1) unauthorized demand for 50% down payment; fraud and misrepresentation as registered HUD agent; false statement that purchase would be owner-occupied; failure to disclose broker ownership interest in listed property (19 NYCRR 175.6); failure to deliver duplicate original (19 NYCRR 175.12); agency disclosure notice (RPL § 443[3][b]); use of unlicensed name (RPL § 440-a; 441 [1][a]); incompetency; revocation

1668 DOS 07 Matter of Anzalone- broker; failure to deal honestly and fairly even when not acting as agent; untrustworthiness in failure to make agreed payments; self dealing as broker entering into purchase agreement; insufficient evidence of other charges of impropriety and failure to list property; six months suspension

2206 DOS 07 Matter of Sir Winston Realty- fraudulent scheme involving “straw buyer”; breach of fiduciary duty; failure to disclose broker’s relationship with attorney and “investor”; fraudulent practice; DOS can consider licensee’s conduct as attorney in determining his fitness to be licensed; revocation; no future application until accounted for proceeds of sale.

2208 DOS 07 Matter of Kirkpatrick- broker; fraud and untrustworthiness; lied about tenant’s finances and reason for moving (cooperating broker had threatened to evict tenants from her property previously); revocation

2269 DOS 07 Matter of Dillon- broker; interim suspension; opportunity to appear with attorney; fraudulent practices; unauthorized transfer of title; unearned commission; revocation

1293 DOS 08 Matter of Delly – unlicensed activity; insufficient evidence of collection of commission; improper advertising 175.25; fraud re: compliance with building code; fraudulent practices

1294 DOS 08 Matter of Chimber – salesperson; forgery and falsifying business records; unlicensed activity; insufficient evidence of failure to provide RPL 443 notice; revocation

584 DOS 09 Matter of Sucuzhanay – failure to provide agency disclosure; fraudulent transaction; complaint dismissed

734 DOS 09 Matter of Hammer – fraudulent MLS information; revocation

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