The core principles
| Principle | What it means in practice |
|---|---|
| Integrity & honesty | Act truthfully; don't misrepresent property facts or client positions |
| Competence | Practise within your skill / training; refer out matters beyond your competence |
| Confidentiality | Keep client info private; don't disclose to other party or third parties without consent |
| Diligence | Respond promptly; chase essential approvals; don't delay client's transactions |
| Material facts disclosure | Disclose known defects, encumbrances, your interests, third-party fees |
| Conflict of interest | Avoid acting for both sides without informed written consent; declare related-party interest |
| Dispute handling | Take complaints seriously; refer to EA's complaints process; cooperate with CEA inquiries |
| Lawful advertising | Identify EA + RES; truthful claims; comply with ASAS; no bait ads |
| Document retention | Maintain records for 5 years (PMLPFTF) or as CEA prescribes |
| PMLPFTF compliance | CDD on clients; STR if suspicious; tipping-off prohibited |
Disclosure of material facts
The duty to disclose material facts is one of the most-tested CEPCC principles in both real practice and the RES exam. Material facts include:
- Physical defects of the property known to the RES (leaks, structural issues, infestations)
- Adverse history (suicide / unnatural death within recent years, if known)
- Pending en-bloc, conservation status, planning restrictions, illegal alterations
- The RES's or EA's personal interest in the property
- Commissions or referrals received from third parties
- Conflicting representation (RES acting for both buyer and seller)
- Outstanding tax / fees owed by the seller on the property
Failure to disclose a known material fact is a CEPCC breach and may also expose the RES to civil liability for misrepresentation or negligence.
Avoiding conflicts of interest
The CEPCC requires RES to actively avoid conflicts. Common scenarios:
- Dual representation — acting for both buyer and seller. Requires explicit, written informed consent from both parties.
- Self-interest transaction — buying a property listed with your EA. Must disclose to seller; ideally arms-length and supervised.
- Family / related party — recommending a property where you or family have an interest; required disclosure.
- Secret commissions — receiving payment from a lender, lawyer, or developer beyond what you disclosed to client. Always prohibited.
- Co-broke disputes — engaging another RES to share commission without proper agreement.
Advertising and marketing
CEPCC sets standards for property advertising:
- Identify the EA name and licence number; identify the RES name and registration number.
- All material claims (price, size, view, etc.) must be accurate and verifiable.
- No bait advertising — i.e. listing properties not actually for sale to lure enquiries.
- Comply with the ASAS Code (truthful, legal, honest, decent).
- Online listings (PropertyGuru, 99.co, etc.) must include same identification info.
- Photographs must accurately represent the property — not from other units, not heavily altered.
PMLPFTF — anti-money-laundering
The Prevention of Money Laundering and Prevention of Financing of Terrorism (PMLPFTF) regime requires every RES to:
- Carry out Customer Due Diligence (CDD) on every client — verify identity, residence, source of funds.
- Conduct Enhanced Due Diligence (EDD) for high-risk clients (e.g. PEPs, jurisdictions on FATF watchlist).
- File Suspicious Transaction Reports (STR) to the Suspicious Transaction Reporting Office (STRO) when suspicious activity is detected.
- Not tip off the client about an STR being filed.
- Maintain records for at least 5 years.