Competency Units 3.1 to 3.4 (Paper 2): the regulatory framework under the Estate Agents Act 2010 (EAA) and its regulations, professional practice and ethics, the role of a salesperson, and the obligations to prevent money laundering, proliferation financing and terrorism financing (PMLPFTF). Units 3.2 and 3.4 are new in the 2027 syllabus.
The Council for Estate Agencies (CEA) is a body corporate set up under the EAA to raise professional standards and protect consumers; it licenses estate agents (the businesses) and registers salespersons (natural persons only, registered through one estate agent that supports the application, and fit and proper). Each estate agent must have a key executive officer (KEO) who manages the business and supervises its salespersons. A new salesperson must have passed the RES examination within 2 years before registration and must keep up continuing professional development and the estate agent's professional indemnity insurance cover. Doing estate agency work without a licence or registration is an offence and the fee cannot be recovered. Estate agents must give CEA the prescribed transaction records, and CEA can investigate and discipline estate agents and salespersons (censure, financial penalty, suspension or revocation), with rights of appeal.
Salespersons convey offers promptly and accurately, explain the meaning and consequences of documents and give the client time to read them, do not ask clients to sign documents with material terms left blank, and put commission and bonus arrangements in writing. Claims in marketing must be justifiable by verifiable facts; guarantees of a sale price above valuation, touting and harassing tactics, and racial preferences in advertisements are not allowed. Co-broking terms are agreed in writing between the estate agents before the deal is closed, and each side collects commission only from its own client; a salesperson must not deal directly with a party represented by another salesperson without that salesperson's consent. Client data is handled under the Personal Data Protection Act 2012. The salesperson whose work is the effective cause of a transaction, not one who merely made an earlier introduction, is generally the one entitled to the commission. Information sources include the MCST for condominium matters and HDB InfoWEB or the Town Council for HDB estates.
Estate agents must have a process for handling complaints. CEA does not adjudicate fee claims or order refunds; disputes over commission and fees under the prescribed residential agreements go to the CEA Dispute Resolution Scheme: mediation first, then arbitration, at the Consumers Association of Singapore (CASE), the Singapore Institute of Surveyors and Valuers (SISV) or the Singapore Mediation Centre (SMC). A mediated settlement binds once it is put in writing and signed, and the dispute resolution process does not prevent CEA from taking disciplinary action.
Money laundering moves through placement, layering and integration; terrorism financing can use lawfully earned money; proliferation financing funds weapons of mass destruction. Singapore's framework (Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act, Terrorism (Suppression of Financing) Act, regulations under the United Nations Act, and the Estate Agents (PMLPFTF) Regulations 2021 with CEA's Guide and forms) follows the standards of the Financial Action Task Force. Before the option to purchase is issued, the salesperson carries out customer due diligence (CDD) on the client, identifying and verifying the client (for example by sighting the NRIC or using Singpass), any person acting for him and the beneficial owners of a company (the individuals who ultimately own or control it), and assesses the ML/PF/TF risk. Higher-risk clients, such as foreign politically exposed persons, require enhanced CDD, including checks on the source of wealth and source of funds and the approval of a designated officer of the estate agent; due diligence is also done on an unrepresented counterparty. Records are kept for at least 5 years. Where money laundering or terrorism financing is suspected, the salesperson stops the deal, tells the estate agent and files a suspicious transaction report (STR) with the Suspicious Transaction Reporting Office: reasonable grounds to suspect are enough, even if the deal never completes, and tipping off the client is an offence.
1. What are the two main aims of the regulatory framework set up under the Estate Agents Act 2010 (EAA)?
The EAA protects consumers' interests and raises the professionalism of the real estate agency industry; the syllabus describes a framework that raises professional standards and safeguards consumer interests. Price and foreign-buyer controls are cooling measures and Residential Property Act matters, developers are licensed under the Housing Developers (Control and Licensing) Act, and the CEA does not set commissions. (CEA, Legislation page; RES Examination Syllabus 2027, Competency Unit 3 overview)
2. Who made the Estate Agents (Estate Agency Work) Regulations 2010, which contain the Code of Ethics and Professional Client Care and the Code of Practice for Estate Agents?
The Regulations were made by the Council for Estate Agencies under sections 42, 44 and 72 of the EAA, with the approval of the Minister for National Development. They are subsidiary legislation, not part of the Act passed by Parliament, and every licensed estate agent and registered salesperson must comply with the CEPCC set out in their First Schedule (reg. 3). (Estate Agents (Estate Agency Work) Regulations 2010, enacting words and regs 3-4)
3. Part 2 of the Estate Agents Act 2010 establishes the Council for Estate Agencies. Which statement correctly describes the legal status of the CEA?
Section 6 establishes the Council for Estate Agencies as a body corporate with perpetual succession, capable of suing and being sued, of holding and disposing of property and of doing the other acts that bodies corporate may lawfully do. Under s.8(1), it consists of a president and not fewer than 5 nor more than 15 other members, as the Minister determines; it is not a members' association or a company owned by the industry. The Act's long title states its purpose: an enhanced framework for the regulation of estate agents and their salespersons, and the formation of the CEA. (EAA 2010, long title, ss.6 and 8)
4. Which of the following is one of the functions of the Council for Estate Agencies (CEA) under section 9 of the Estate Agents Act 2010?
Section 9(1) lists the CEA's functions, including administering the licensing and registration regimes, regulating the practice of estate agents and salespersons, developing codes of practice, ethics and conduct, administering examinations and conducting investigations and disciplinary proceedings. The CEA does not fix commission rates, which are agreed between agent and client, nor does it price HDB flats or grant loans. (EAA 2010, s.9(1))
5. Ms Hannah Lim, a registered salesperson, markets a condominium unit in Johor Bahru to buyers who live in Singapore. Does the Estate Agents Act 2010 apply to this work?
Section 2 provides that the Act applies to estate agency work in respect of property situated in Singapore and outside Singapore, and 'property' in s.3(1) includes an interest in land situated elsewhere. The buyer's citizenship does not affect the scope of the Act. (EAA 2010, ss.2 and 3(1))
6. Under section 3 of the Estate Agents Act 2010, which of the following falls within the meaning of 'property'?
'Property' means an interest in land, whether in Singapore or elsewhere, that is recognised by law, and includes any building or part of a building, whether completed, being constructed or to be constructed, and a future interest in land. Company shares, parking permits and movable items are not interests in land. (EAA 2010, s.3(1))
7. Ms Farah Aziz is an advocate and solicitor with a practising certificate. In the course of her legal practice, she introduces a client who wants to sell a shophouse to another client who wants to buy one, and charges a fee for the introduction. She does no other estate agency work in the deal and holds no estate agent's licence. Which statement is correct?
Section 4(1)(b) excludes things done by a solicitor in the course of practising, in introducing to the client third persons who wish to acquire or dispose of a property (whether for remuneration or otherwise), provided the solicitor does no other work within the definition of estate agency work. If she went further, for example by negotiating the price, the exclusion would no longer apply. (EAA 2010, s.4(1)(b))
8. Larkspur Realty Pte Ltd wants its subsidiary company to be registered as a salesperson so that the subsidiary can earn co-broking fees. What does the Estate Agents Act 2010 provide?
Section 32(1) states that only a natural person may be registered as a salesperson. A company that does estate agency work must instead hold an estate agent's licence under s.28 and appoint a key executive officer under s.38. (EAA 2010, ss.28, 32(1) and 38)
9. Mr Rajesh Nair, aged 34, passed the RES examination six months ago and has an offer from a licensed estate agent. He is an undischarged bankrupt. How does the Estate Agents Act 2010 treat him when he applies for registration?
Under s.3(2)(a)(iv), an individual who is an undischarged bankrupt is not a 'fit and proper person' unless the Council otherwise determines, and s.32(2)(c) requires the Council to consider the applicant a fit and proper person before registering him. Insurance or disclosure to clients does not cure this. (EAA 2010, ss.3(2)(a)(iv) and 32(2)(c))
10. Ms Joanne Seah is registered as a salesperson through Merbau Homes Pte Ltd. On 1 August she resigns from Merbau Homes to join Jambu Lane Realty Pte Ltd, which wants her to start taking new listings for it at once. Which statement is correct?
Registration is not transferable and is subject to the salesperson continuing to act for the licensed estate agent she is registered through (s.34(6)). She therefore needs a new registration, applied for through and with the support of Jambu Lane, which must certify that she meets the requirements (s.34(2)); her Merbau Homes registration does not allow her to act for Jambu Lane, and acting as a salesperson without registration is an offence (s.29). Neither the consent of her former agency nor a period of grace changes this. (EAA 2010, ss.29 and 34)
11. Which particular must the public register kept by the CEA show for every registered salesperson?
Section 36(2)(b) requires the register to contain, for every salesperson, his name, the name of the estate agent he acts for and is registered through, the period of registration and any suspension or revocation. The register must be available for public search or inspection (s.36(5)). (EAA 2010, s.36)
12. Under section 38 of the Estate Agents Act 2010, what is the key executive officer (KEO) of an estate agent responsible for?
An estate agent must appoint a KEO and ensure that he is responsible for the proper administration and overall management of its business and the supervision of its salespersons (s.38(1)); the KEO must be contactable by the Council and the salespersons at all reasonable times (s.38(4)). No agent may hold transaction monies (Estate Agency Work Regulations, reg. 7). (EAA 2010, s.38)
13. The key executive officer of Kenari Point Realty Pte Ltd resigns and stops carrying out his duties on 3 March. Under section 38(5) of the Estate Agents Act 2010, what must the estate agent do?
When the post of KEO falls vacant through death, resignation or revocation of appointment, s.38(5) requires the estate agent to notify the Council within one week of the KEO ceasing to carry out his duties, and to appoint another KEO within one month. (EAA 2010, s.38(5))
14. A licensed estate agent ends its appointment of a salesperson. Within what period must it notify the CEA of the cessation?
Section 43(2) requires a licensed estate agent that ceases to appoint, associate with or employ a person as a salesperson to notify the Council within 7 days (or such other period as is prescribed). Regulations 20 and 21 of the Licensing and Registration Regulations require the notice to be given electronically within 7 days, in the form provided on the CEA website. (EAA 2010, s.43(2); Estate Agents (Licensing and Registration) Regulations, regs 20-21)
15. Under the Estate Agents (Transaction Records) Regulations 2021, which particular of a client's completed residential transaction is included in the report submitted to the CEA but is not among the particulars that may be shown in the public register?
Regulation 3 lists the particulars that may be included in the public register: for an HDB flat, its HDB Town, and for other property, its postal district number and general location, but not its address. Regulation 4 lists the particulars of the report under s.43A, which include the address of the property. The client's role, the completion date and the salesperson's registration number appear in both lists. (Estate Agents (Transaction Records) Regulations 2021, regs 3-4; EAA 2010, ss.36(3)(aa) and 43A)
16. A buyer wishes to complain about the conduct of a registered salesperson. Under section 49 of the Estate Agents Act 2010, which statement is correct?
Section 49(1) provides that any complaint of the conduct of a licensed estate agent or registered salesperson may in the first place be made to the Executive Director, who must refer it to the Council. The Council may require a complaint to be supported by a statutory declaration, except where it is made by a public officer (s.49(3)). The Appeals Board hears appeals against decisions of the Council or a Disciplinary Committee (s.59). (EAA 2010, s.49(1)-(3))
17. After an investigation, the Council is satisfied that there is sufficient cause for action against a salesperson for a breach unrelated to anti-money laundering rules. Without referring the matter to a Disciplinary Committee, what may the Council itself impose under section 49(6)?
Under s.49(6)(b), where the Council is satisfied that there is sufficient cause (other than an AML/PF/TF contravention, dealt with in s.49(6)(a)), it may impose a financial penalty not exceeding $5,000, censure the person, or both. Larger financial penalties, with suspension or revocation, are imposed by a Disciplinary Committee to which the Council may refer the matter instead (ss.49(11) and 52(3)); the Council's own power to suspend or revoke a registration comes from s.55, not s.49(6), and fines or imprisonment are imposed by a court on conviction. (EAA 2010, ss.49(6), 49(11), 52 and 55)
18. On 2 May, the Council serves written notice on Mr Daniel Ong, a salesperson, that it intends to impose a financial penalty on him under section 49(6). He wants to explain why no penalty should be imposed. The Council serves its written decision on 10 June and he does not appeal. Which statement is correct?
Before deciding under s.49(6), the Council must give written notice of its intention (s.49(7)); the person may show cause within 14 days after the date of the notice (s.49(8)). Subject to an appeal under s.59, the decision does not take effect until 14 days after the written notice of the decision is served (s.49(10)). The 21-day period applies to representations against a proposed suspension or revocation by the Council under ss.54-55. (EAA 2010, s.49(7)-(10))
19. The Council proposes to revoke a salesperson's registration because he no longer meets the eligibility requirements. Under section 55 of the Estate Agents Act 2010, what must happen first?
Under s.55(3)-(4), where the Council proposes to suspend or revoke a registration, it must give the salesperson and the estate agent he is registered through written notice of the proposal and the reasons for it, stating that written representations may be made within 21 days (or a longer period allowed). The Council must consider any representations before suspending or revoking (s.55(5)). (EAA 2010, s.55(2)-(5))
20. A Disciplinary Committee suspends the registration of Mr Kelvin Yeo for six months, and he does not appeal. During the suspension, a long-time client asks him to arrange viewings of her condominium unit and to negotiate with buyers, promising to pay him privately. What is the legal position?
While a suspension order is in force, the salesperson must cease to act as a salesperson for any person (s.56(3)) and is deemed not to be registered, except for the purposes of disciplinary proceedings (s.56(4)). Acting as a salesperson while unregistered is an offence under s.29(1), punishable by a fine of up to $25,000, imprisonment of up to 12 months, or both (s.29(3)). (EAA 2010, ss.29 and 56)
21. A Disciplinary Committee orders that Ms Priya Menon's registration be suspended for three months and that she pay a financial penalty of $8,000. She gives due notice of appeal to the Appeals Board, and the Council makes no application to the Board about the appeal. Pending the appeal, which statement is correct?
Section 59(3) states that lodging an appeal does not suspend the effect of the decision appealed against, subject to s.59(4): where an order revoking or suspending a licence or registration is appealed with due notice, that order is stayed pending the appeal unless the Appeals Board, on the Council's application, orders otherwise. The financial penalty order therefore remains in effect. (EAA 2010, s.59(3)-(4); s.52(9))
22. Mr Tony Chia holds no estate agent's licence and is not a registered salesperson. He advertises online that he can 'sell your condo fast', finds a buyer for a neighbour's unit and negotiates the price. The neighbour then refuses to pay the agreed fee of S$15,000. Which statement is correct?
Holding oneself out to the public and acting as an estate agent without a licence is an offence under s.28(1), punishable by a fine of up to $75,000, imprisonment of up to 3 years, or both (s.28(2)). Section 28(3) adds that no fee, commission or reward for anything done in respect of the offence is recoverable in any action, suit or matter, so later registration does not help. (EAA 2010, s.28)
23. What is the maximum penalty on conviction for a person who acts as a salesperson for a licensed estate agent without being registered under the Estate Agents Act 2010?
Section 29(3) sets a maximum fine of $25,000, imprisonment of up to 12 months, or both, for being or acting as a salesperson without registration. The $75,000/3-year maximum applies to unlicensed estate agents (s.28(2)), and $10,000/6 months applies, for example, to the estate agent card offence in reg. 9 of the Estate Agency Work Regulations. (EAA 2010, ss.28-29)
24. A salesperson tells a homeowner that she acts for Senna Grove Realty Pte Ltd, a large agency, although she is registered through a different estate agent. What does section 40(3) of the Estate Agents Act 2010 provide?
A salesperson who makes any false representation, whether verbally, in writing or by conduct, that she is employed by or authorised to act for a specified estate agent commits an offence and is liable on conviction to a fine not exceeding $5,000 (s.40(3)). A co-broking arrangement between agencies does not authorise a salesperson to claim to act for another agency. (EAA 2010, s.40(3))
25. Ms Cheryl Lau submits a forged diploma with her application for registration as a salesperson. What is the maximum penalty on conviction for this offence under the Estate Agents Act 2010?
Section 34(7) makes it an offence for any person, in an application for registration or renewal of registration (for himself or another person), to submit false documents or make a statement that is false or misleading in any material particular; the maximum penalty is a fine of $50,000, imprisonment of 3 years, or both. The Council may also suspend or revoke a registration obtained with false or misleading information (s.55(2)(c)). Financial penalties imposed by the Council are capped at $5,000 (s.49(6)) and are not criminal penalties. (EAA 2010, ss.34(7), 49(6) and 55(2)(c))
26. Tembusu Crest Realty Pte Ltd appoints a new director but fails to notify the CEA within the period required by section 43(3) of the Estate Agents Act 2010. Section 43(6) makes this an offence without stating a penalty. Which penalty applies on conviction?
Under s.64(2), a person guilty of an offence under the Act for which no penalty is expressly provided is liable on conviction to a fine not exceeding $10,000, imprisonment not exceeding 12 months, or both; the further fine of up to $1,000 a day applies only to a continuing offence after conviction and is not the whole penalty. No composition sum is fixed by the Act (s.69 only caps it), and financial penalties imposed by a Disciplinary Committee arise in disciplinary proceedings, not on criminal conviction. (EAA 2010, ss.43(3), 43(6), 64(2) and 69)
27. Angsana Quay Realty Pte Ltd let three newly registered salespersons carry out estate agency work for it for several months before any written agreement between them and the company was signed, an offence under the Estate Agents Act 2010. Its key executive officer, Mr Lim, knew of the arrangement and approved it to save on paperwork. The company is prosecuted. What is Mr Lim's position?
A licensed estate agent must not cause or permit a salesperson to carry out estate agency work for it unless a written agreement authorises the salesperson to do so (s.41(1)); contravention is an offence (s.41(3)). Under s.68(1), where an offence committed by a body corporate is proved to have been committed with the consent or connivance of an officer, or to be attributable to the officer's neglect, the officer as well as the body corporate is guilty of the offence; 'officer' includes a key executive officer (s.68(5)(a)). Disciplinary action may follow as well, but it does not replace criminal liability. (EAA 2010, ss.41 and 68)
28. A salesperson is reasonably suspected of two offences under the Estate Agents Act 2010: offence A, which carries a maximum fine of $5,000, and doing estate agency work without a written agreement with his estate agent under section 41(2) (maximum fine $25,000). Assume both are prescribed as compoundable offences. What is the most that may be collected under section 69 to compound both offences?
Section 69(1) caps each composition sum at the lower of half the maximum fine for the offence and $5,000. Offence A: half of $5,000 = $2,500, which is lower than $5,000. Section 41(2): half of $25,000 = $12,500, capped at $5,000. Total = $2,500 + $5,000 = $7,500. $15,000 ignores the $5,000 cap; $10,000 applies the cap without halving the first fine; $5,000 applies one cap to both offences together. (EAA 2010, ss.41(3) and 69(1))
29. Mr Benjamin Tan, aged 45, is a director of Pulai Ridge Homes Pte Ltd. He has four GCE 'O' level passes, eight years of estate agency work and 35 completed property transactions in the past 3 years. He passed the RES examination in 2017 but has never sat the Real Estate Agency examination, and holds none of the degrees or diplomas listed in the First Schedule. The agency wants to appoint him as its key executive officer. Which statement is correct?
Regulation 9(1) of the Licensing and Registration Regulations requires a KEO to be the sole proprietor, a director or a partner, aged 21 or above, with 4 GCE 'O' level passes or equivalent, at least 3 years of estate agency experience, at least 30 transactions in the 3 years before appointment (or 3 years of management experience) and, subject to exemptions, a pass in the Real Estate Agency examination within the 2 years before appointment (reg. 9(1)(e)). Mr Tan meets every requirement except the examination. (Estate Agents (Licensing and Registration) Regulations, reg. 9)
30. Ms Aisha Rahman passed both papers of the RES examination in March 2024 but did not take up a job in the industry. In September 2026 she joins a licensed estate agent and applies for registration for the first time. She has four GCE 'O' level passes and no exempting degree or diploma. What is her position?
Regulation 16(1)(b) requires an applicant to have passed the RES examination in the 2 years immediately before applying for registration. The exemption in reg. 16(4) covers persons who are, or were within the past 2 years, registered salespersons, KEOs or specified individuals and who kept up their CPE requirements; Ms Rahman was never registered, so CPD hours cannot replace a fresh pass. (Estate Agents (Licensing and Registration) Regulations, reg. 16)
31. Under the CEA's 2026 Continuing Professional Development (CPD) framework, how many training hours must a salesperson complete in each CPD cycle?
Every KEO, practising director or partner and salesperson must complete 16 training hours per CPD cycle: at least 12 hours of Structured Learning (including 4 hours of Prescribed Essentials and 8 hours of Professional Competencies) and 4 hours of Self-directed Learning. Each CPD cycle runs from 1 January to 31 December. (CEA, 2026 CPD Framework, para 2; Estate Agency Work Regulations, reg. 15(1))
32. Mr Kenneth Low is registered as a salesperson for the first time in April 2026. What CPD requirement applies to him for his first CPD cycle?
New salespersons are exempted from the CPD requirement for their first CPD cycle, but must comply with it for the next and subsequent cycles. (CEA, CPD Guidelines for Estate Agents and Real Estate Salespersons, para 10; CEA, CPD framework page)
33. In the 2026 CPD cycle, Ms Grace Teo completes the required Prescribed Essentials course and two accredited Professional Competencies courses with contact hours of 3.5 and 4.5 hours. She also completes 5 hours of Self-directed Learning, all duly recognised. How many more training hours must she complete before the cycle ends?
Training hours are credited in whole hours and partial durations are rounded down: 3.5 h = 3 h and 4.5 h = 4 h, so her Professional Competencies hours are 3 + 4 = 7, one short of the 8-hour minimum. Her Prescribed Essentials and Self-directed Learning (5 h against a 4-hour minimum) components are met, but hours in one category cannot substitute for another, so the extra SDL hour does not help. (CEA, CPD Guidelines, paras 9 and 15; CEA, CPD framework page, Important Note)
34. Under the 2026 CPD framework, how are the Self-directed Learning (SDL) hours of a salesperson recognised?
Structured Learning courses (Prescribed Essentials and Professional Competencies) are accredited by the CEA, whereas attendance at Self-directed Learning courses is verified and approved by the salesperson's KEO, who assesses the relevance of the activity; SDL attendance records must be kept for 5 years. (CEA, 2026 CPD Framework, Table; CPD Guidelines, paras 7, 16-17)
35. What is the purpose of the professional indemnity insurance (PII) that every estate agent must take out and maintain while it carries out estate agency work?
Under reg. 13(2) of the Estate Agency Work Regulations, the insurance must be in respect of civil liability for negligence in the performance of estate agency work, and reg. 14 bars anyone from undertaking estate agency work without the required cover. A licence is not granted or renewed unless the PII requirements are met (Licensing and Registration Regulations, reg. 11). Candidates are not required to memorise the minimum amounts. (EAW Regulations, regs 13-14)