REALTOR
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A, a residential broker, worked in a market area that included an attractive suburb of a large city. At the time REALTOR
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A launched a new advertising program, there were a number of houses for sale in the neighborhood listed exclusively with other REALTORS
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, each having the respective listing broker’s sign on the front lawn of the property. Working with his advertising agency, REALTOR
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A developed a special e-mail solicitation describing the services of his offices. He employed a commercial e-mail distribution service to purchase the e-mails of every homeowner in REALTOR
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A’s market area.
The e-mail distribution service sent REALTOR
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A’s e-mail solicitation to all the homeowners in his market area, including houses that had other REALTORS
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’ signs in the front yard. Several of the REALTORS
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whose clients received REALTOR
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A’s e-mails filed complaints with the association against REALTOR
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A. The Grievance Committee considered the complaints and referred them to the Professional Standards Administrator. A hearing to consider all of the complaints was then scheduled by the Hearing Panel of the Professional Standards Committee. The complaints charged REALTOR
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A with unethical conduct in failing to respect the exclusive agency of other REALTORS
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.
At the hearing, REALTOR
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A defended his action by saying that the distribution of his e-mail solicitation was widespread in nature; that it had been carried out by a commercial distribution service; and that it was of the same nature as television or social media advertising that might come to the attention of some clients having exclusive listing contracts with other REALTORS
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.
The Hearing Panel’s decision noted that REALTOR
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A, in designing his advertising campaign, did not direct his e-mail to property owners whose identity had come to REALTOR
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A’s attention through information disclosed by other REALTORS
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consistent with their ethical obligation to cooperate with other brokers under Article 3 of the Code of Ethics; e.g., through a “for sale” sign or through information disseminated through a Multiple Listing Service. Rather, REALTOR
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A’s advertising campaign was directed in an indiscriminate manner to all property owners in a given geographical area. Furthermore, the medium REALTOR
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A chose for his advertising campaign was an e-mail, which property owners could read or delete as they saw fit. The panel determined that this form of communication does not harass a property owner, as would telephone calls or direct personal contacts. The Hearing Panel, therefore, held that REALTOR
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A’s advertising campaign did not violate Article 16 of the Code of Ethics.