Policy Area: Compliance
Applies To: All Easy Realty affiliated brokers, broker associates, sales associates, employees, contractors, staff, and other persons conducting business on behalf of Easy Realty
Policy Owner: Brokerage Management
Status: Company Policy
Purpose #
Easy Realty is committed to Fair Housing, equal professional service, nondiscrimination, and the fair and professional treatment of every person with whom we conduct business.
Federal Fair Housing law prohibits housing discrimination because of race, color, national origin, religion, sex, familial status, or disability. Florida law likewise prohibits specified discriminatory practices in the sale or rental of housing because of race, color, national origin, sex, disability, familial status, or religion.
Easy Realty’s standards of professional conduct extend beyond circumstances in which a particular Fair Housing law may technically apply.
Accordingly, this policy establishes two related standards:
- Compliance with applicable Fair Housing and nondiscrimination laws, including federal, state, and local requirements.
- Easy Realty’s Equal Professional Service Standard, which requires fair, respectful, professional, and nondiscriminatory treatment in brokerage activities and business relationships.
Compliance with this policy is a condition of conducting business through Easy Realty.
Easy Realty’s Policy #
Easy Realty supports and practices Fair Housing and equal professional service.
Easy Realty will not tolerate unlawful discrimination in the delivery of brokerage services, the availability or marketing of housing, the representation of our buyers and our sellers, or other activities conducted through the Brokerage.
Easy Realty also requires its affiliated agents and representatives to interact professionally and without unlawful discrimination with other real estate professionals and persons involved in our business.
An individual may therefore violate Easy Realty policy even where particular conduct does not independently constitute a violation of the federal Fair Housing Act.
Fair Housing Protected Classes #
Federal Fair Housing law prohibits discrimination in housing because of:
- Race
- Color
- National origin
- Religion
- Sex
- Familial status
- Disability
Florida’s Fair Housing Act likewise establishes protections against specified housing discrimination based upon race, color, national origin, sex, disability, familial status, and religion.
Agents must also comply with any additional protected classifications or nondiscrimination requirements imposed by other applicable federal, state, or local laws governing the property, transaction, service, or activity involved.
Agents should not assume this list represents every nondiscrimination requirement that may apply to a particular transaction or location.
When an agent is uncertain whether a particular law applies, the matter should be referred to Easy Realty for guidance rather than resolved through assumption.
Equal Professional Service Standard #
Every person is entitled to professional service based upon legitimate real estate and transaction considerations rather than unlawful discriminatory considerations.
Easy Realty agents shall provide professional service without unlawful discrimination in matters including:
- Representation of our buyers and our sellers
- Property marketing
- Property searches
- Showing and access opportunities
- Presentation and handling of offers
- Negotiations
- Transaction communications
- Referrals
- Brokerage cooperation
- Property availability
- Provision of information
- Advertising
- Transaction services
- Other brokerage activities
An agent’s personal beliefs, preferences, assumptions, stereotypes, prejudices, or perception of another person’s characteristics must not improperly influence the professional services provided through Easy Realty.
Fair Housing in Representing Our Buyers #
Easy Realty agents representing buyers must allow our buyers to determine where they want to live and which properties they wish to consider.
Agents may assist a buyer in identifying properties based upon legitimate, objective criteria provided by the buyer, including matters such as:
- Price
- Property type
- Property characteristics
- Lot size
- Location
- Distance
- Amenities
- School district boundaries when the buyer identifies a desired district
- Commuting considerations
- Other objective property requirements
Agents must not substitute their own assumptions about where a person should or should not live based upon a protected characteristic.
An agent should provide objective property and community information and, where appropriate, direct our buyer to authoritative third-party sources so the buyer can make their own decisions.
Steering #
Steering, when prohibited by applicable Fair Housing law, is prohibited by Easy Realty.
Agents must not direct, discourage, encourage, limit, or influence a person’s housing choices based upon a protected characteristic.
This includes conduct that improperly influences a person’s consideration of particular:
- Neighborhoods
- Communities
- Developments
- Buildings
- Geographic areas
- Properties
An agent should not decide that a particular neighborhood would or would not be suitable for a buyer because of assumptions concerning the buyer’s race, religion, familial status, disability, national origin, sex, or another legally protected characteristic.
Conversely, responding to legitimate, objective criteria specified by our buyer is not the same thing as making assumptions for the buyer.
When there is uncertainty about whether requested search criteria could create a Fair Housing concern, the agent must seek Brokerage guidance.
Fair Housing in Representing Our Sellers #
Our sellers are entitled to professional representation, but an agent may not carry out an instruction that would require the Brokerage or agent to engage in unlawful discrimination.
A listing agent may not implement discriminatory instructions concerning matters such as:
- Who may view a property
- Who may receive information about a property
- Who may submit an offer
- Whether an offer will be presented
- Whether particular buyers should be encouraged or discouraged
- Where or to whom a property will be marketed
If our seller gives an instruction that an agent believes may be discriminatory or unlawful, the agent must not simply carry out the instruction.
The matter must be referred to the Brokerage.
Property Availability #
Agents must provide truthful information concerning property availability.
No agent may falsely state or imply that a property is unavailable based upon a protected characteristic or other unlawfully discriminatory reason.
Property access may nevertheless be governed by legitimate nondiscriminatory considerations, including lawful showing instructions, property condition, scheduling, occupancy, safety, contractual obligations, or other legitimate transaction requirements.
Those requirements must be applied consistently and without unlawful discrimination.
Advertising and Marketing #
All Easy Realty advertising and marketing must comply with applicable Fair Housing requirements.
Agents must not create or publish advertising that unlawfully:
- Expresses a preference for or against persons based upon a protected characteristic
- Expresses a discriminatory limitation
- Discourages a protected group from considering a property
- Indicates that a particular type of person is preferred
- Communicates that an otherwise available property is unavailable for a discriminatory reason
Advertising requirements apply regardless of whether advertising is created personally by the agent or produced using a third-party service, automated system, template, social media platform, or artificial intelligence tool.
The agent remains responsible for ensuring that advertising published in connection with the agent’s Easy Realty business complies with applicable law and Brokerage policy.
Artificial Intelligence and Automated Tools #
The use of artificial intelligence, automated advertising, audience targeting, property recommendation systems, lead-routing tools, or other technology does not eliminate an agent’s responsibility to comply with Fair Housing requirements and this policy.
Agents must not knowingly use technology to accomplish indirectly what would be prohibited if done directly.
If an automated system produces questionable property recommendations, advertising language, audience restrictions, classifications, or other content, the agent must review and correct the output before using it in brokerage business.
EasyBot and other Easy Realty systems may provide compliance information and identify matters that should be referred to the Brokerage, but agents remain responsible for complying with Brokerage policy and applicable law.
Disability-Related Housing Matters #
Agents must treat disability-related housing matters professionally and in accordance with applicable Fair Housing requirements.
Agents should not make independent legal determinations regarding unfamiliar accommodation or modification requests.
Questions or unusual situations involving disability-related requests should be elevated to the Brokerage when guidance is necessary.
Treatment of Other Real Estate Professionals #
Easy Realty’s Equal Professional Service Standard is not limited to our buyers and our sellers.
Agents are expected to conduct themselves professionally and without unlawful discrimination when dealing with:
- Other Easy Realty agents
- Agents affiliated with other brokerages
- Brokers and broker associates
- Transaction coordinators
- Title and closing professionals
- Lenders and mortgage professionals
- Appraisers
- Inspectors
- Attorneys
- Vendors
- Property managers
- Other persons participating in a transaction or Brokerage activity
Agents may disagree, negotiate firmly, protect our client’s interests, question another professional’s conduct, decline a business relationship for a legitimate reason, or report suspected misconduct.
Nothing in this policy requires an agent to overlook poor performance, unlawful conduct, abusive behavior, contractual violations, conflicts of interest, safety concerns, or other legitimate business considerations.
The distinction is the reason for the decision or conduct.
Legitimate professional and business decisions are permitted. Unlawful discriminatory decisions are not.
Cooperation With Other Agents and Brokerages #
An Easy Realty agent must not refuse or restrict otherwise appropriate professional cooperation with another real estate professional for an unlawfully discriminatory reason.
Decisions concerning cooperation may appropriately be based upon legitimate considerations such as:
- Our client’s lawful instructions
- Agency or representation obligations
- Transaction requirements
- Licensing requirements
- Compensation arrangements
- MLS rules where applicable
- Documentation requirements
- Professional misconduct
- Fraud or suspected fraud
- Safety
- Legal or regulatory requirements
- Brokerage policy
Such decisions must not be a pretext for unlawful discrimination.
Treatment of Fellow Easy Realty Agents #
Easy Realty expects affiliated agents to treat fellow Easy Realty agents fairly, professionally, and respectfully.
Disagreements over transactions, compensation, referrals, leads, procedures, policies, or other business matters must be addressed on their merits.
Harassment, discriminatory treatment, exclusion, retaliation, or other improper conduct directed toward another Easy Realty agent is inconsistent with the professional standards of the Brokerage.
This policy applies to relevant conduct in Brokerage business whether it occurs in person or through business communications such as email, telephone, messaging, company-sponsored communication systems, transaction platforms, or other professional channels.
Client and Consumer Requests That May Be Discriminatory #
An agent must not assume that a request becomes permissible merely because it originated with our buyer, our seller, or another party.
If a client requests that an Easy Realty agent take action that the agent reasonably believes may violate Fair Housing law or another nondiscrimination requirement, the agent must not proceed with the questionable instruction without Brokerage guidance.
The agent should:
- Avoid implementing the questionable instruction.
- Explain, when appropriate, that Easy Realty follows Fair Housing and nondiscrimination requirements.
- Refer the matter to the Brokerage promptly.
- Preserve relevant communications and documentation.
- Follow the Brokerage’s direction concerning the matter.
Easy Realty will not require an affiliated agent to participate in unlawful discriminatory conduct.
Retaliation, Interference and Intimidation #
Easy Realty prohibits retaliation against a person for raising a good-faith Fair Housing or nondiscrimination concern, requesting Brokerage guidance, reporting suspected discriminatory conduct, or participating in an authorized review of such a matter.
Agents must not intimidate, threaten, coerce, or improperly interfere with a person because that person raises or exercises rights protected by applicable Fair Housing law.
Reporting Concerns #
Fair Housing concerns should be taken seriously and raised promptly.
An Easy Realty agent who receives a potentially discriminatory instruction, observes suspected discriminatory conduct, receives a discrimination complaint, is uncertain whether proposed conduct may constitute steering, is uncertain whether advertising may be discriminatory, encounters an unusual accommodation or disability-related issue, or otherwise believes a Fair Housing or nondiscrimination issue may exist should contact the Brokerage for guidance.
Agents should preserve relevant emails, messages, transaction records, advertisements, instructions, and other documentation relating to the concern.
Agents must not alter, conceal, destroy, or fabricate records concerning a reported matter.
Complaints Against Easy Realty or an Easy Realty Agent #
Any complaint alleging Fair Housing discrimination or other unlawful discriminatory conduct involving Easy Realty business must be promptly reported to the Brokerage.
Agents should not attempt to:
- Conduct their own formal investigation on behalf of Easy Realty
- Admit liability on behalf of the Brokerage
- Promise compensation or settlement
- Retaliate against the complainant
- Delete or alter relevant records
- Discourage a person from raising a concern
- Represent that they are authorized to resolve a legal claim on behalf of Easy Realty unless specifically authorized
The Brokerage will determine the appropriate response and escalation based upon the circumstances.
Good-Faith Reporting #
Easy Realty encourages good-faith reporting of suspected Fair Housing and nondiscrimination concerns.
A person does not need to establish conclusively that a violation occurred before bringing a concern to the Brokerage.
Knowingly making false allegations, fabricating evidence, or deliberately misrepresenting another person’s conduct is itself inconsistent with Easy Realty’s professional standards and may be addressed separately.
Training and Continuing Responsibility #
Fair Housing compliance is an ongoing professional responsibility.
Agents are responsible for remaining familiar with Fair Housing requirements applicable to their real estate activities and for completing Fair Housing education required by applicable law, the Brokerage, or an applicable MLS.
Easy Realty may issue additional compliance guidance, educational materials, examples, alerts, or policy updates as laws, regulations, enforcement positions, technologies, and brokerage practices evolve.
Brokerage Review and Direction #
When a Fair Housing or nondiscrimination issue is referred to Easy Realty, the Brokerage may review the circumstances, transaction documentation, communications, advertising, instructions, or other relevant information.
The Brokerage may require corrective action appropriate to the circumstances, including additional training, correction of advertising or communications, additional documentation, enhanced supervision, or other compliance measures.
An agent must comply with lawful Brokerage instructions relating to compliance and supervision.
Violations of This Policy #
Violation of applicable Fair Housing requirements or this policy is considered a serious compliance matter.
Depending upon the circumstances, Easy Realty may take action including:
- Compliance counseling
- Required education or retraining
- Written warning
- Correction or removal of advertising
- Restriction or suspension of Brokerage privileges
- Removal from a transaction when appropriate
- Additional supervision or compliance requirements
- Termination of affiliation with the Brokerage
- Other action permitted by the Independent Contractor Agreement, Office Policy Manual, Brokerage policies, or applicable law
Legitimate Business Decisions #
This policy does not prohibit Easy Realty or its agents from making legitimate, lawful business or transaction decisions.
Professional standards, contract requirements, pricing, qualifications, property characteristics, lawful client instructions, brokerage relationships, transaction risk, safety considerations, legal requirements, applicable MLS requirements, and documented business considerations may appropriately affect brokerage decisions.
Equal professional service does not mean every person, property, offer, transaction, agent, vendor, or situation must be treated identically regardless of relevant circumstances.
It means differences in treatment must not be based upon unlawful discriminatory considerations.
No Agent Authority to Waive This Policy #
No Easy Realty agent has authority to waive, modify, disregard, or authorize an exception to applicable Fair Housing requirements or this policy on behalf of the Brokerage.
A client’s instruction, another agent’s request, customary practice, competitive pressure, commission opportunity, or desire to complete a transaction does not authorize an agent to disregard this policy or applicable law.
Relationship to Law and Other Brokerage Policies #
This policy supplements the Easy Realty Independent Contractor Agreement, Office Policy Manual, and other Brokerage policies.
It does not replace applicable federal, state, or local law.
Where applicable law establishes a higher or more specific requirement, applicable law controls.
Where Easy Realty establishes a professional standard that is more comprehensive than the minimum legal requirement, affiliated agents are expected to comply with the Easy Realty standard as a condition of conducting business through the Brokerage.
Questions and Compliance Guidance #
Fair Housing questions can be fact-specific.
Agents should seek guidance before acting when they are unsure whether proposed conduct, advertising, a client’s instruction, a property search, a communication, or another action raises a Fair Housing or nondiscrimination concern.
Requesting guidance is encouraged.
Making an assumption and proceeding with questionable conduct is not.
Easy Realty Equal Professional Service Commitment #
Easy Realty provides equal professional service.
We conduct real estate business without unlawful discrimination and expect professional, fair, and respectful treatment of our buyers, our sellers, fellow agents, cooperating real estate professionals, transaction participants, vendors, and others with whom we conduct business.
Fair Housing is not merely a legal requirement. It is part of the professional standard for conducting real estate business through Easy Realty.
