New Commission Disbursement And Audit Certification Policy

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At Easy Realty, our goal is to pay commissions as quickly as possible while maintaining the highest standards of compliance, accounting accuracy, and transaction oversight. Most transactions are paid through a Commission Disbursement Authorization (CDA), allowing agents to receive payment directly at closing. However, there are circumstances where a CDA cannot be issued and commission funds must instead be paid directly to the Brokerage for review and processing.

To create clear expectations and ensure consistency for all Associates, Easy Realty has adopted a new Commission Disbursement and Audit Certification Policy.

Read the policy document here: Commission Disbursement and Audit Certification Policy

Why This Policy Is Necessary

As a licensed real estate brokerage, Easy Realty is responsible for ensuring that every transaction file complies with brokerage requirements, state regulations, and internal auditing standards.

In many cases, commission payments can be authorized directly through a CDA because the transaction file has been completed, reviewed, and approved prior to closing. However, when a file contains missing documentation, missing signatures, missing initials, incomplete forms, unresolved compliance issues, or other deficiencies, the Brokerage may be unable to approve a CDA before closing.

When this occurs, commission funds must be paid directly to Easy Realty and processed after closing once all compliance and accounting requirements have been satisfied.

This policy establishes a consistent framework for handling those situations.

When A CDA Can Be Issued

Easy Realty will continue to make every reasonable effort to approve and issue CDAs whenever a transaction file has been completed and audit certified before closing.

To qualify for a CDA, the transaction file must be fully submitted, reviewed, and approved by the Brokerage’s compliance team prior to closing.

Agents are encouraged to submit required documentation throughout the transaction rather than waiting until the final days before closing.

Audit Certification Deadline

Effective immediately, any transaction file that has not achieved audit certification by 5:00 p.m. Eastern Time on the business day preceding closing may, at the sole discretion of the Brokerage, be deemed ineligible for a Commission Disbursement Authorization (CDA).

This requirement helps ensure adequate time for compliance review and reduces the risk of errors, omissions, and last-minute documentation issues that can delay payment processing.

Submitting documents shortly before closing does not guarantee approval for a CDA.

Common Reasons A File May Not Be Audit Certified

A transaction file may be deemed incomplete for a variety of reasons, including:

• Missing signatures

• Missing initials

• Missing disclosures

• Missing addenda

• Incomplete brokerage forms

• Unexecuted agreements

• Missing settlement statements or closing disclosures

• Inconsistent transaction data

• Outstanding compliance requests

• Missing brokerage-required documentation

• Any other compliance or auditing deficiency identified by the Brokerage

Agents remain responsible for correcting deficiencies and submitting all required documentation in a timely manner.

Brokerage-Held Commission Payments

When a CDA cannot be issued and commission funds are paid directly to Easy Realty, the transaction will be processed under the Brokerage-Held Commission Payment procedures.

Commissions will be processed and disbursed within five (5) business days after all of the following have occurred:

  1. The transaction has successfully closed.
  2. Easy Realty has received the commission funds.
  3. The funds have fully cleared through the banking system.
  4. All required documentation has been submitted.
  5. All compliance deficiencies have been corrected.
  6. The transaction file has been reviewed, approved, and audit certified.
  7. Any necessary accounting review has been completed.
  8. Any amounts owed to the Brokerage have been identified and applied.

The five-business-day processing period does not begin until all required conditions have been satisfied.

Understanding Processing Times

Easy Realty’s goal is always to process commission payments as quickly as possible. In many situations, commissions may be processed sooner than the five-business-day period.

However, payment timing can vary depending on banking clearance requirements, compliance review needs, accounting verification, outstanding documentation, and transaction-specific circumstances.

For this reason, Associates should not rely on receiving payment before the completion of the policy’s stated processing timeline.

Agent Responsibilities

Associates play an important role in ensuring prompt commission payment.

To avoid unnecessary delays, agents should:

• Submit required documents as they are received.

• Respond promptly to compliance requests.

• Review contracts and forms for completeness before submission.

• Ensure all signatures and initials are obtained.

• Address deficiencies as soon as they are identified.

The fastest way to receive a commission payment is to ensure the transaction file is complete and audit certified before closing.

Professional Communication Expectations

Easy Realty understands that commission payments are important to every Associate and welcomes reasonable inquiries regarding payment status.

At the same time, all communications with Brokerage staff, compliance personnel, accounting personnel, management, and the Broker must remain professional and respectful.

Harassing, abusive, threatening, hostile, excessive, or otherwise unprofessional communications regarding commission payments, compliance reviews, or Brokerage operations may constitute a violation of Brokerage policy and may result in disciplinary action.

Moving Forward

This policy is designed to provide clarity, consistency, and fairness for all Associates while protecting the Brokerage’s compliance and accounting obligations.

Our objective is simple: process commissions as quickly as possible while ensuring every transaction has been properly reviewed, approved, and documented.

By submitting complete files early and addressing compliance requests promptly, agents can help ensure a smoother closing process and the fastest possible commission disbursement experience.

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