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AHGA Minimum Services Comments to Texas Real Estate Commission

We are very pleased that the Justice department and the FTC warned the Texas Real Estate Commission to reject their minimum level of service regulation, which, as their letter to TREC aptly points out would "harm Texas consumers by reducing their choices (in brokerage representation) and likely raising prices without any countervailing benefits." President Bush's regulators are defending the rights of the nation's homeowners by warning TREC not to restrict competition in the name of consumer protection.

There is no reason that consumers should be forced to pay for services they neither want nor need. Indeed the dual agency provisions in many real estate listing agreements allow real estate brokers to abrogate their fiduciary duty to represent a home seller in negotiations if the buyer is represented by the agent in the same firm. Unlike a listing agreement with a discount broker, where the commission savings are defined at the outset, dual agency clauses in most cases do not provide consumers commission reductions, rebates, or other fee reductions when dual agency clauses are exercised by the broker.

Certainly many consumers have had problems with the exercise of dual agency clauses, and consumers have not infrequently had other problems with full service real estate brokers. We are aware of no clear evidence that rapid increase in the use of discount brokers by home sellers is causing any greater level of problem for consumers than other aspects of their relationships with real estate brokers.Clearly home sellers are flocking to the discount broker model. If this business model is as flawed as the Texas Real Estate Commission appears to believe it is very doubtful that it would be continuing its rapid growth in the marketplace.

What's the solution? The first step is to find out if consumers are having more problems with discount brokers than they have with dual agency clauses,or other types of issues with full service real estate brokers. The Texas Real Estate Commission should step back from the draconian approach of outlawing an entire business model and first do some quantitative research before proceeding. If consumers are facing problems as a result of the discount broker model there are probably far less damaging alternatives. For example the Texas Real Estate Commission could require discount brokers to provide more clear disclosure of the responsibilities they must assume and could also require traditional brokers to provide more clear disclosure of the risks and loss of fiduciary services that result when dual agency clauses are exercised.

This would be a far more reasonable and less competitive alternative than the proposal under consideration by the Texas Real Estate Commission.


Chris Christensen

Vice President, Public Affairs

American Homeowners Grassroots Alliance

Serving the interests of the nation's 70 million homeowners and future homeowners since 1984. Visit our web site http://www.americanhomeowners.org. Contact us at: 6776 Little Falls Road, Arlington, VA 22213-1213. Phone 703-536-7776 Fax: 703-536-7079.

 
 

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