Ethics, Rules, Conduct + Professionalism Flashcards
1
Q
What are the four levels of RICS membership
A
- FRICS (to become have show evidence of four characteristics: Five years MRICS, Leadership Role, Achievement in certain area, raising the profile of the RICS)
- MRICS
- AssocRICS
- Trainee
2
Q
Who is the CEO of the RICS
A
Justin Young
3
Q
Who is the RICS president?
A
Tina Paillet
4
Q
When was the RICS founded?
A
Royal Institution of Chartered Surveying was founded in 1868. With the Royal Charter in 1881.
5
Q
What is the RICS motto?
A
There is measure in all things
6
Q
What is the current governance structure?
A
Governed under terms of its Royal Charter. Structure is as follows:
- Governing council has over 20 member, which runs the RICS, providing management + strategic direction
2a. Standards & Regulations Board
2b. Management Board
- 17 specialist groups covering property, land and constriction. Each group has an elected board + is responsible for outline standards of competence + practice (e.g. Planning & Development, Building Surveying, Valuation, Rural)
7
Q
What is the role of the RICS?
A
- Maintain highest standards of education + training
- To protect consumers through strict regulation of professional standards
- To be the leading source of information + independent advice on land, property construction + associated environmental issues
8
Q
What was the aim of The Bichard Review 2022?
A
- Clarify purpose of the RICS
- Make recommendations on its governing structure
- Provide proposals for incoming leadership and the strategy of the institution
9
Q
What were some of the key recommendations of the Bichard Review 2022?
A
- Renewed + increased focus on public interest remit of the RICS
- Increased focus on diversity + inclusion across RICS
- Independent RICS review every 5 years
- Simplified governance structure
- Greater leadership
- Maintaining self reguation
10
Q
What are the RICS Future Foundations?
A
Published in November 2023 following the Bichard Review
Vision - A natural & built environment that is sustainable and inclusive for all.
Introduces new Mission (Inspire, uphold), Strategic Goals (Lead + Influence on Sustainability, Attract next gen) and Values (Professional, Collaborative, Inclusive)
11
Q
What are the 5 benefits to being a RICS Member?
A
- Status - Professional credentials provide client confidence
- Recognition - Promotion of professional excellence to governments + the market
- Market Advantage - RICS Status + Standards give a competitive advantage
- Knowledge - International practice standards, professional guidance, CPD
- Network - Access to professionals worldwide
12
Q
What are the RICS Requirements for Registration?
A
- If 50% of principles are RICS members, then the firm has to be regulated, if at least 25% then the firm can apply to be RICS regulated
- There needs to be a ‘Responsible Principle’
- Principals are the directors of the business
13
Q
What is the information required by the RICS for registration?
A
- Type of business + staffing details
- name of the Responsible Principle
- Statutory regulated activties
- Nature of clients
- Complaints handling procedure + record
- PII details
- Whether the firm holds clients money
14
Q
What did the RICS Rules of Conduct (2021) replace?
A
Previous rules of conduct and the 5 Global Professional + Ethical Standards
15
Q
What are the RICS Rules of Conduct?
A
Rule 1 - Be honest, act with integrity
Rule 2 - Maintain professional competence + ensure services are provided by competent individuals
Rule 3 - Good quality + diligent service
Rule 4 - Treat others with respect, encourage Diversity + Inclusion
Rule 5 - Act in the public interest, take responsibility for your actions and maintain public confidence in their profession
16
Q
What is the aim of the Rules of Conduct?
A
The Rules of Conduct promote and enforce the highest ethical standards in surveying profession.
17
Q
What are some example behaviours of Rule 1 (Act with Honesty + Integrity)?
A
1.2 - Members and firms do not allow themselves to be influenced improperly by others (as a result of, for example, giving or receiving work referrals, gifts, hospitality or payments) or by their own self-interest.
1.3 - Members and firms identify actual and potential conflicts of interest throughout a professional assignment and do not provide advice or services where a conflict of interest or a significant risk of one arises, unless they do so in accordance with the current edition of Conflicts of interest, RICS professional statement
1.9 - Members and firms protect confidential information and only use or disclose it for the purposes for which it was provided, where they have the necessary consent to do so or where required or permitted by law.
18
Q
What are some example behaviours of Rule 2?
A
2.1 - Members + Firms only undertake work that they have the knowledge, skills and resources to carry out competently
2.3 - Members + firms check that subcontractors have the necessary competence and skills to carry out work competently
19
Q
What are some example behaviours of Rule 3?
A
3.1understand the client needs + objectives
3.5 timely manner, with a due skill and care
3.9 good records
3.10 Encourage solutions that are sustainable, and do not harm the environment
20
Q
What are some example behaviours of Rule 4?
A
4.3 Members and firms do not bully or harass anyone
4.6 Members and firms to work cooperatively with others
21
Q
What are some example behaviours of Rule 5?
A
5.1 Members and firms have an obligation to speak out if they believe work they are completing is not right in any way
5.3 Members and firms to ensure public statements do not undermine public’s confidence in the profession
22
Q
What are members Professional Obligations to the RICS?
A
Appendix A of the RICS Rules of Conduct
- Comply with CPD
- Cooperate with the RICS
- Promptly provide all info required by standards + regulation board
23
Q
What are firms Professional Obligations to the RICS?
A
Appendix A of the RICS Rules of Conduct
- Publish a Complaints Handling Procedure, which includes an ADR provider
- Ensure work is covered by adequate & appropriate professional indemnity cover
- Cooperate with the RICS
- Provide info requested by Standard and Regulation Board
- If a sole practitioner must make arrangements for death
24
Q
What was the rationale for developing the new Rules of Conduct?
A
- Simpler Structure
- Clear examples
- Focusing on Respect, Diversity + Inclusion
- Understanding evolving technology
- Tackling climate change
25
What is the Ethics Decision Tree?
It is a framework of questions which members should ask themselvs when facing a situation in which they are asked to act in a potentially unethical manner or situation
26
What are the steps that the Ethics Tree encourages you to consider?
1. Do you have all the facts?
2. Legality of one's actions
2. Consistency with the RICS Rules of Conduct
3. Consult with the correct + appropriate people and have clear reasoning ahead of making decisions
4. Would you be content for your decision to be made public?
27
What does the "Use of Social Media: Guidance for RICS Members, 2021" highlight?
Whilst social media is extremely important for members of firms, it reminds members of the high standards of professional behaviour that is expected of RICS members and that the Rules of Conduct apply to social media as well.
28
Why is the RICS responsible for regulating the surveying profession?
To protect the public, uphold the public confidence in the profession, uphold professional standards
29
Who undertakes RICS disciplinary procedures on behalf of the RICS?
The Standards + Regulatory Board
30
What are the three levels of disciplinary action?
1. Action by the Head of the Regulation
2. Disciplinary Panel (drawn from the independent regulatory tribunal)
3. Appeal Panel
31
What is the first step of a formal investigation?
A formal investigation by the Head of Regulation of the RICS, who can initiate four actions upon completion of their investigation should they consider that disciplinary action is required
32
What are the four actions that the Head of Regulation of the RICS can initiate?
1. Serve a fixed penalty notice
Used for breaches of the Rules relating only to the supply of information to the RICS by firms and members. May consist of a fine or caution
2. Regulatory Compliance Order
Low level breaches which can easily be corrected. A written document that states terms upon which member or firm must follow. May be used for example when a member fails to undertake appropriate CPD.
3. Refer matter to single member of regulatory tribunal
3. Action by a disciplinary panel
More serious breaches of control. May include Lay members (not RICS). Penalties available include; RCO, warning, fine, expulsion. Results to be published in the RICS Modus magazine.
33
What is the new category of core material that is replacing Professional Statement & Guidance notes
Professional Standards: "Set the requirements or expectations for RICS members + regulated firms about how they provide services or the outcomes of their actions"
34
What is RICS Practice Information?
Info to support practice, knowledge + performance of RICS members + regulated firms. They do not include advice
35
What are RICS Practice Alerts? and what is a recent one?
Came into affect in August 2023. New tool for warnings or alerting profession to emerging areas of risk.
e.g. An alert providing extra guidance reminding RICS members on the professional obligations when deciding on acting and acting as an Expert Witness
36
Talk through some key things to note on Fee Negotiations?
1. Fees should be market bases + agreed on an ad-hoc basis, avoid price fixing or collusion
2. Fee negotiations are allow (as long as professional)
3. Scope can be adjusted accordingly, but high level of service still required
4. Transparent if receiving a referral fee. Referral fees should in the context of a Bribery Act 2010 + RICS Rules of Conduct
37
What should the Terms of Engagement include?
Must state in writing:
- The client's agreement to the proposed fee basis
- Payment of expenses
- Copy of the firm's complaints handling process
38
What are the three steps to check ahead of accepting an instruction?
1. Check that you are professionally competent
2. No conflicts of interest or personal interest
3. Confirm terms of engagement in writing before commencing
39
What does the Consumer Rights act 2015 allow?
A cooling off period of 14 days from the date of the agreement
40
When might it be appropriate to decline an instruction?
1. You are not competent to undertake the work
2. Do not have sufficient facts on the issue
3. Client will not sign off you terms of engagement
4. Conflict of Interest
5. Professional Indemnity Insurance Liability Cap cannot be agreed
6. Advice is pro bono and PII will not cover this
7. Client is included in UK Government Sanctions List
8. Would you be happy for you actions to be made public?
Follow the Ethics Decision Tree
41
What is the first decision when you face a Conflict of Interest
Conflict Avoidance vs Conflict Management (No vs Yes)
Conflict Avoidance = to not accept the instruction
Conflict Management = to accept the instruction but to manage the conflict through a written agreement
42
What does the RICS Professional Standard on Conflicts of Interest, 2017, state? And what are some key areas of the Standard?
A member must not advise or represent a client where doing so would involve a conflict of interest other than where all those who are, or may be affected have provided consent.
- All conflicts must be managed in accordance with the professional standard
- All firms must have in place effective systems + controls to ensure compliance
- All firms must keep records of all conflicts
43
What are the three types of conflict of interest?
1. A 'Party Conflict' - Work done on the same instruction for two different parties
2. An 'Interest Only Conflict' - Personal Interest
3. A 'Confidential Information Conflict' - Work between two parties that is confidential
44
What is informed consent?
Only given if pure transparency is given and the party impacted fully understands position
Informed consent only if best for all parties
45
How to handle a conflict of interest?
1. Conflict Avoidance
Receive full information + decide if conflict is irresolvable or if it can be managed. Then decide whether to accept instruction.
2. Written advice to both parties
Assuming you want to accept the instruction. Set out in writing information including; Nature of conflict + relevant facts and then proposals to deal with conflict (e.g. information/ethical barrier), be clear as you can, request written confirmation of informed consent from both clients
3. Conflict Management
Set up an information barrier in accordance with the provisions agreed with both clients
46
What is a Conflict Management technique?
Information / Ethical Barriers
If informed consent received that you can work for two parties where a conflict of interest exists, an information barrier should be set up. This process should include:
- Barrier must be robust enough to offer no chance of information passing through
- Surveyors acting on either side must be different + physically seperated
- All information regarding instruction must be securely stored
- Audit trail of conflict process. Compliance officer must oversee all actions
47
What's an example of where a conflict of interest has been managed at your firm?
When we were selling a piece of land, I had appointed an agent to act on behalf of my client to market and run the sales process. They then proceeded to inform me that they had another team who had been acting on behalf of a potential investor who was interested in the land. The agent notified myself and highlighted that each team are situated in different offices, provided their data management procedures for all information relating to the instruction, ahead of receiving written consent from myself.
48
Talk me through RICS Bye Laws notes on Confidentiality
- 'Client Confidentiality must be maintained for all Client affairs'
- If a 3rd party wants to access your files you must get written consent, unless statutory duty that overrides e.g. police or HMRC
- Documents should be held for a minimum of 6 years before disposal and destroyed securely
- If a surveyor comes across confidential information that is not meant for them, they are not allowed to use this information. Sender to be Notified + Compliance officer to be notified.
49
What are some of the details set out in the RICS Guidance Note on Complaints Handling (2016)?
- Requirement for a RICS regulated firm to have a published complaints handling procedure (CHP) that meets the RICS Rules of Conduct
- CHP should always be highlighted under the terms of agreement
- Notification of PII insurers as soon as complaint as could be a claim for negligence
- An RICS approved Alternative Dispute Resolution (ADR) mechanism should be highlighted in the CHP
50
What are the standard procedures for handling a complaint?
Stage 1 (In House):
- Details of CHP issued following complaint to whomever the firm owes a duty of care
- Complaints Handling Officer to be stated as the first person to contact
- Complaint acknowledged within 7 days and investigated within 28 days
Stage 2 (ADR - Third Party Resolution)
- If complainant is not happy with In House review, independent redress scheme is issued
- Name of redress scheme to be provided (RICS Dispute Resolution Service)
51
What are the four requirements for CPD?
1. Members shall undertake a minimum of 20 hours a year
2. At least 10 of the hours have to be formal, with other allowed to be informal
3. All members must maintain a current understanding of the RICS Rules of Conduct
4. Members must record activity on RICS website by 31st Jan
52
What is formal CPD vs Informal?
Formal = Structure training (training, courses, seminars)
Informal = Self managed learning
There is an online decision tree to assist with decision making
53
What needs to have occurred in order for a negligence claim to be made:
A duty of care exists to clients + third parties, using a reasonable care + skill.
When a duty of care is breached, and there is a loss so a claim for damages arises.
For example, if a surveyor fails to report a defect that has to be put right, the existence of which has an impact on the value of the property, both parties will have anticipated at the point the contract was agreed that the client would suffered a loss when purchasing the property with the defect.
54
Provide some negligence case law
Hope Capital vs Alexander Reese Thompson (2023)
Negligence claim from lender, saying that valuer was to blaim for over lending due to over valuation. However court rules that reliance on valuation for lending wasnt stipulated in the purpose of valuation
55
What are the limitations of negligence?
From the Limitation Act 1980, the current limitation periods for negligence are:
- Contract - 6 years from date of negligent act, breach of contract or omission. Section 14A provides alternative limitation period
- Tort - 6 years from the date claimant suffered the loss
56
What are some strategies to avoid negligence?
1. Clearly understand client objectives, confirm instruction in writing in terms of engagement
2. Ensure competence
3. Undertake work in accordance with professional standards + practice info
4. Detailed file notes + photos
5. CPD + keep up to date with market knowledge
6. Cap professional liability excess on your PII policy in your ToE
57
What are some requirements for Professional Indemnity Insurance?
- Mandatory for surveyors & an appropriate level of PII needs to be in place for all instruction
- To protect client, surveyors + third parties when there is a duty of care breach + claim for damages arises
- Details set out in Professional Indemnity Insurance Requirements 2022
- Policies need to be written by a RICS approved insurer
- Policy should retroactive (PII covers on a 'claims made' basis covering only claims that are made during period insured regardless of when negligent act occured)
- Certificate to be sent to RICS annually
58
What are the minimum requirements for PII?
- £100k or less = £250k PII
- £100k to £200k = £500k PII
- £200k or more = £1m PII
59
What are the maximum levels of uninsured excess required?
- Turnover up to £10m = Greater sum of £10k or 2.5%
- Over £10 = no maximum
60
What is required following the cessation of trading?
"Adequate + Appropriate run off cover is required
- For consumer claims at least £1m of aggregate cover for 6 years
- For commercial claims, firms to consider an appropriate amount for 6 years
- Firms unable to get run-off cover can apply for cover from RICS run off pool
61
Is PII needed for Pro-bono work
Yes
62
What is some key info in RICS Practice Info - Risk + Liability Insurance 2021?
RICS recommends the use of liability caps to manage risks with associated professional work
Be aware of third party reliance and make it clear that advice can only be relied upon by client named in terms of engagement
63
What are some of the procedures which chartered surveyors need to be aware of when handling client money?
Client Money Handling 2022
- Clients accounts must be kept seperate + clearly identifiable
- The word 'client' is on the bank account
- Client must be able to have their monies on demand
- Accounts must be kept in credit
- Annual auditing + reporting
- All firms that handle clients money must display their procedures on their website
- There is the RICS Client's Money Protection Scheme for a RICS regulated firm who can't repay a Client's money
64
What are some RICS requirements when setting up a new practice?
- Inform RICS of your new practice by completing a Firm Details Form
- Appoint a Responsible Principal
- Register with RICS for regulation
- Arrange PII + send to the RICS
- Client Money Handling
- Set up a Complaints Handling Procedure, and obtain approval from the RICS. Set up a complaints log and appoint a complaints handling officer.
- Plan for succession if a sole practitioner
- Ensure CPD logged online
65
What are some Statutory (legal) requirements when setting up a new practice?
- Business name
- Disability discrimination compliance with the Equality Act
- Bribery Act 2010 Compliance
- Money laundering reporting officer
- Health + Safety compliance (H+S Act 1974)
- Asbestos register
- Fire safety compliance
- Register for data protection
- HMRC for tax + VAT registration
66
What is some RICS Compliance when closing a practice?
- Inform RICS of retirement / closure and deregister
- Ensure clients are informed + hand over arrangements are made to a new firm
- Return any client moneys held
- Inform insurers + procure PII run-off cover for a minimum of 6 years from expiry of policy
- Retain files + records for a minimum of 6 years
67
What are some of the key areas of the Bribery Act 2010?
- Aims to reduce Bribery in business in the UK + abroad
- A bribe can be giving, offering, promising or receiving of an advantage (such as a gift) in exchange for a service or an action
- Companies are responsible for employees acts unless adequate policies can be shown
- Hospitality is not prevented under the act (recorded in the gist register)
- Companies must provide they have undertaken mitigation steps (e.g. Risk Identification, Training, Clear Policies + Regular Reviews)
68
What are the six principles for implementing adequate procedures to prevent bribery within the Bribery Act 2010?
1. Proportionality
2. Top level commitment
3. Risk Assessment
4. Due Diligence
5. Communication
6. Monitoring + Review
69
What are the four different offences within the Bribery Act 2010?
1. Bribing
2. Receiving a bribe
3. Bribing a foreign official
4. Failure to prevent a bribe
70
Who polices the Bribery Act 2010? And what are the penalties?
- Policed by the Serious Fraud Office
- Max prison sentence 10 years and/or unlimited fine for individuals
- Companies face unlimited fine
71
What are key provisions with the Money Laundering, Terrorist Financing + Transfer of Funds Regulations 2017?
Money laundering is when proceeds of criminal activities is hidden or converted + realised as legitimate
1. Regulations cover estate agency work
2. Requirement to have a money laundering risk assessment
3. Internal policies and regulation
4. Staff training
5. New customer DD (CDD & EDD for PEPs) (Anti-Money Laundering Checks to confirm purchaser identity)
6. Record Keeping for minimum of 5 years
7. 10,000 euros limit of cash to be received
8. On-going business relationship with a client to be monitored
9. Money Laundering Reporting Office to report to National Crime Agency
72
What are Estate Agents legal obligations?
- Individuals + business need to be approved + remain registered by HMRC to trade
- Customer Due Diligence checks on vendors, purchasers, landlords + tenants
- Enhanced Due Diligence checks of red flags (e.g. high countries, or non face to face)
73
What types of transactions must firms scrutinise?
- Complex or unusually large
- Unusual patterns
- Without economic or legal purpose
74
Explain what needs to occur for CDD?
Customer Due Diligence
- Identify client + verify identity bases on reliable independent source (ID)
- Identify beneficial owners of the client
- For a company, its name, company number and address of registered office
- Names of directors unless company is listed
75
Explain what needs to occur if EDD?
Enhanced Due Diligence
- Requires additional evidence + monitoring. More detailed examination of their background.
- Including high risk third country or a politically exposed person
- PEP = someone entrusted with a prominent public function. Higher potential risk for bribery + corruption.
76
What are the penalties if fail to follow Money Laundering, Terrorist Financing + Transfer of Funds Regulations 2017?
- Max 14 years prison sentence + fine for assisting with money laundering
- Max 5 years for tipping someone off that they are under suspicion
77
What are the typical requirements for money laundering checks for CDD for different organisation types? & the evidence of Constitution required?
Public Limited Company = London Stock Exchange Listing
Public Accountable Body = Government Ownership / Control
Private Limited Company = Certification of Incorporation, Name, Registered Number, Registered Address, Directors
Private Individual = Passport, driving license, bank statement, bills for past three months
78
What should you consider if asked about acceptance of cash / hospitality?
1. Bribery Act 2010
2. RICS Professional Standard
3. My organisations procedure
4. Professional objectivity
5. Tax implications
6. Sanctions
7. Employment contract details
79
If asked about AML, what should you consider?
1. Money laundering, terrorist financing + transfer of funds regulation 2017
2. RICS Professional Standard
3. Government guidance for estate agents
4. Due Diligence (CDD + EDD)
5. Professioanl Transparency
6. "Red Flags"
80
What are some red flags associated with money laundering?
- Unwillingness to provide identity documents
- Changes to parties involved in transaction
- Unusual features, unexpected urgency, loss making
- Payment of fees in unusual currencies
81
What does RICS Guidance "Anti Money Laundering Sanctions Update, 2022" update
Reminder about the sanctions of Money Laundering + Estate Agents' role in enforcing these:
- Understanding risk factors + red flags
- Using software is recommended if likely to engage with higher risk clients
- Checking existing clients regularly
82
What are the main areas of the Proceeds of Crime Act 2022
- Provides powers for enforcement authorities in the UK to recover criminal + civil proceedings money + other assetrs which are deemed to be proceeds of crime
- Also obligation to submit a Suspicious Acitivity Report if they suspect someone is involved with TF, Bribery or ML
83
What are the three main areas of offence within the Proceeds of Crime Act 2022?
1. Concealing criminal property
2. Arrangement
3. Acquisition, use or possession of criminal property
84
What is the Economic Crime (Transparency + Enforcement) Act 2022?
- Strengthens investigation powers regarding unexplained wealth orders
85
What does the RICS Professional Standard: Countering Bribery, Corruption, Money Laundering + terrorist financing 2019 tell you?
Sets out the mandatory, globally applicable requirements for RICS members + regulated firms in relation to bribery, corruption, money laundering + terrorist financing
86
What are the three sections of the RICS Professional Standard: Countering Bribery, Corruption, Money Laundering + Terrorist Financing 2019
1. Mandatory requirements for anti bribery, corrpution, AML and terrorist financing
2. Guidance setting out supporting good practice for above
3. Supplementary guidance on some concepts in 1 and 2
87
What does Section 1 of the RICS Professional Standard: CB, C, ML + TF 2019 tell members + firms about B+C?
RICS Regulated Firms must:
- Not accept anything that could constitute a bribe
- Procedures in place to comply with law
- Report anything suspicious
- Due Diligence
- Records to highlight firm has met professional standards
88
What does Section 1 of the RICS Professional Standard: Countering Bribery, Corruption, Money Laundering + Terrorist Financing 2019 tell members + firms about AML & terrorist financing?
RICS Regulated Firms must:
- Not facilitate or be complicit in ML or TF
- Should have systems in place
- Report anything suspicious
- Evaluate + review risk
- Appropriate DD to understand client
- Keep records
89
What does Section 2 of the RICS Professional Standard: Countering Bribery, Corruption, Money Laundering + Terrorist Financing 2019 tell Members & Firms?
Guidance is provided such as:
- Have written policy in place for each
- Code of behaviour
- Transparency
- Set up a gifts register
- Keep up to date with legalisation
90
What does Section 3 of the RICS Professional Standard: Countering Bribery, Corruption, Money Laundering + Terrorist Financing 2019 tell Members & Firms?
Supplementary Guidance is provided on:
- Establishing a risk's based approach. Consider the three Ws (who you work for, what you are doing and why you are being asked)
- Greater DD with PEP
- Need to identify beneficial owner of the firm
91
Give me an example of a time when you aligned with Rule 1 of the Rules of Conduct?
Gift from landscape contractor
92
Give me an example of a time when you aligned with Rule 2 of the Rules of Conduct?
Professional team assessment of consultants with the correct competence to work on a timber building design
93
Give me an example of a time when you aligned with Rule 3 of the Rules of Conduct?
When assessing viability of a building comparing structural solutions highlighted that Concrete slabs were more viable, however advised my client that timber slabs would be preferred due to their much reduced embodied carbon
94
Give me an example of a time when you aligned with Rule 4 of the Rules of Conduct?
Project charter to ensure that I respect everyone's ways of working
95
Give me an example of a time when you aligned with Rule 5 of the Rules of Conduct?
When making a public statement about removal of an art installation from our development, ensured to highlight reasoning for removal and where it was going to, managed the communication and response.
96
Give an example of when you have dealt with a complaint?
Residents at Elephant Park complained that via complaints log that kids were playing music until late at night.
Took complaint on board, and took ownership. Spoke to estate manager who explained that they could ask the security, who are on shift 24/7 to do walk arounds the estate more often. This begun to happen. Highlighted this in my response to the resident, and highlighted ADR.
They were satisfied
97
Who is head of regulation at RICS?
Nigel Clarke
