COUNT I - Respondent is charged with engaging in a practice that is harmful or detrimental to the public by holding himself out as being engaged in the business of selling real estate and/or practicing real estate while his salesperson license was inactive, lapsed, or expired in violation of Iowa Code sections 543B.1, 543B.3, 543B.5(12), 543B.29(1)(d), 543B.34(1) (2016). See 193E Iowa Administrative Code sections 4.5, 4.6, 18.2(5), 18.14(5)(a).
COUNT II - The Respondent is charged with engaging in practices harmful or detrimental to the public by conducting real estate business independently outside of a licensed broker in violation of Iowa Code sections 543B.24, 543B.29(1)(d), 543B.33, 543B.34(1). See 193E Iowa Administrative Code sections 4.1(2), 4.1(3), 7.1(8), 18.2(5), 18.14(5)(a), 18.14(5)(s).