Paper 2 · Professional Practice, Ethics & Conduct · 19 min read
CEA Code of Ethics & Professional Conduct
Practise this section (175 questions) → · 3.2 Professional practice, ethics and conduct, in sets of about 30
Must-know for the exam
- The Code of Ethics and Professional Client Care (First Schedule, Estate Agency Work Regulations 2010) binds every estate agent and salesperson; an offer or attempt to breach it is itself a breach.
- Regulation 7, not the Code, bans holding or handling money for any party to a sale or purchase in Singapore or an HDB lease: up to $10,000, 6 months, or both.
- Reg 7(2)(a) allows a salesperson to deliver a crossed account-payee cheque or cashier's order made out to the other party; a private tenancy's rent falls outside reg 7.
- PSM 5.3.1: you shall not lend or advance money to or for a client, except rental stamp duty before reimbursement; reg 6 separately bans moneylender referrals ($25,000, 12 months).
- Code para 15: never disclose or use a client's confidential information without consent or legal basis; disclose only to the appropriate person, only as needed. The duty outlasts the deal.
- When asked, the seller's salesperson must find out and convey material facts: loan-shark harassment, bankruptcy, divorce, unnatural death, defects such as leaks, unauthorised works, caveats, HDB MOP (PSM 3.8.3).
- Code para 7(3): any opinion must be justifiable by verifiable facts; para 7(4): never solicit a fee from someone who did not engage you; para 8: explain documents before signing.
- A first less serious breach (low loss, low gain, no dishonesty) generally draws a Letter of Warning; repeats an LOC up to $5,000; serious breaches go to a Disciplinary Committee.
- Clients expect you to understand their needs (para 6(2)), know their kind of deal (paras 4, 14) and be patient (paras 7(2), 8, 11) (syllabus 3.3.2).
- Appeal to the Appeals Board within 14 days ($1,000 fee). An appeal suspends nothing, except that a suspension or revocation is stayed unless the Board orders otherwise (EAA s 59).
On this page · 12 sections
Conduct is governed by the Code of Ethics and Professional Client Care, set out under the Estate Agents (Estate Agency Work) Regulations. It is not aspirational — it is enforceable, and breaches are a rich source of Section B scenarios.
Who the Code binds
The Code binds both the registered salesperson and the licensed estate agency they work through. The agency — and its KEO — must supervise its salespersons and ensure compliance, so one salesperson's misconduct can expose the agency too. Duties are owed primarily to the client, but honesty obligations also extend to the other party in the transaction.
Core duties of a salesperson
- Act with honesty, integrity and in the client's best interest.
- Avoid conflicts of interest (and disclose any that arise).
- Do not mislead — no false or exaggerated representations.
- Never hold or handle transaction money — and note this one is not in the Code at all: it is regulation 7 of the Estate Agency Work Regulations, a criminal offence. See the section below.
- Protect confidential information; keep proper records.
- Be competent and diligent, and keep up CPD.
▸ More checkpoints: instructions you must refuse, relayed claims and the client's price
- *Obey lawful instructions only. A client who tells you to keep quiet about a material defect*, or to describe the unit in a way you know is false, is instructing you to breach the Code. "The seller told me to" is no defence — the duty not to mislead is yours, and it does not switch off on instruction.
- Relaying is not a defence under the Code either. Passing on a seller's claim you never checked — a floor area, a tenure, an "approval" — is a false or misleading representation by you. Verify material facts or attribute them to their source. (The contract-law liability that follows sits on the misrepresentation page.)
- Confidentiality covers the client's price position. Your seller's floor price, or your buyer's ceiling, is confidential information — revealing it to the other side to close faster breaches the duty, whatever the outcome.
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Quick self-check · 5 questions
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Say your answer out loud, then tap to check it.
Is the ban on holding a client's transaction money in the Code of Ethics, and what is the penalty?Show answer
No, it is regulation 7 of the Estate Agency Work Regulations, a criminal offence: a fine up to $10,000, up to 6 months' jail, or both, plus up to $500 a day if continuing.
May a salesperson deliver the buyer's cheque to the seller?Show answer
Yes, if it is a crossed account-payee cheque or cashier's order drawn in favour of the other party (reg 7(2)(a)). Cash, or a cheque made out to the salesperson, is holding money for a party and an offence.
A salesperson tells a client prices will rise 20% next year with nothing to back it. Which Code paragraph is breached?Show answer
Para 7(3). Any opinion must be justifiable by reference to verifiable facts and given with integrity and objectivity, so a bare prediction breaches it even framed as an opinion.
What are the maximum financial penalties under a Letter of Censure and from a Disciplinary Committee?Show answer
LOC: up to $5,000. DC: up to $200,000 on an estate agent and $100,000 on a salesperson. Caps are per case, or per breach for AML/PF/TF breaches (from 1 Jul 2025).
Where does an appeal against a Disciplinary Committee decision go, and by when?Show answer
To the Appeals Board, independent of CEA, within 14 days of notification, with a non-refundable $1,000 fee. Its decision is final. An appeal does not suspend the decision, though suspension or revocation orders are stayed unless the Board orders otherwise.
Common questions
- Is the CEA Code of Ethics legally binding?
- Yes — it sets out mandatory professional obligations under the estate-agency regulations, and breaches can result in disciplinary action against the salesperson or agency.
- Can a salesperson appeal against a Disciplinary Committee decision?
- Yes. The appeal goes to an Appeals Board that is independent of CEA — not back to CEA and not to the courts. The notice of appeal must be lodged within 14 days of being notified of the decision, together with a non-refundable fee of $1,000, and the Appeals Board's decision is final. The same Appeals Board also hears appeals against CEA's own decisions, such as one on a licence or a registration.
- Can a property agent give an opinion on future prices?
- Only one they can back up. Paragraph 7(3) of the Code of Ethics and Professional Client Care requires any opinion given to a client or anyone else to be justifiable by reference to verifiable facts, and given with professional integrity, objectivity and courtesy. A bare prediction of a price rise, with no data behind it, breaches the Code even though it is framed as an opinion.
- Can a property agent hold my deposit or option money?
- No. Regulation 7 of the Estate Agents (Estate Agency Work) Regulations 2010 makes it an offence for an estate agent or salesperson to hold or handle any money for or on behalf of any party to the sale or purchase of a property in Singapore, or to the lease of an HDB property. Conviction carries a fine of up to $10,000, imprisonment of up to 6 months, or both. Pay the seller or the conveyancing solicitor directly.
- Can my agent pass my cheque to the seller?
- Yes, within a narrow exception. Regulation 7(2)(a) permits a salesperson to deliver, on behalf of a party, a crossed "account payee" cheque or cashier's order drawn in favour of another party to the transaction. The agent is acting as a courier for an instrument that can only be banked by the named payee — quite different from taking cash, taking a cheque made out to themselves, or holding the money in their own account, all of which are offences. Regulation 7(2)(b) separately allows a salesperson to receive remuneration or reimbursement for managing, repairing or renovating the property under a written contract or authorisation.
- Does the transaction-money ban cover rent on a private condo tenancy?
- Regulation 7(1) reaches the sale or purchase of any property situated in Singapore and the lease of HDB property — so a private residential tenancy's rent and security deposit fall outside the regulation 7 offence. That is not permission to collect them: the Code of Ethics still requires honesty, diligence and the client's interests to come first, CEA's guidance is that consumers should pay the payee directly through verifiable means, and mishandling the money can still lead to disciplinary action or a criminal charge such as criminal breach of trust. In the exam, check whether the question asks about an offence under regulation 7 or a breach of the Code.
- What happens if an agent breaches the Code of Ethics?
- CEA investigates, then takes one of two routes. Less serious breaches are dealt with by CEA itself through a Letter of Censure, with or without a financial penalty of up to $5,000. Serious breaches are referred to a Disciplinary Committee of at least three members drawn from CEA's Disciplinary Panel, which can impose a financial penalty of up to $200,000 on an estate agent or $100,000 on a salesperson, suspend or revoke the licence or registration, attach or vary conditions on it, or issue a written reprimand. For anti-money laundering, proliferation financing and terrorism financing breaches those caps apply per breach rather than per case, from 1 July 2025 (Estate Agents Act 2010, ss 49, 51 and 52).
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