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DCP clarifies schools, continuing education, record retention and fair-housing references in real-estate regulations
Summary
Connecticut’s Department of Consumer Protection said prelicensing must be offered in-person or live online, continuing education may be asynchronous, schools must retain student records three years, licensee records must be retained seven years, and the regulations now reference CHRO for housing discrimination standards.
Annalisa Villard Howe, DCP staff attorney, said statutory changes consolidated definitions and moved school- and course-registration requirements into statute; the regulations were revised to reflect those moves and to clarify course delivery and record-keeping rules.
"Prelicensing courses can only be offered in person or live online. Prelicensing is only in person or live online," Villard Howe said. She added that continuing-education courses may be offered asynchronously, meaning they can be completed without live interaction, but that prelicensing remains limited to live-instruction formats.
The department said schools must retain complete student records for three years; after that period, the burden shifts to the licensee to prove course completion. Grabowski and Villard Howe also described a separate retention rule for licensee transactional records: the regulations now reflect a seven-year retention period and require records to be made available to the department in electronic format "unless impractical." Grabowski said the regulations echo statutory language giving the commissioner authority to request information for administration of Chapter 392 (real estate licensees).
Villard Howe said the fair-housing section of the regulations was revised to cite the Commission on Human Rights and Opportunities statute (Conn. Gen. Stat. § 46a-64c) rather than restating lists of protected characteristics; the change avoids inconsistency by directing readers to CHRO law for the authoritative list of discriminatory housing practices.
Kylie, an intern who presented briefly, clarified that reciprocity applies only to initial license applications and not to continuing education: Connecticut continuing education must be completed using Connecticut-approved CT courses posted on the DCP website.
Presenters also addressed practical questions raised in the webinar: referral status is not a DCP licensing category but a business arrangement brokers may create; brokers may not pay an unlicensed business in lieu of paying a licensee; and DCP has an online process for temporary "custodial broker" appointments when a designated broker becomes incapacitated.
The department said the real estate commission will continue to mandate a required continuing-education course each cycle and that any additional mandatory elements must be posted six months before they become required.
