Broker Office Management
& Compliance

The Broker of Record for Strata Real Estate & Leasing is Joanne Olimpo. The Broker's authority derives from NRS Chapter 645 and encompasses every real estate activity conducted under Strata's brokerage license. No person may perform real estate activities for compensation under Strata's license without the Broker's authorization. No contract, listing agreement, management agreement, lease, or representation agreement is binding on Strata without the Broker's authorization, express or implied through written policy.

The Broker's authority includes:

• Final approval of all property management agreements
• Final approval of all listing and buyer representation agreements
• Exclusive authority over trust account signatory designations
• Authority to hire, supervise, and terminate licensees affiliated with Strata
• Authority to establish, modify, and enforce all brokerage policies
• Authority to represent Strata in any regulatory, legal, or administrative proceeding
• Authority to decline any transaction, client, or instruction that violates Nevada law or Strata's standards

The Broker's duties under NRS 645 and NAC 645 include both affirmative obligations and prohibitions. Strata's Broker performs the following duties as a matter of standard practice:

The Broker actively supervises all licensees affiliated with Strata. Supervision is not passive — it does not consist merely of being available for questions. Active supervision means reviewing transaction files, monitoring trust account activity, confirming that disclosures are made, reviewing advertising for compliance, and confirming that every licensee is operating within the scope of their license and Strata's policies.

The Broker is personally responsible for the proper maintenance of all Strata trust accounts. This responsibility cannot be transferred to an agent, bookkeeper, or accountant. The Broker reviews trust account reconciliations monthly and is the final authority on any trust account question or concern. Detailed trust account procedures are addressed in Section 6 of this manual and in Book 2 of the Strata Compliance Library.

The Broker ensures that Strata's operations comply with all applicable Nevada statutes, administrative codes, and federal requirements. The Broker reviews all advertising before publication, reviews transaction files on a sampling basis, and conducts formal quarterly office reviews as described in Section 1 of this manual.

The Broker is responsible for maintaining current, written policies that govern all aspects of Strata's operations. These policies are documented in the Strata Compliance Library and are reviewed and updated annually. The Broker communicates policy changes to all affiliated licensees in writing within five business days of any policy change.

The Broker is the ultimate consumer protection resource within Strata. Any licensee who receives a complaint, a question about their authority, or a request to do something they believe may be improper brings the matter to the Broker immediately. The Broker investigates the matter and makes the final determination.

The Broker may delegate certain operational responsibilities to trusted, licensed agents or staff, but the Broker's legal responsibility cannot be delegated. Delegation of a task does not remove the Broker's accountability for the outcome of that task.

Responsibilities that may be delegated with appropriate oversight:

• Transaction coordination — processing file documentation under Broker supervision
• Scheduling and administrative tasks — calendar management, vendor coordination
• Routine tenant communications — maintenance scheduling, rent reminders
• Listing preparation — drafting listing descriptions, uploading photos to MLS

Responsibilities that may never be delegated:

• Final approval of trust account disbursements above the authorized threshold
• Signing or executing property management agreements
• Issuing approval or denial decisions on tenant applications (final Broker review required)
• Responding to Nevada Real Estate Division inquiries
• Making representations about the Broker's supervision practices to regulators or courts
• Authorizing deviations from Strata's published screening or compliance policies

The Broker maintains an active awareness of the risk profile of Strata's operations. Risk management at the broker level includes:

• Reviewing all new client relationships for potential conflicts, unusual instructions, or elevated risk
• Maintaining errors and omissions insurance at required coverage levels
• Reviewing and renewing E&O coverage annually before expiration
• Ensuring that all affiliated licensees carry current E&O coverage if required by Strata policy
• Monitoring the litigation and complaint environment for trends affecting Nevada property management
• Consulting legal counsel on any matter involving potential liability, regulatory action, or unusual legal questions
• Maintaining the Strata Compliance Library as a current, documented record of all operating policies

The Broker's professional conduct sets the standard for every licensee at Strata. The Broker models the conduct expected of every agent — professional communication, punctual and accurate documentation, consistent fair housing compliance, and transparent dealings with all clients and consumers.

The Broker does not:

• Accept instructions from an owner that violate Nevada law or fair housing requirements
• Execute or authorize a transaction in which the Broker has an undisclosed material interest
• Allow a licensee to continue operating under Strata's license while the licensee's license is inactive, suspended, or expired
• Permit any person to perform activities requiring a real estate license without holding one
• Make false or misleading representations to the Nevada Real Estate Division

Example 1 — Broker Intervention in Illegal Instruction: A property owner contacts the Broker and requests that Strata apply a screening standard that would effectively exclude families with children. The Broker declines the instruction, advises the owner that familial status is a protected class, documents the conversation in writing, and confirms that Strata's published screening standards — not the owner's preferences — govern all tenant decisions.

Example 2 — Trust Account Review: The Broker reviews the monthly trust account reconciliation prepared by the office bookkeeper. The Broker finds a discrepancy between the reconciled balance and the outstanding tenant balances. The Broker investigates, identifies an entry error, corrects the record, and documents the error and correction in the trust account file. The Broker does not sign off on the reconciliation until it balances.

Example 3 — Licensee Supervision: A new agent under Strata's license submits a lease for execution. The Broker reviews the lease before it is sent to the tenant and identifies a missing required disclosure. The Broker returns the lease to the agent with the deficiency noted, confirms the correction, and signs off on the revised lease. The review is logged in the file.

All licensed salespeople and associate brokers affiliated with Strata operate under the direct supervision of the Broker of Record. Affiliation with Strata does not reduce the Broker's supervisory responsibility. The Broker's supervision of licensed salespeople and associate brokers includes:

• Reviewing all property management agreements before execution
• Reviewing all listing agreements, buyer representation agreements, and referral agreements before execution
• Reviewing all lease documents and related addenda before they are sent to applicants or tenants for signature
• Reviewing all tenant application decisions — approval, conditional approval, or denial — before the decision is communicated to the applicant
• Reviewing all notices of non-renewal, notices to quit, and eviction filings before they are issued
• Monitoring trust account activity through monthly reconciliations and exception reporting
• Confirming that all advertising produced or published by affiliated licensees complies with Nevada law and Strata's advertising standards
• Confirming that all affiliated licensees hold active, current Nevada real estate licenses

The Broker verifies license status for each affiliated licensee at the time of affiliation and on a quarterly basis. License verification is performed through the Nevada Real Estate Division's license search system. Any licensee whose license is found to be inactive, expired, or suspended is immediately suspended from Strata activities pending resolution.

Many licensees affiliated with real estate brokerages are classified as independent contractors for tax and employment purposes. Independent contractor status does not reduce the Broker's supervisory obligations under Nevada law. The legal standard of broker supervision applies regardless of whether the affiliated licensee is an employee or an independent contractor.

Strata's independent contractor agreements with affiliated licensees confirm that:

• The licensee operates under the Broker's supervision at all times
• The licensee complies with all Strata policies and procedures
• The licensee complies with all Nevada real estate licensing requirements
• The licensee maintains any required errors and omissions insurance
• The Broker retains authority over all trust account activity
• The Broker retains final approval authority over all transactions, agreements, and tenant decisions

The independent contractor agreement does not waive or modify the Broker's supervisory obligations. A licensee who refuses to comply with Broker supervision under the rationale of independent contractor status is in violation of Strata policy and Nevada law.

Unlicensed assistants may perform administrative and support functions in a real estate office but may not perform any activity that requires a Nevada real estate license. The distinction between licensed and unlicensed activity is strictly enforced at Strata. Unlicensed assistants are covered in detail in Section 11 of this manual.

The Broker's supervisory responsibilities with respect to unlicensed assistants include:

• Confirming that every unlicensed assistant's duties are defined in writing and are limited to permitted activities
• Training unlicensed assistants on the boundary between licensed and unlicensed activity
• Monitoring unlicensed assistant activity for any conduct that crosses into licensed territory
• Immediately addressing any instance of unlicensed practice

Strata's broker supervision program operates through the following standing oversight mechanisms:

The Broker reviews a sample of active transaction files on a monthly basis. The sample is not limited to files referred for specific concerns — it is a random or judgment-based review of files in progress. The review confirms that all required disclosures are present, that the file is complete, that all communications are documented, and that the transaction is proceeding within the scope of the applicable agreement.

The Broker reviews all trust account activity monthly. The review includes reconciliation confirmation, exception reporting, and verification that all deposits and disbursements are properly authorized and documented. See Section 6 for complete trust account oversight procedures.

The Broker reviews all advertising on the 45-day cycle established in Section 1. Any advertising that does not comply with Nevada law, fair housing requirements, or Strata's standards is corrected or removed immediately.

The formal quarterly review is conducted every 90 days and covers all aspects of office operations. The quarterly review report is maintained in the Strata Compliance file. See Section 4 for complete office operations standards.

The Broker conducts an annual review of each affiliated licensee's performance, compliance record, and adherence to Strata's standards. Annual reviews are documented and provide an opportunity to address any pattern of concern before it becomes a regulatory problem.

All licensees and staff are required to escalate the following matters to the Broker immediately — meaning the same business day, not the next available opportunity:

• Any complaint from a client, consumer, or tenant alleging misconduct, discrimination, or financial impropriety
• Any contact from the Nevada Real Estate Division, including correspondence, audit notice, or inquiry
• Any notice or inquiry from any other regulatory or law enforcement agency
• Any threat of litigation or receipt of a legal summons, complaint, or demand letter
• Any suspected trust account irregularity or shortage
• Any situation in which the licensee believes they may have committed an error with material financial consequences
• Any instruction from a client or consumer that the licensee believes may be unlawful
• Any fair housing complaint or allegation

The Broker's response to an escalated matter includes: acknowledging receipt, assessing the situation, determining the appropriate response, and if necessary, consulting legal counsel or the Nevada Real Estate Division's compliance resources. The Broker's response is documented in the relevant file.

Example 1 — License Lapse: During the quarterly license verification review, the Broker discovers that an affiliated licensee's license expired 12 days ago. The Broker immediately suspends the licensee from all Strata activities. All open files managed by the licensee are reviewed to confirm no transactions occurred after the expiration date. The licensee is notified in writing and advised to renew before resuming any activities under Strata's license. The incident is documented.

Example 2 — Unlicensed Practice Concern: An unlicensed assistant is observed discussing lease terms with a prospective tenant over the phone. A licensed agent alerts the Broker. The Broker immediately intervenes, clarifies the assistant's permitted scope, and provides retraining. The incident is documented. If the conduct recurs, the Broker terminates the assistant's role.

Example 3 — Escalated Complaint: An agent receives an email from a tenant alleging that the agent applied different screening standards to the tenant based on national origin. The agent forwards the email to the Broker the same day. The Broker reviews the application file, the screening worksheet, and the communication record. The Broker determines that the screening criteria were applied consistently and prepares a documented response. The Broker consults legal counsel before communicating with the complainant.

The first licensed staff member to open the Strata office each business day confirms that:

• All systems — Buildium, email, phone — are operational
• Any after-hours voicemails or messages are retrieved and logged
• The daily task list in Buildium is reviewed for any time-sensitive items
• Any new inquiries received overnight are flagged for same-day response
• Any regulatory mail received the prior day is flagged for Broker review

Every licensee responsible for managed properties reviews Buildium at the start of each business day for:

• New maintenance requests submitted since the prior business day
• Overdue rent payments triggering the follow-up workflow
• Pending lease expirations within the 90-day renewal planning window
• Pending owner communications awaiting response
• Any open items from prior days that have not been resolved

All mail — physical and electronic — addressed to the brokerage is reviewed daily. Physical mail is opened, dated on receipt, and routed to the appropriate licensee or the Broker. Any regulatory correspondence — from the Nevada Real Estate Division, any court, or any government agency — is routed to the Broker immediately, regardless of the specific addressee.

Every transaction, management relationship, and client file maintained by Strata is organized using a consistent structure. Consistent file organization ensures that any authorized person can locate any document in any file without special knowledge of how that particular file was managed.

Each managed property has a file in Buildium that includes:

• Executed property management agreement
• Owner identification and contact information
• All executed leases and addenda — current and prior
• Move-in condition reports and photographs
• Move-out condition reports and photographs
• Security deposit records — receipt, accounting, and disposition
• All maintenance records — requests, work orders, and invoices
• All owner statements and disbursement records
• All notices issued to tenants — pay or quit, lease violation, entry, rent increase
• All tenant correspondence — material communications
• Trust account records related to the property
• HOA registration records and correspondence
• Insurance records — owner policy and tenant renter's insurance

Each sales transaction file includes:

• Fully executed purchase agreement and all addenda
• All disclosures required under Nevada law — Seller's Real Property Disclosure, Lead-Based Paint, etc.
• MLS listing records
• Buyer representation or seller representation agreement
• Title and escrow correspondence
• Inspection reports
• Financing documentation provided to the brokerage
• Final HUD-1 or Closing Disclosure
• All material communications related to the transaction
• Commission documentation and disbursement authorization

Professional communication is a non-negotiable standard at Strata. Every written communication — email, text, letter, or Buildium message — is a record. Every phone call involving a material matter becomes a record through documentation.

Office communication standards apply to all Strata licensees and staff:

• Email responses are sent within four hours during business hours
• Phone calls are returned within two hours during business hours
• All material communications are logged in Buildium the same day
• No personal email accounts are used for brokerage communications
• All outgoing communications include the agent's full name, title, brokerage name, and contact information
• Communications to clients and consumers are professional in tone at all times

Every person operating under Strata's license or in Strata's name is expected to conduct themselves with the professionalism appropriate to a licensed fiduciary. This expectation covers:

• Punctuality — appointments are kept, callbacks are timely, deadlines are met
• Accuracy — information provided to clients and consumers is verified before it is communicated
• Integrity — representations are honest, disclosures are made, conflicts are disclosed
• Confidentiality — client information is protected and not shared without authorization
• Respect — all clients, consumers, tenants, and vendors are treated with professional courtesy
• Documentation — all material activity is documented in Buildium promptly

Professional expectations apply equally at the office, at client meetings, at showing appointments, and in all digital communications. Strata's reputation is built and maintained through every individual interaction.

Business continuity planning ensures that Strata's operations can continue in the event of a technology failure, natural disaster, or extended absence of key personnel. The Broker maintains a documented business continuity plan that is reviewed annually.

Business continuity elements:

• All active transaction and management files are stored in Buildium and cloud-backed — no critical data exists only on a local device
• The Broker designates a licensed backup designee who can access Strata's systems and serve clients in the event of the Broker's incapacitation
• Emergency contact information for all clients, tenants, and vendors is accessible from Buildium from any internet-connected device
• The Broker's emergency contact information is posted in the office and accessible to all staff
• Strata maintains offline backup copies of all trust account records, updated monthly

Business continuity procedures are tested annually as part of the annual policy review. See Section 15 for complete business continuity standards.

Example 1 — Regulatory Mail: The office manager receives a letter from the Nevada Real Estate Division addressed to Strata Real Estate & Leasing. Without opening the letter, the manager marks it 'Received [Date]' and places it directly in the Broker's inbox. The Broker opens and reviews it within the same business day and responds within the required timeframe.

Example 2 — Incomplete File: During a file review, the Broker finds that a property management file does not contain a copy of the tenant's renter's insurance certificate. The Broker notes the deficiency and directs the responsible agent to obtain the certificate and upload it to Buildium within 48 hours. The deficiency and its resolution are documented.

Example 3 — Daily Buildium Review: An agent reviews Buildium at 9:00 AM and finds two new maintenance requests submitted after hours the prior evening. The agent acknowledges both requests in Buildium by 9:30 AM, contacts the appropriate vendor for one request that appears urgent, and schedules the second for the following business day. Both actions are logged in Buildium by noon.

The following categories of records are retained for a minimum of five years:

• All executed purchase agreements, listing agreements, buyer representation agreements, and addenda
• All disclosures and acknowledgments required under Nevada law
• All MLS records, correspondence, and material communications related to a transaction
• All closing documents — HUD-1 statements, Closing Disclosures, settlement statements
• All commission disbursement authorizations and payment records

• All executed property management agreements and amendments
• All executed leases, lease renewals, and addenda
• All move-in and move-out condition reports with photographs
• All security deposit records — receipt, accounting, disposition, and return
• All maintenance records — requests, work orders, vendor invoices, and completion records
• All notices issued to tenants and all material tenant communications
• All owner communications on material matters
• All trust account records associated with each managed property

• All trust account bank statements
• All trust account reconciliations
• All deposit records with supporting documentation
• All disbursement records with authorization and supporting documentation
• All trust account opening, modification, and closing records

• Copies of all affiliated licensee licenses and renewal documentation
• All independent contractor agreements with affiliated licensees
• All advertising records — copies of all published advertising with publication dates
• All complaint records — initial complaint, investigation notes, and resolution
• All regulatory correspondence — incoming and outgoing
• All quarterly office review reports
• All annual policy review documentation

Strata is a digital-first operation. The large majority of records are created, stored, and accessed electronically. Electronic records are treated with the same legal weight and the same retention obligations as physical records under Nevada law.

Electronic record standards at Strata:

• All records in Buildium are maintained as the primary system of record for property management activities
• Electronic records are stored in formats that remain accessible and readable for the full retention period — proprietary formats that may become unreadable are avoided or supplemented with PDF exports
• No electronic record subject to a retention obligation is deleted without Broker authorization and retention period confirmation
• Electronic records are backed up as described in Section 15 of this manual
• Email records involving material brokerage matters are archived in the brokerage's email system — not deleted at the individual agent level

Strata uses cloud storage to ensure that all records are accessible from any authorized device and are protected against local hardware failure. Cloud storage for brokerage records must meet the following standards:

• Provider is a reputable, commercially established service with documented security practices
• All brokerage data is stored in folders accessible to the Broker at all times
• Individual agent access does not supersede Broker access — Broker retains master access regardless of the individual agent's status
• Cloud storage is not a substitute for Buildium as the primary system of record — cloud is the backup and supplement
• Data stored in cloud systems is reviewed annually to confirm accessibility and organization

While Strata maintains electronic records as the primary system, certain transaction files may generate physical documents — executed agreements, notarized documents, physical inspection reports, or original disclosure acknowledgments. Physical documents are:

• Scanned and uploaded to Buildium or cloud storage within five business days of receipt
• Stored in a labeled, organized physical file for the duration of the retention period
• Never stored in a location accessible only to the individual agent — all physical files are stored at the Strata office or in a secured, Broker-accessible off-site location
• Retained for the same five-year minimum regardless of whether a digital copy exists

Material communications are a category of records that require special attention because they are generated constantly, across multiple platforms, and often without a formal filing step. Strata's approach:

• All material emails are archived in the brokerage email system
• All material Buildium messages are automatically retained in Buildium's record system
• All material phone calls are summarized in a Buildium note entered the same day as the call
• All material text exchanges are logged in Buildium — the text content is copied into a note, not merely referenced
• 'Material' means any communication that could be relevant to a dispute, complaint, compliance question, or financial decision

Example 1 — Post-Tenancy Record: A tenant vacates a Strata-managed property and a small claims dispute arises 14 months after move-out regarding the security deposit disposition. Because Strata retained the move-in condition report, move-out condition report, photographs, vendor invoices, and the written disposition letter in Buildium, the Broker is able to produce a complete documented record within one business day. The dispute is resolved in favor of the owner with full documentation support.

Example 2 — Nevada Real Estate Division Audit: The Nevada Real Estate Division notifies Strata of a routine audit and requests five years of trust account reconciliation records and a sample of ten property management files. Because all records are maintained in Buildium and in organized cloud storage, the Broker produces the complete requested record within the requested timeframe with no missing documents.

Example 3 — Record Destruction Request: An agent asks the Broker whether old files from a closed property can be deleted from Buildium to free up space. The Broker reviews the file date and confirms that the tenancy ended three years ago. The Broker advises that the file is subject to the five-year retention requirement and may not be deleted for two more years. The request is denied and documented.

The Broker's specific trust account responsibilities include:

• Authorizing the opening and closing of all trust accounts
• Establishing written authorization thresholds for disbursements
• Reviewing and approving monthly trust account reconciliations
• Reviewing and investigating any reconciliation that does not balance to zero
• Ensuring that all trust account deposits are made within one business day of receipt
• Ensuring that trust account records are maintained in Buildium and are complete
• Reporting all trust account changes to the Nevada Real Estate Division within 30 days
• Maintaining audit-ready trust account files at all times
• Ensuring that the trust account is never overdrawn
• Ensuring that funds are disbursed only from the account in which they are held

Trust account reconciliations are performed monthly. The reconciliation process confirms that the bank account balance, the Buildium ledger balance, and the aggregate owner and tenant liability balances all agree. No reconciliation may be completed, signed, or approved unless it balances to zero.

Monthly reconciliation steps:

• Obtain the bank statement for the calendar month.
• Reconcile the bank statement to Buildium's trust account register — matching all deposits, disbursements, and adjustments.
• Prepare the owner ledger summary — a list of each owner's balance in the trust account.
• Confirm that the sum of all owner ledger balances equals the reconciled bank balance.
• Investigate and resolve any discrepancy before signing the reconciliation.
• Broker reviews and signs the completed reconciliation.
• Reconciliation documentation — bank statement, register report, owner ledger summary, signed reconciliation form — is uploaded to Buildium and retained.

Trust funds are maintained in accounts completely separate from Strata's operating funds. The trust account is used exclusively for client and tenant funds. Brokerage fees, commissions, and operating income are deposited into Strata's operating account. Under no circumstances are trust funds and operating funds commingled.

Segregation of funds also applies within the trust account. Security deposits are maintained with clear ledger identification to the specific tenant and property. Rent received is credited to the specific owner's ledger before disbursement. No owner's funds are used to satisfy another owner's obligations.

The Broker maintains a nominal amount of brokerage funds in the trust account as a banking accommodation reserve, as permitted by Nevada law. The amount of this reserve is documented, monitored, and does not change without the Broker's written authorization.

Strata maintains its trust account records in a state of continuous audit readiness. An audit by the Nevada Real Estate Division may be announced or unannounced. Strata's response to any audit request is prompt, complete, and professional.

Audit readiness standards:

• All monthly reconciliations are completed and signed within 30 days of the end of each calendar month
• All trust account bank statements are retained for the full five-year period
• The owner ledger summary is reconcilable to a specific account balance on any given date
• Every deposit can be traced to a specific source document — lease, receipt, or wire confirmation
• Every disbursement can be traced to a specific authorization — owner instruction, lease term, or invoice
• No trust account record has been altered, corrected without notation, or deleted

When an audit notice is received, the Broker immediately notifies legal counsel and assembles the requested records. The Broker reviews the records before producing them to confirm completeness and accuracy. If any deficiency is identified during the self-review, the Broker consults legal counsel before producing the records.

The complete property management trust accounting procedures — including deposit procedures, disbursement procedures, owner statement preparation, NSF handling, security deposit accounting, and the full monthly reconciliation process — are documented in Book 2 of the Strata Compliance Library: Trust Account Management & Property Accounting. This section establishes the supervisory framework; Book 2 provides the operational detail.

Example 1 — Deposit Timing: A tenant delivers a cashier's check for the security deposit on Friday afternoon at 4:30 PM. The office closes at 5:00 PM. The following Monday is not a bank holiday. The agent deposits the check into the trust account on Monday morning. The deposit is made within one business day of receipt — compliant. The agent logs the deposit in Buildium with the date received and the date deposited.

Example 2 — Reconciliation Discrepancy: The monthly reconciliation shows a $200 discrepancy between the bank balance and the Buildium ledger. The Broker does not sign the reconciliation. The bookkeeper investigates and identifies a transposed digit in a manual entry. The correction is made, the Broker confirms, and the reconciliation balances. The error and correction are documented in the trust account file before the reconciliation is signed.

Example 3 — Unauthorized Disbursement Request: An agent contacts the bookkeeper and requests that $500 be transferred from the trust account to a vendor for emergency repair work. The agent is not an authorized trust account signatory. The bookkeeper declines, advises the agent to submit the request to the Broker, and documents the request and the response. The Broker reviews the invoice and authorizes the disbursement through the proper channel.

Under NRS 645 and NAC 645, every advertisement for real estate services must:

• Include the brokerage name as it appears on the brokerage license
• Be clearly identified as an advertisement — not misrepresented as editorial content or a third-party review
• Not contain false, misleading, or deceptive statements about properties, services, or the licensee's qualifications
• Be authorized by the property owner before publication
• Not advertise a property at a price or on terms not authorized by the owner

All MLS listings are subject to the rules of the applicable multiple listing service. Strata's MLS advertising standards:

• All listing data entered in the MLS is accurate and verified by the agent before publication
• Property status is updated in the MLS within the MLS-required timeframe upon any status change — active to pending, pending to closed, etc.
• Photos are current, accurate, and representative of the property's actual condition at the time of listing
• No feature or amenity is listed in the MLS that the property does not actually have
• Compensation and cooperation information is accurate and consistent with the property management agreement or listing agreement
• All required MLS fields are populated — no required field is left blank

MLS violations — including inaccurate data, false status updates, or listing properties without authorization — are subject to MLS sanctions as well as Nevada licensing action. The Broker reviews a sample of active MLS listings monthly.

Strata's brokerage website is a licensed advertising medium subject to all applicable requirements. Website standards:

• All property listings displayed on Strata's website are current and accurate
• Listings that are no longer available are removed within 24 hours of status change
• The website displays Strata's licensed brokerage name prominently
• The website displays the Equal Housing Opportunity logo or statement on the home page and on all listing pages
• No testimonial or endorsement on the website misrepresents a client's experience
• All representations about services, expertise, or market performance are accurate and substantiated

The website is reviewed by the Broker as part of the 45-day advertising cycle. Any outdated or inaccurate content is corrected before the review cycle ends.

Social media advertising presents unique compliance challenges because content can be shared, screenshotted, and taken out of context. Strata's social media advertising standards:

• All property posts on social media identify Strata as the managing or listing brokerage
• All social media posts advertising properties include the Equal Housing Opportunity logo or the hashtag #EqualHousingOpportunity
• No property post includes language that could be interpreted as expressing a preference for or against any protected class
• Social media content is reviewed by the Broker before publication — agents do not post property advertising on social media without Broker approval
• Social media profiles for Strata agents identify the agent's affiliation with Strata Real Estate & Leasing
• Screenshots of prior posts are retained as the advertising record — social media posts that are later edited or deleted are documented

Print advertising includes flyers, brochures, postcards, newspaper advertisements, and any other physical printed marketing material. Print advertising standards:

• All print advertising includes Strata's brokerage name as it appears on the license
• All print advertising includes the Equal Housing Opportunity logo and the phrase 'Equal Housing Opportunity'
• All print advertising is reviewed by the Broker before distribution or publication
• Copies of all print advertising are retained in the advertising records file for the full five-year period
• No print advertising misrepresents property features, availability, or pricing

The Fair Housing Act prohibits advertising that indicates a preference for or against any person based on race, color, national origin, religion, sex, familial status, or disability. Nevada law extends these protections to additional classes including ancestry, sexual orientation, and gender identity. See Section 13 of this manual for the complete fair housing advertising standards.

Advertising fair housing compliance requires not only the absence of prohibited language but also affirmative steps:

• Displaying the Equal Housing Opportunity logo or statement in all advertising
• Using diverse imagery in visual advertising materials when applicable
• Reviewing all listing descriptions for coded language that may express a preference based on a protected class
• Ensuring that the selection of advertising platforms does not systematically exclude segments of the population based on protected class characteristics

The following are examples of prohibited advertising language or conduct at Strata. This list is illustrative, not exhaustive. When in doubt, consult the Broker before publishing.

Every 45 days, the Broker or designated reviewer conducts a comprehensive advertising review. The review includes:

• Review of all active MLS listings — accuracy, completeness, and fair housing compliance
• Review of the Strata website — current listings, equal housing statements, accurate content
• Review of all active social media posts — compliance, equal housing, brokerage identification
• Review of any active print campaigns — accuracy and equal housing compliance
• Confirmation that all advertising records are retained in the compliance file

The results of the review are documented in the advertising compliance log maintained in Buildium. Any non-compliant advertising is corrected or removed before the next business day following the review.

Example 1 — Social Media Compliance: An agent drafts a social media post advertising a new rental listing. The post does not include the Equal Housing Opportunity statement. The Broker's review before publication identifies the omission. The agent adds the required statement and resubmits for Broker approval before posting.

Example 2 — Prohibited Language: An agent's listing description includes the phrase 'quiet, family-friendly neighborhood.' The Broker's review identifies 'family-friendly' as potentially implying preference for families with children and 'quiet' as potentially implying preference against families. Both phrases are removed. The description is revised to describe the property's features only.

Example 3 — MLS Status Update: A property under contract goes to closing. The title company confirms closing on a Thursday afternoon. The agent is required by MLS rules to update the listing status to 'Closed' within 24 hours. The agent updates the status in the MLS and on Strata's website by Friday morning.

Client information protected under Strata's confidentiality policy includes:

• Client names, addresses, phone numbers, and email addresses
• Client financial information — income, assets, credit history, bank account information
• Client motivations — reasons for selling, buying, or renting
• Client negotiating positions and authority
• Tenant screening information — credit reports, background check results, rental history
• Disability-related information and reasonable accommodation requests
• Domestic violence documentation and related communications
• Social Security numbers or government identification numbers
• Property access codes, key locations, and security information

Client information is shared within Strata only on a need-to-know basis. An agent does not share one client's financial information with another client, with a vendor, or with any third party except as required by the transaction or by law.

Trust account records are confidential. The contents of any individual owner's or tenant's trust account ledger are disclosed only to the specific owner or tenant whose funds are recorded, to the Broker, and to authorized regulatory or legal authorities. An owner does not have access to another owner's account information. A tenant does not have access to another tenant's financial records.

Trust account records provided to the Nevada Real Estate Division during an audit are provided as required by law. The Broker reviews all records before production to confirm they are responsive to the specific request and do not include unauthorized disclosures of other clients' information.

The security of digital data is a critical component of Strata's confidentiality obligations. Data security standards at Strata include:

• Buildium access is limited to authorized users with individual login credentials — shared accounts are not permitted
• Passwords for all brokerage systems are changed at least annually and whenever a user with access leaves the organization
• No brokerage or client data is stored on personal devices that are not protected by the same security standards as brokerage devices
• Email attachments containing sensitive client information are encrypted or sent through secure channels
• Cloud storage access is limited to authorized Strata personnel — Broker retains master access at all times
• Physical files containing sensitive information are stored in locked cabinets accessible only to authorized personnel
• Sensitive documents that are no longer needed within the retention period are disposed of by shredding — not placed in general recycling or trash

Privacy protection at Strata extends beyond confidentiality of specific data to a broader commitment to respecting the privacy of every client and consumer. Privacy practices include:

• Not discussing client or tenant matters in public spaces where conversations may be overheard
• Not identifying clients by name in social media posts, marketing materials, or advertising without their explicit written consent
• Not sharing client photographs, property images, or identifying information with third parties without authorization
• Ensuring that screening reports and background check results are accessed only by the agent responsible for the file and the Broker
• Ensuring that tenant medical or disability information obtained through the reasonable accommodation process is treated as confidential medical information

Cybersecurity threats — including phishing attacks, wire fraud schemes, and ransomware — are active risks for real estate brokerages. Strata's cybersecurity awareness standards:

• Agents do not wire trust funds or client funds based on instructions received by email without independent telephone verification using a confirmed phone number — not the number in the email
• Agents are alert to email phishing attempts that appear to come from clients, title companies, or other known parties but request unusual actions or contain suspicious links
• Any suspected phishing attempt or cybersecurity threat is reported to the Broker immediately
• Brokerage computers and devices are maintained with current security software
• Public Wi-Fi networks are not used for access to Buildium or any system containing client data without a VPN

Example 1 — Unauthorized Inquiry: A person calls the Strata office claiming to be the adult child of a property owner and requesting information about the owner's account balance and payment history. The agent does not provide the information. The agent advises the caller that account information is provided only to the account holder directly. The agent logs the call and notifies the Broker.

Example 2 — Wire Fraud Attempt: An agent receives an email that appears to be from the title company, providing updated wire instructions for a closing scheduled for the following day. Before wiring any funds, the agent calls the title company using the phone number from the previously executed closing instructions — not the number in the email. The title company confirms that no wire instruction change was sent. The email was a fraudulent phishing attempt. The Broker is notified and the incident is documented.

Example 3 — Disability Confidentiality: A tenant submits a reasonable accommodation request for an assistance animal, including documentation from their therapist. The agent processes the request and obtains Broker approval. The agent notifies the owner only that an accommodation has been approved and that the tenant has an approved assistance animal. The agent does not disclose the nature of the disability or the therapy documentation to the owner.

The most powerful risk management tool available to Strata is documentation. A well-documented file is a defensible file. The absence of documentation is not neutrality — it is a liability. When a dispute arises about what was disclosed, what was agreed, what condition a property was in, or what instructions an owner gave, the answer that matters is what the file shows.

Documentation risk management principles:

• Every material decision is documented at the time it is made — not reconstructed from memory later
• Every material communication is logged in Buildium within 24 hours
• Every property condition is photographed — at vacancy preparation, at move-in, at every inspection, and at move-out
• Every instruction from an owner that deviates from standard procedure is confirmed in writing before it is followed
• Every screening decision is supported by a documented screening worksheet retained in the file
• Every denial of a tenant application is supported by a documented adverse action notice
• Every trust account transaction is supported by a source document

The second most important risk management tool is escalation. Risk that is identified and escalated to the Broker while it is still manageable is fundamentally different from risk that is identified after it has become a dispute, a complaint, or a lawsuit. Strata's escalation policy — described fully in Section 3 — ensures that the Broker is always informed of risk in time to respond effectively.

Risk situations requiring immediate escalation:

• Any complaint from a client, consumer, or regulatory body
• Any legal threat or contact from an attorney representing an adverse party
• Any situation in which a licensee suspects an error has occurred that may affect a client's financial interest
• Any trust account irregularity or question
• Any situation in which an owner or client requests something that may violate Nevada law
• Any incident involving discrimination allegations
• Any situation involving domestic violence, criminal activity, or law enforcement contact at a managed property

When a complaint is received — whether from a client, tenant, owner, vendor, or other party — Strata's response follows a consistent procedure:

• The complaint is received and acknowledged to the complainant within one business day.
• The complaint is escalated to the Broker the same day it is received.
• The Broker reviews all relevant file documentation.
• The Broker determines whether legal counsel should be consulted before responding.
• A response is prepared — professional, specific, and factual.
• The response is sent within five business days unless legal complexity requires more time.
• All complaint documentation — the original complaint, Strata's response, and any subsequent correspondence — is retained in the compliance file.

Strata does not acknowledge errors, offer compensation, or make commitments in response to complaints without the Broker's review and, when warranted, legal counsel's input. A professional, documented response is not an admission.

Strata maintains errors and omissions (E&O) insurance at a coverage level appropriate to the brokerage's transaction volume and risk profile. E&O insurance provides professional liability coverage for claims arising from alleged errors, omissions, or negligence in the performance of real estate services.

E&O coverage requirements:

• Coverage is maintained without lapse — the Broker confirms renewal at least 60 days before policy expiration
• Coverage limits and deductibles are reviewed annually and adjusted if the brokerage's risk profile changes
• All affiliated licensees are confirmed to be covered under the brokerage policy or required to maintain their own coverage
• Any claim or potential claim that may implicate E&O coverage is reported to the carrier within the policy's required reporting period
• The E&O carrier is notified of any situation that may give rise to a claim — even before a formal claim is made — if the situation involves a risk of professional liability

Every licensee affiliated with Strata is expected to maintain the professional standards of their license and of the brokerage. Professional standards at Strata include:

• Staying current on Nevada real estate law through required continuing education and voluntary professional development
• Not engaging in any conduct that would constitute grounds for license discipline under NRS 645.633
• Disclosing all material facts to clients and consumers
• Avoiding conflicts of interest or disclosing them when they cannot be avoided
• Maintaining confidentiality of client information
• Complying fully with fair housing requirements in all professional activities
• Treating all clients, consumers, and colleagues with professional respect

A licensee who fails to maintain professional standards is subject to Broker action, which may include additional training, supervised file management, suspension of authority, or termination of affiliation with Strata.

Example 1 — Proactive Risk Identification: An agent is preparing a lease and notices that the property's address is in a jurisdiction that has recently enacted tenant protections the agent is unfamiliar with. Rather than proceeding without certainty, the agent alerts the Broker. The Broker reviews the applicable local ordinance, confirms the required terms, and ensures the lease complies. A potential compliance error is prevented.

Example 2 — Immediate Complaint Escalation: A tenant sends the agent an email alleging that the security deposit disposition was improper and threatening to file a complaint with the Nevada Real Estate Division. The agent forwards the email to the Broker immediately without responding to the tenant. The Broker reviews the file, confirms the disposition was properly documented, consults with legal counsel, and responds to the tenant within five business days with complete documentation support.

Example 3 — E&O Notification: An agent discovers that a required lead-based paint disclosure was not provided to a buyer prior to closing on a pre-1978 property. The Broker is immediately notified. The Broker reviews the file, contacts legal counsel, and notifies the E&O carrier of a potential claim. The notification preserves coverage even if no formal claim is ultimately made.

Most licensees affiliated with Strata operate as independent contractors rather than employees for tax and employment law purposes. Independent contractor status is defined by the terms of the written independent contractor agreement between Strata and the licensee. Independent contractor status does not affect the Broker's supervisory obligations under Nevada law or the licensee's obligation to comply with Strata's policies.

Key terms of the independent contractor relationship:

• The licensee operates under Strata's brokerage license and under the Broker's supervision
• The licensee complies with all Strata policies, Nevada law, and applicable federal law
• The licensee maintains a current, active Nevada real estate license at all times
• The licensee maintains any required E&O insurance coverage
• The licensee does not represent that they are an employee of Strata unless they are specifically engaged as an employee
• The independent contractor relationship may be terminated by either party per the terms of the written agreement

The written independent contractor agreement is executed before any licensee performs any activity under Strata's license. A licensee without an executed agreement may not operate under Strata's license.

Licensees at Strata may form or participate in real estate teams, subject to the following requirements:

• Team structures are disclosed to the Broker in writing before the team begins operating
• All team members must hold active Nevada real estate licenses appropriate to their activities
• The team name must comply with Nevada advertising requirements and not imply a separate brokerage
• All team advertising identifies Strata as the brokerage
• Team leaders are responsible for the day-to-day supervision of team members but do not relieve the Broker of supervisory responsibility
• Commission splits within teams are governed by written agreements among the team members — copies are provided to the Broker
• All team transaction files are maintained in Buildium under Strata's file standards

Referrals — compensation paid to or received from another licensee for directing a client — must comply with Nevada law and Strata policy:

• All referral fee arrangements are disclosed in writing before the referral is finalized
• Referral fees paid to Strata from outside brokerages are directed to the Strata trust account or operating account as appropriate
• Referral fees paid from Strata to outside licensees are authorized by the Broker and documented
• Referral fees to unlicensed persons are prohibited under NRS 645 — any payment for the referral of real estate business must go to a licensed brokerage or licensee
• Referral agreements are executed in writing before compensation is paid

All relationships between Strata and affiliated licensees are governed by written agreements. Oral agreements are insufficient and unenforceable for material terms. Written agreements required by Strata include:

• Independent contractor agreement — executed before any activity under Strata's license
• Team participation agreements — for all licensees operating as part of a team
• Referral agreements — for all referral compensation arrangements
• Buyout or termination agreements — documenting the terms under which a licensee's affiliation with Strata ends

All written agreements with affiliated licensees are retained in the licensee's personnel file for the duration of the affiliation plus five years.

The following activities by affiliated licensees require advance Broker approval:

• Entering into any listing agreement, management agreement, or representation agreement
• Executing any lease on behalf of an owner
• Approving or conditionally approving any tenant application
• Denying any tenant application
• Issuing any eviction notice or filing any eviction action
• Publishing any advertising in Strata's name
• Making any representation about Strata's services, qualifications, or fee structure
• Referring clients to vendors who have a financial relationship with the licensee
• Engaging in any dual representation arrangement

The requirement for Broker approval is not a bureaucratic obstacle — it is the mechanism by which the Broker fulfills the supervisory obligation imposed by Nevada law. An affiliated licensee who acts without required Broker approval does so in violation of Strata policy and may expose the brokerage to liability.

Example 1 — Team Disclosure: An experienced agent at Strata informs the Broker that she plans to bring on a newly licensed agent as part of a two-person team. The Broker requires the team leader to submit the written team agreement, confirm the new agent's license is active, execute a new independent contractor agreement with the new agent, and confirm that all team advertising will identify Strata as the brokerage. All conditions are met before the new agent begins operating.

Example 2 — Unauthorized Referral: A Strata agent offers to pay a neighbor $500 for referring a property management client. The neighbor is not a licensed real estate agent. The Broker learns of the arrangement and immediately stops it. The agent is advised that paying referral fees to unlicensed persons is illegal under Nevada law. The incident is documented. The Broker confirms that no payment was made before the intervention.

The following activities may be performed by an unlicensed assistant at Strata:

• Answer phones and route calls to appropriate licensees
• Schedule appointments, showings, and inspections on behalf of a licensee
• Prepare and organize files, documents, and correspondence under a licensee's direction
• Input data into Buildium or other software systems under a licensee's direction
• Order supplies, coordinate vendor schedules, and manage office logistics
• Prepare transaction files with licensee-provided information

• Prepare marketing materials under a licensee's direction and with licensee review before publication
• Upload photographs to listing platforms under a licensee's direction
• Schedule professional photography and inspection appointments
• Post pre-approved content on social media under specific licensee direction and with prior approval
• Prepare open house materials, signage, and promotional handouts

• Transmit pre-prepared documents that a licensee has already reviewed and approved
• Confirm and remind clients and prospects of appointments scheduled by a licensee
• Relay pre-approved information to third parties as specifically instructed by a licensee
• Collect and organize documents submitted by clients for the licensee's review

The following activities require a Nevada real estate license and may not be performed by an unlicensed assistant under any circumstances:

• Discussing or negotiating any term of a real estate contract, lease, or agreement
• Providing advice about pricing, market conditions, or negotiation strategy
• Explaining the terms of a lease, contract, or disclosure to a client or consumer
• Presenting or making any representation about an offer or counteroffer

• Contacting prospective tenants or buyers to discuss property features, availability, or terms
• Responding to questions from clients or consumers about property conditions, lease terms, or transaction details
• Conducting property showings — even for a licensee who is unavailable
• Collecting any negotiation information from clients or conveying any negotiation position

• Executing any agreement, lease, addendum, or disclosure on behalf of a licensee or client
• Accepting earnest money or security deposits — unless working directly under a licensee's supervision and immediately routing funds to the licensee
• Preparing or reviewing any document that requires licensee judgment about terms, accuracy, or legal sufficiency

Marketing assistants who focus on advertising, social media, photography coordination, and listing presentation support are a common and valuable resource in a modern real estate office. Marketing assistants at Strata:

• Prepare listing descriptions for licensee review and approval before publication
• Coordinate professional photography and virtual tours
• Manage the brokerage's social media platforms under Broker direction and approval
• Prepare print marketing materials for licensee and Broker review before distribution
• Track advertising performance metrics and report to the Broker

A marketing assistant who prepares a listing description is not performing a licensed activity as long as the description is reviewed and approved by a licensed agent before publication. A marketing assistant who publishes unapproved content, misrepresents property features, or makes substantive representations about a property is crossing into licensed activity.

Administrative staff — office managers, bookkeepers, receptionists, and transaction coordinators — provide essential operational support. Their duties are defined in writing, reviewed by the Broker annually, and communicated to each staff member at hire and annually thereafter.

Transaction coordinators, who often manage the paperwork flow of real estate transactions, operate within a particularly well-defined scope. Transaction coordinators at Strata:

• Collect, organize, and track required transaction documents
• Send reminders and follow-up communications about document deadlines
• Confirm that all required signatures are obtained on non-substantive process documents
• Coordinate closing logistics — scheduling, title company contacts, utility transfers

Transaction coordinators at Strata do not draft, review, or advise on the substance of any real estate document. They facilitate the process — they do not exercise the judgment required for licensed practice.

Example 1 — Permissible Assistance: An unlicensed assistant calls a prospective tenant to confirm a showing appointment that was scheduled by the assigned agent. The assistant confirms only the address, date, time, and the agent's name. The assistant does not discuss rental terms, property features, or application requirements. This is a permitted activity.

Example 2 — Prohibited Conduct: An unlicensed assistant responds to a prospective tenant's email question about whether pets are allowed at a listed property. Even though the answer is readily available in the listing, this is a substantive property question that may affect the prospect's decision. The assistant has effectively provided information that could influence a real estate transaction. This is not permitted. The correct action is to forward the inquiry to the licensed agent for response.

Example 3 — Marketing Support: An unlicensed marketing assistant prepares a draft listing description for a new vacancy. The draft is sent to the assigned agent for review. The agent edits the description for accuracy and compliance, then sends the revised description to the Broker for final approval before publication. The marketing assistant then uploads the Broker-approved description and photographs to the MLS and Strata's website. All steps are permissible.

Email is Strata's primary written communication channel. Email creates a timestamped record, is capable of carrying attachments, and is appropriate for all non-emergency communications.

Email standards at Strata:

• All brokerage emails are sent from the agent's Strata-issued email address — not personal accounts
• Email subject lines are specific and identify the property or matter referenced
• Emails are written in complete sentences with correct spelling and professional tone
• Every email signature includes the agent's full name, license number, title, brokerage name, brokerage address, and phone number
• The Equal Housing Opportunity statement or logo is included in email signatures on all property-related emails
• Responses to client and consumer emails are sent within four hours during business hours
• Material email exchanges are retained — emails are not deleted from the brokerage email system during the five-year retention period
• Email attachments containing sensitive client information are encrypted or sent through Buildium's secure document portal

Phone calls are the fastest and most personal form of professional communication. They are also the most easily undocumented. Strata's phone call standards address both the quality of the call and the documentation that follows it.

Phone call standards:

• Calls are answered professionally: '[Brokerage name], this is [Name].'
• Missed calls are returned within two hours during business hours
• Calls on substantive matters are summarized in a Buildium note within one hour of the call's conclusion
• The note includes: date, time, parties to the call, summary of what was discussed, any commitments made or received
• No commitment is made on a phone call that has not been authorized — if uncertain, the agent says 'I'll confirm that and follow up with you today'
• Voicemail greetings identify the agent and brokerage and request a message with the caller's name, phone number, and brief reason for calling
• Voicemails on brokerage matters are transcribed or summarized in Buildium if the content is material

Text messaging has become a primary communication channel for many clients and prospects. Strata accommodates text communication while applying the same professional and documentation standards as any other channel.

Text message standards:

• Professional tone — complete words and sentences, no casual abbreviations or emojis in business communications
• Text is appropriate for brief confirmations, appointment reminders, and non-sensitive updates
• Sensitive, complex, or legally significant communications are not conducted by text — those matters are handled by email or formal written notice
• Material text exchanges are logged in Buildium — the content of the exchange is entered into a Buildium note, not merely referenced
• Brokerage text communications are conducted from the agent's brokerage phone or brokerage-registered messaging platform — not personal numbers without Broker authorization

Strata's response time standards reflect both professional courtesy and practical business necessity — a prospect who does not receive a timely response will move to a competing property or brokerage:

Email — client or consumer: Four hours during business hours

Phone call — client or consumer: Two hours during business hours

Text message — client or consumer: Two hours during business hours

Buildium messages from residents: Same business day

Regulatory correspondence: Same business day to Broker; response per applicable deadline

Vendor communications: One business day

Professional communication is the standard at Strata regardless of the circumstances. Agents do not communicate anger, frustration, or exasperation in writing. Agents do not engage in argument or debate with clients or consumers in written form. Agents do not make personal comments about clients, tenants, or vendors in written communications that form part of the brokerage record.

When a communication is received that is hostile, accusatory, or emotionally charged, the appropriate response is:

• Pause before responding — do not respond in the moment of reaction.
• Escalate to the Broker if the matter is sensitive, legally significant, or involves an allegation of misconduct.
• Respond professionally and specifically to the factual content of the communication.
• Document the response in Buildium.

The test for any written communication: how would this read to the Broker, to a regulator, or to a judge? If the answer is uncomfortable, the communication is not yet ready to send.

Every material communication becomes a record. The documentation standard at Strata ensures that the record is complete, accurate, and accessible.

Documentation requirements:

• Phone call summary in Buildium — within one hour of conclusion for material calls
• Text exchange log in Buildium — within 24 hours of the exchange for material texts
• Email archive — all material emails retained in the brokerage email system
• Buildium messages — automatically retained in Buildium
• Written notices — copies uploaded to Buildium and physical copy retained in file

Example 1 — Email Standard: An agent emails an owner with a recommended rental rate and a supporting market analysis. The email is sent from the agent's Strata email address, includes the agent's full signature with license number and brokerage name, and references the specific property address in the subject line. The owner's reply, and any subsequent material exchange, is retained in the brokerage email archive and uploaded to the Buildium property record.

Example 2 — Difficult Phone Call: A tenant calls to dispute a late fee charge, using frustrated and borderline aggressive language. The agent listens without interrupting, acknowledges the tenant's concern professionally, advises that the late fee was assessed per the lease terms, and offers to provide a written copy of the lease provision by email. After the call, the agent documents the summary in Buildium within 30 minutes. The agent does not respond to the tenant's emotional tone in kind.

Example 3 — Text Documentation: An agent exchanges several text messages with a prospective tenant about showing availability. After confirming the appointment by text, the agent logs the key points in Buildium: prospect name, property, showing date and time confirmed by text, prospect's phone number. The actual text exchange is not uploaded (routine scheduling) but the key information is preserved in the guest card record.

The Fair Housing Act prohibits discrimination in housing based on the following characteristics:

• Race
• Color
• National Origin
• Religion
• Sex
• Familial Status — presence of children under 18 in the household, pregnant persons, persons obtaining legal custody of a minor
• Disability — physical or mental impairment that substantially limits one or more major life activities

Nevada's Fair Housing Law (NRS Chapter 118) extends protection to additional classes:

• Ancestry
• Sexual Orientation
• Gender Identity or Expression

Nevada's additional protections apply to all housing activity within Nevada, including all properties managed by or listed through Strata.

Disparate treatment occurs when a person is treated differently because of their protected class membership. An agent who responds more quickly to inquiries from one group than another, who shows more enthusiasm during showings for certain applicants, or who applies screening criteria more strictly to applicants of one background has engaged in disparate treatment — regardless of intent.

Disparate impact occurs when a facially neutral policy disproportionately affects members of a protected class without a legitimate, non-discriminatory justification. A screening policy that effectively excludes all applicants from a particular background — even without any intent to discriminate — may violate fair housing law if the exclusion falls disproportionately on a protected class.

Persons with disabilities have the right to request reasonable accommodations in rules, policies, or services, and reasonable modifications to physical premises. Failure to engage with these requests in good faith and within a reasonable time is a fair housing violation.

Steering occurs when a licensee directs prospective buyers, renters, or clients toward or away from particular neighborhoods or properties based on protected class characteristics. Steering does not require explicit statements — it can occur through the selective presentation of listings, the characterization of neighborhoods, or the response to expressed preferences.

Advertising standards under the Fair Housing Act are covered in Section 7 of this manual. Key advertising requirements:

• No advertising may express a preference for or against any protected class
• Equal Housing Opportunity logo or statement in all advertising
• No discriminatory language — including coded language that implies preference without explicit statement
• No targeting of advertising platforms in a way that excludes protected class members

Every interaction between a Strata agent and a client or prospective client is a fair housing moment. Standards for client interactions:

• Every person who contacts Strata about a property receives the same quality of service, the same information, and the same professional courtesy
• Showing appointments are scheduled with the same enthusiasm and timeliness for all prospects
• No agent makes comments about a neighborhood's demographic composition, schools, or character that could be interpreted as steering
• No agent asks any prospect about their familial status, national origin, disability, religion, or any other protected class characteristic
• No agent makes assumptions about what a prospect can afford or would want based on their protected class characteristics

The following are examples of common fair housing violations. Every affiliated licensee and staff member at Strata must recognize these violations and understand that they are prohibited:

All Strata licensees complete fair housing training at affiliation and on an annual basis thereafter. Fair housing training covers the protected classes, common violation scenarios, advertising requirements, and the reasonable accommodation process. Documentation of completed training is retained in each licensee's file.

The Broker and all affiliated licensees maintain current fair housing continuing education as part of their Nevada license renewal requirements. The Broker confirms training completion as part of the annual licensee review.

Any Strata licensee or staff member who witnesses, suspects, or receives an allegation of a fair housing violation escalates the matter to the Broker immediately. The Broker investigates all fair housing concerns without delay and consults legal counsel when the situation warrants.

Strata does not retaliate against any person — licensee, staff, client, or tenant — for reporting a fair housing concern or filing a fair housing complaint.

Example 1 — Steering Attempt: An agent showing a prospective buyer multiple properties begins describing one neighborhood as 'up and coming' and another as having 'a lot of good families.' Both characterizations are neighborhood stereotype references that could constitute steering. The correct approach is to provide factual information — proximity to highways, school district boundaries, price per square foot — and allow the buyer to draw their own conclusions.

Example 2 — Selective Enforcement: An agent sends a lease violation notice to one tenant for a minor parking violation but does not send the same notice to other tenants who have committed the same violation. If the selected tenant is a member of a protected class and the unnoticed tenants are not, selective enforcement may constitute a fair housing violation. Strata's standard is consistent enforcement applied to all tenants equally.

An internal complaint is a concern raised by a Strata licensee or staff member about the conduct of another licensee, staff member, or the Broker. Internal complaints are taken seriously and addressed promptly.

Internal complaint procedure:

• The person with the concern brings it to the Broker in writing.
• The Broker acknowledges receipt within one business day.
• The Broker investigates the concern by reviewing relevant documentation and speaking with involved parties.
• The Broker issues a written determination within ten business days.
• If the concern involves the Broker, the complainant may contact the Nevada Real Estate Division directly.
• All internal complaint documentation is retained in a confidential file.

Consumer complaints are concerns raised by clients, prospective clients, tenants, or members of the public about the conduct of a Strata licensee or Strata's operations.

Consumer complaint procedure:

• The complaint is received and immediately escalated to the Broker.
• The Broker acknowledges receipt to the complainant within one business day — by phone or in writing.
• The Broker reviews all relevant file documentation.
• The Broker determines whether legal counsel should be consulted before responding.
• A written response is prepared addressing the specific complaint factually and professionally.
• The response is sent within five business days unless additional investigation or legal review is required.
• If the complaint alleges a fair housing violation, legal counsel is consulted before any response is sent.
• All complaint documentation is retained in the compliance file.

Every complaint received by Strata is documented regardless of its apparent merit. Documentation includes:

• The date the complaint was received
• The method of receipt — phone, email, letter, in person
• The identity of the complainant (if provided)
• The substance of the complaint — specific allegations or concerns raised
• The date the Broker was notified
• The investigation steps taken
• Any legal counsel consulted and the date
• The written response sent
• The outcome — resolved, unresolved, escalated to regulators or courts

Complaint documentation is retained for the full five-year period regardless of resolution. Complaints that escalate to Nevada Real Estate Division proceedings or litigation are retained until those proceedings are fully resolved.

Contact from the Nevada Real Estate Division (NRED) requires immediate Broker response. NRED contact may take the form of:

• Audit notice — requesting specific records
• Complaint investigation — requesting a response to a filed complaint
• Routine correspondence — license renewal, trust account change notification confirmation
• Disciplinary proceeding — notice of potential license action

Response to NRED contact:

• All NRED correspondence is routed to the Broker the same day it is received.
• The Broker reviews the correspondence and determines whether legal counsel should be retained.
• For audit notices and complaint investigations, legal counsel is typically consulted before any substantive response.
• All requested records are assembled and reviewed before production.
• All communications with NRED are conducted by or through the Broker — not by individual affiliated licensees.
• All NRED correspondence and Strata's responses are retained in the regulatory correspondence file.

Example 1 — Tenant Complaint: A tenant calls the Strata office and complains that their maintenance request submitted three weeks ago has not been resolved. The receptionist acknowledges the concern and advises the tenant that the matter will be reviewed by the assigned agent immediately. The receptionist notifies the agent and the Broker. The agent reviews the Buildium record, discovers the request was submitted but the vendor confirmation was never entered, and contacts the vendor immediately. The Broker reviews the situation and contacts the tenant by phone with an apology for the delay and a specific repair date. The incident is documented.

Example 2 — Fair Housing Complaint to NRED: Strata receives a notice from the Nevada Real Estate Division advising that a former applicant has filed a fair housing complaint alleging that their application was denied based on national origin. The Broker immediately contacts the brokerage's legal counsel. Legal counsel reviews the application file, screening worksheet, adverse action notice, and the showing log. The file demonstrates consistent application of published screening criteria. Legal counsel prepares a response for submission to NRED. The Broker does not respond independently.

Strata's operations depend on technology systems that must be maintained, backed up, and secured. Technology continuity standards:

• Buildium is the primary system of record — all critical operational data resides in Buildium and is accessible from any internet-connected device
• No critical operational data resides only on a local device — laptops, desktop computers, and local servers are not the only or primary storage location for any required record
• Buildium's cloud-hosted infrastructure provides inherent redundancy — Strata's data is not dependent on Strata-maintained servers
• All brokerage devices are maintained with current operating systems and security software
• Device failure does not cause data loss — all work is saved to cloud systems, not local device storage only
• Internet connectivity failure at the primary office does not prevent access to Buildium from mobile devices or alternative locations

Strata uses cloud storage to supplement Buildium for documents not generated within Buildium. Cloud storage standards:

• Cloud storage provider is commercially established with documented security, encryption, and redundancy practices
• All brokerage cloud folders are accessible to the Broker with master credentials separate from individual agent accounts
• Cloud storage is organized consistently — the same folder structure is used for every property and every transaction type
• Agent departures do not result in loss of access to brokerage records stored under the agent's cloud account — files are organized in brokerage-owned folders, not personal folders
• Annual review of cloud storage confirms that all records are accessible, organized, and within retention compliance

Backup procedures at Strata ensure that critical data is not dependent on a single system or storage location:

• Buildium data is backed up by Buildium's infrastructure — Strata confirms Buildium's backup practices as part of the annual technology review
• Trust account records — reconciliations, bank statements, ledger exports — are exported from Buildium and saved to a separate cloud storage location monthly
• Executed agreements and critical transaction documents are stored in Buildium and in cloud storage
• A monthly export of all active management records — tenant ledgers, owner balances, open maintenance — is saved to cloud storage
• Backup integrity is tested annually — the Broker confirms that records can be retrieved from backup storage when the primary system is unavailable

Cybersecurity threats represent a significant and growing risk to real estate brokerages. Wire fraud, email phishing, and ransomware are among the most common and financially devastating threats. Strata's cybersecurity program includes:

Wire fraud is one of the highest-dollar threats facing real estate businesses. Strata's wire transfer policy:

• All wire transfer instructions are verified by phone call to the recipient using a number independently confirmed from a reliable source — never from the email providing the wire instructions
• Any change to wire instructions is treated as a potential fraud attempt until independently verified
• Trust account wire transfers require Broker authorization regardless of amount
• Wire confirmation is obtained from the sending bank and retained in the file

• Agents are trained to recognize phishing attempts — unsolicited requests to click links, provide credentials, or take unusual actions
• Suspicious emails are reported to the Broker before any action is taken
• Email accounts are protected with strong passwords and, where available, multi-factor authentication
• Brokerage email is not accessed from shared or public computers

• All brokerage devices are protected with full-disk encryption and screen lock
• Public Wi-Fi networks are not used for access to Buildium or any system containing client data without a VPN
• Antivirus and anti-malware software is maintained current on all brokerage devices
• Software updates are applied promptly — delayed security updates are a primary vector for malware attacks

Emergency operations planning addresses the scenario in which Strata's normal office operations are disrupted by an event — natural disaster, extended power outage, medical emergency, or similar situation.

Emergency operations elements:

• The Broker designates a licensed backup responsible party who can access Strata's systems and make authorized decisions in the Broker's absence
• The backup designee's authorization is documented in writing and updated annually
• Emergency contact information for all clients, tenants, and critical vendors is accessible from Buildium on any internet-connected device
• Tenant emergency communications are handled through Buildium's messaging system and through the brokerage's emergency maintenance line, which is staffed even during office closures
• Trust account access in an emergency is handled by the Broker's authorized designee — the backup designee must be a licensed broker or broker-salesperson with the Broker's written authorization for trust account access
• The emergency operations plan is communicated to all Strata staff and reviewed annually

Example 1 — Device Failure: A Strata agent's laptop fails completely on a Thursday morning. Because all work is saved to Buildium and cloud storage — not only to the local device — the agent accesses all active files, tenant records, and pending transactions from a borrowed device within 30 minutes. No client is affected and no deadline is missed. The laptop is repaired separately without any impact on client service.

Example 2 — Phishing Attempt: An agent receives an email that appears to come from the Broker requesting immediate wire transfer of trust funds to a new account 'for emergency purposes.' The email asks the agent not to call the Broker and to act immediately. The agent recognizes the urgency and secrecy as classic phishing indicators, does not act on the email, and calls the Broker directly using the Broker's known phone number. The Broker confirms that no such email was sent. The incident is documented and the compromised-appearing email address is reported to the brokerage's IT contact.

Example 3 — Broker Incapacity: The Broker is hospitalized following an accident and will be unavailable for three weeks. The Broker's documented backup designee — a licensed associate broker — immediately accesses Buildium and assumes operational responsibility. All active management files, trust account access, and pending decisions are handled by the designee within the Broker's written authorization. All clients are notified of the temporary change in contact. The Broker's complete return is documented when operational responsibility transfers back.

There is a persistent temptation in any busy office to take shortcuts — to skip the documentation step because the client is waiting, to skip the Broker review because the answer seems obvious, to delay the trust account deposit because it is late in the day. These shortcuts are individually small and collectively catastrophic.

Compliance Before Convenience means that statutory requirements, brokerage policies, and fair housing obligations take precedence over what is easier, faster, or more comfortable in any given moment. The one-business-day trust deposit requirement applies even on a Friday afternoon. The lease requires Broker review even when the property needs to be leased quickly. The adverse action notice must be sent even when the conversation will be awkward.

The reason this principle leads Strata's operating principles is that non-compliance is never actually convenient. A trust account discrepancy discovered in an audit costs far more time and money than the deposit would have cost to make correctly. A fair housing complaint arising from a shortcut in the screening process costs far more than the proper process would have required. The apparent convenience of the shortcut is an illusion. Compliance, executed consistently, is the most efficient way to operate a professional brokerage.

Every Strata licensee and staff member is expected to apply this principle not only to their own work but to the work they see around them. If a procedure is being skipped, the right response is to raise it — not to assume someone else will address it.

Memory is unreliable. The human mind reconstructs rather than records — we remember what we expected to happen, what we intended, and what feels consistent with our understanding of events. In a dispute, that reconstruction is not evidence. Documentation is.

Documentation Before Memory means that every material decision, every material communication, and every material observation is recorded at the time it occurs — not later, not from memory, not summarized at the end of the week. A phone call about lease terms is logged in Buildium the same day. A property condition noted during inspection is photographed immediately. An owner instruction that deviates from standard procedure is confirmed in writing before it is followed. A denial decision is documented in the file before the adverse action notice is sent.

The practical consequence of this principle is that every Strata file, at every stage of the transaction, should be able to tell the complete story of what happened — to anyone who reads it, without supplemental explanation from the agent who managed it. If a file cannot stand alone and tell its own story accurately, it is not yet complete.

Documentation Before Memory also protects individual licensees. An agent who is the subject of a complaint two years after a transaction has closed cannot rely on memory to defend their conduct. The file is the defense. Agents who document thoroughly have defenses. Agents who rely on memory do not.

Real estate is a business involving people's homes, their investments, and their financial futures. Emotions are present in nearly every transaction. A frustrated tenant, an anxious owner, an aggressive applicant, a grieving seller — every one of these situations presents an invitation to respond emotionally rather than professionally. Strata's standard is consistency.

Consistency Before Emotion means that the same screening criteria apply to every applicant at the same property, regardless of how much the agent likes or dislikes the individual. The same lease enforcement procedures apply to every tenant in violation, regardless of their personal circumstances. The same documentation standards apply to every file, regardless of how straightforward or simple the transaction appears. The same professional tone applies to every communication, regardless of how the other party is communicating.

Consistency is not indifference to human circumstances. An agent can acknowledge a tenant's difficult situation while still applying the lease terms consistently. An agent can be compassionate with a grieving seller while still following the required disclosure procedures. Consistency and compassion are not in conflict. Consistency and special treatment are.

The most important reason for Consistency Before Emotion is fair housing compliance. Inconsistent application of any policy — even unconsciously, even with good intentions — creates the conditions for a disparate treatment finding. If some tenants are charged late fees and others are not, and the pattern correlates with a protected class, the inconsistency becomes a fair housing violation regardless of the agent's intent. Consistency protects every client, every consumer, and the brokerage itself.

Communication is the primary medium through which Strata's standards are expressed or violated. Every email, every phone call, every text, and every Buildium note is simultaneously a service to the client and a record in the file. The standard for all of them is the same: professional.

Professional communication at Strata means complete and accurate information delivered in a tone that is respectful, clear, and appropriate to the professional relationship. It means responses within the established timeframes. It means not making commitments that have not been authorized. It means acknowledging what you do not know while committing to find out. It means never allowing frustration, stress, or interpersonal conflict to appear in written communications that form part of the brokerage record.

Professional communication also means knowing when not to communicate. An agent who receives a legal threat by email does not respond before consulting the Broker. An agent who receives an emotionally charged message does not respond in kind. An agent who receives a fair housing allegation does not attempt to explain or defend — they escalate. The professional discipline of not communicating in the wrong moment is as important as the quality of communication in the right moments.

The test for any communication under Strata's standards is this: how would this read to the Broker, to the Nevada Real Estate Division, or to a judge? If the answer is uncertain or uncomfortable, the communication is not yet ready. Write it better, or consult the Broker first.

Strata is a fiduciary — a professional trusted with other people's money, property, and important decisions. That trust is not a formality. It is the foundation of every relationship the brokerage has with every owner, tenant, buyer, seller, and member of the public who interacts with Strata.

Protecting clients and consumers means disclosing material facts, even when disclosure is uncomfortable. It means declining owner instructions that would harm tenants, even when the owner insists. It means applying fair housing standards, even when a client expresses a preference that violates them. It means maintaining confidentiality, even when sharing information would be convenient. It means completing every required document, even when the transaction seems simple enough not to need it.

Protection of clients and consumers is not in conflict with advocacy for clients. An agent can advocate aggressively for an owner's financial interests while still treating tenants lawfully and professionally. An agent can represent a buyer's interests fully while still disclosing material information that affects the transaction. The fiduciary relationship does not require an agent to harm the other party — it requires the agent to serve their client within the law.

When client interests and legal requirements appear to conflict, Strata's standard is clear: legal requirements prevail. An owner who wants to discriminate does not get that service from Strata. A client who wants to conceal material information does not get that service from Strata. If complying with the client's instruction would require Strata to violate the law, Strata declines the instruction — and if necessary, declines the client.

This principle is perhaps the most practical of Strata's operating standards. It translates abstract values into concrete daily action: before sending a communication, ask how it would read in review. Before skipping a documentation step, ask how the file would look without it. Before making a screening decision, ask whether the documentation would support it under scrutiny.

Every file Strata manages is potentially subject to review — by the Broker, by the Nevada Real Estate Division, by a court, or by a fair housing investigator. Not every file will be reviewed, but any file might be. The standard is the same regardless of which file is selected: complete, accurate, professional, and defensible.

Operating every file as though it may be reviewed does not mean operating in fear. It means operating with the clarity of purpose that comes from knowing that the standards exist for good reasons and that meeting them consistently is the mark of a professional organization. An agent who documents thoroughly and follows procedure consistently has nothing to fear from any review. An agent who cuts corners and relies on memory has everything to fear.

This principle also applies to all communications. Every email should be written as though the Broker will read it. Every phone call summary should be written as though a regulator will read it. Every property condition report and photograph should be prepared as though a judge will examine it. When these standards are internalized, they do not feel like extra work — they feel like professionalism.

A professional organization does not simply maintain its current standards — it systematically identifies where those standards can be stronger, where procedures can be clearer, and where performance can be better. Continuous improvement at Strata operates through specific mechanisms: annual policy reviews, quarterly office reviews, post-transaction feedback, complaint analysis, and ongoing professional development.

Continuous improvement does not require perfection. It requires honest assessment. When a complaint reveals a gap in procedures, the gap is addressed in the policy. When a regulatory development changes the legal environment, the policies are updated to reflect it. When an agent identifies a situation that the existing procedures do not cover, the Broker adds it to the next policy review. When a pattern of errors appears in multiple files, the training program is updated.

Every affiliated licensee contributes to continuous improvement by bringing observations and concerns to the Broker rather than managing them independently. A licensee who identifies a procedure that does not work in practice provides the brokerage with valuable information. A licensee who quietly works around a procedure that does not fit their practice creates a compliance risk. The culture of continuous improvement depends on communication — agents who raise concerns, Brokers who receive them seriously, and policies that evolve in response to real-world experience.

This principle exists because the temptation to treat broker responsibility as delegable is constant and understandable. A busy broker overseeing multiple licensees, dozens of managed properties, and an active transaction pipeline cannot personally execute every action in every file. Delegation is necessary and appropriate. But delegation of a task is not delegation of responsibility.

When the Broker authorizes a licensee to prepare a lease, the licensee prepares the lease and the Broker reviews it. The review is not optional — it is the mechanism by which the Broker exercises the supervisory responsibility that Nevada law requires. When the Broker authorizes an assistant to reconcile the trust account, the bookkeeper performs the reconciliation and the Broker reviews and signs it. The signing is not a formality — it is the Broker's confirmation that the responsibility has been exercised.

Nevada law is explicit on this point: the Broker is responsible for the activities of all persons operating under the Broker's license. That responsibility exists whether or not the Broker was personally involved in a given transaction, whether or not the licensee followed the Broker's instructions, and whether or not the Broker was even aware of a specific action. The regulatory framework places this responsibility on the Broker because the public relies on the Broker to ensure that every person operating under that license meets professional standards.

At Strata, this principle means that the Broker's review is not a bureaucratic step to be accommodated when convenient — it is a legal obligation to be performed consistently. Files do not close without Broker review of required documents. Tenant applications do not receive final decisions without Broker sign-off. Advertising does not go live without Broker approval. Trust account reconciliations do not get filed without the Broker's signature. These requirements are not negotiable, and they are not reduced during busy periods. They are the floor of the Broker's obligation, not the ceiling of what a diligent Broker does.

STRATA REAL ESTATE & LEASING

Office of the Broker · Joanne Olimpo, Broker

Version 1.0 · 2026 · Confidential — For Internal Use Only

Confidential — Internal Use Only · Page 1 · Version 1.0 · 2026

An agency relationship is created through a brokerage agreement between a client and a broker. Agency creates legal duties and obligations under Nevada law. Once agency exists, the licensee owes the client all statutory duties required by Nevada law. Nevada does not recognize transactional brokerage or limited agency representation. Agency duties generally may not be waived by agreement.

Single Agency exists when a licensee represents only one party — seller, buyer, landlord, or tenant. Single agency is preferred because it minimizes conflicts of interest.

Acting for More Than One Party. Nevada law permits a licensee to represent more than one party under certain circumstances. All required disclosures must be made and written consent obtained before proceeding.

Assigned Agency allows separate licensees within the same brokerage to represent different parties in the same transaction. Each assigned licensee owes full fiduciary duties to their respective client. Confidential information must remain protected at all times.

Nevada law requires specific agency disclosure forms. All forms shall be completed accurately, signed when required, retained in the transaction file, and available for Broker review.

• Duties Owed by a Nevada Real Estate Licensee — Required whenever agency is established. A disclosure document, not a brokerage agreement.
• Consent to Act — Required whenever a licensee acts for more than one party where Nevada law requires written consent. Disclosure alone is not sufficient.
• Authorization to Negotiate Directly — Required when communicating directly with another broker's client pursuant to Nevada law.

One of the greatest risks facing Nevada licensees is the creation of implied agency — when a consumer reasonably believes a licensee represents them based upon the licensee's conduct, advice, actions, or communications.

Licensees shall disclose known material facts and facts that reasonably should have been discovered through the exercise of reasonable care and diligence. A material fact is any fact likely to influence the decision of a reasonable buyer, seller, landlord, or tenant.

Whenever a licensee's relationship to a party changes during a transaction, the change shall be disclosed promptly and documented. New disclosure forms shall be executed whenever required by Nevada law. All changes shall be documented in the transaction file.

Agency relationships may terminate through completion of the transaction, expiration of the brokerage agreement, mutual agreement, termination pursuant to contract terms, or death or incapacity when applicable under law. Termination of agency does not eliminate duties that survive termination, including confidentiality obligations. Transaction files shall clearly document the conclusion or termination of representation.

• Nonfeasance — Failure to perform a required duty. Examples: failure to present offers; failure to provide disclosures; failure to document required actions.
• Malfeasance — Intentional wrongful conduct. Examples: intentional concealment; fraudulent statements; dishonest conduct.
• Misfeasance — Performing a lawful act negligently. Examples: incomplete disclosure; improper supervision; failure to verify critical information.

• Clearly identify representation at the earliest practical opportunity
• Avoid implied agency through conduct, advice, or communication
• Protect confidential information at all times
• Disclose material facts promptly and document delivery
• Present all offers promptly in accordance with Nevada law
• Maintain complete documentation in every transaction file
• Seek Broker guidance whenever agency conflicts arise

The Broker shall be consulted immediately whenever:

• Agency relationships become unclear or disputed
• A potential conflict of interest exists between represented parties
• Consent to Act may be required
• Confidentiality concerns arise within the same brokerage
• Material disclosure questions exist regarding a property or transaction
• Representation issues are disputed by any party