Count I
Respondent is charged with knowingly aiding or abetting an unlicensed person, by allowing the unlicensed practice of real estate in Iowa in violation of Iowa Code sections 543B.1, 543B.3, 543B.29(1), 543B.34. See 193E Iowa Administrative Code sections 7.13, 18.2(6), 18.14(5)(s), 21.2(7).
Count II
7. Respondent is charged with engaging in practices harmful or detrimental to the public in violation of Iowa Code sections 543B.29(1)(d), 543B.29(1)(k), 543B.34(1), 543B.46 by:
(a) Failing to maintain at all times a record of the Respondent’s trust account and improper trust account procedures. See 193E Iowa Administrative Code §§ 13.1(6), 18.14(5)(e), 18.14(5)(f).
(b) Failing to accurately maintain the running balance of all individual ledger accounts for the Respondent’s trust account. See 193E Iowa Administrative Code §§ 13.1(6)(b), 18.14(5)(e)(2).
(c) Failing to provide a means for a monthly reconciliation of the Respondent’s trust account to ensure agreement of the general ledger balance, reconciled bank balance and individual ledger accounts. See 193E Iowa Administrative Code §§ 13.1(6)(a)(3), 18.14(5)(e), 18.14(5)(f).
Count III
8. Respondent is charged with improper trust account procedures by failing to remit accrued interest earned on the real estate trust account on a quarterly basis to the to the State of Iowa in violation of Iowa Code sections 543B.29(1)(k), 543B.46(1). See 193E Iowa Administrative Code §§ 13.1(2), 18.2(2), 18.14(5)(f)(11).
