On November 21, 2025, the Arizona REALTORS® submitted five pages of questions to the Arizona Department of Real Estate (ADRE) seeking clarification regarding its interpretation of recent revisions to the Arizona Administrative Code. Although the ADRE has not issued a formal written response, it has offered piecemeal guidance through presentations, talking points, and responses to questions raised by various association members. Based on that information, the Arizona REALTORS® has compiled its current understanding of the Department’s position on several of the questions previously submitted, which are set forth below.[1]

402(C)
If a licensee submits 16 hours for CE credit in one day, will the ADRE inquire about the submission?  If so, under what grounds? 

ADRE: A licensee may submit unlimited CE hours on a given day.  But the ADRE will cross reference classes to make sure that no CE class hour was taken at the same time.  (updated 2/10/26)

502(C)
Advertisements shall not misrepresent the facts or create misleading or ambiguous impressions.  Can you give an example of an ambiguous impression?

ADRE: Impressions that can be understood in two or more possible ways are ambiguous.  Advertisements must be clear and concise.  (updated 2/10/26)

502(E)
Advertisements shall display the employing broker’s legal name or the dba name(s).  Must all advertisements include all dbas registered by the employing broker?  If not, can one advertisement use one dba of the employing broker on one advertisement and use a different employing broker dba on a different advertisement?  Any guidance is appreciated.

ADRE: All advertisements must clearly and prominently display the employing broker’s legal name or dba(s).  Any public display including a team name or indicates a person is licensed must comply.  Pens, name badges, public displays of your phone number, etc. are all considered advertisements.  (updated 2/10/26)

502(F)
Advertising another licensee’s property shall make a disclosure in the advertisement itself that indicates the properties featured are not representative of the licensee’s transaction history and includes information of the other licensee’s transactions.  What information of the other licensee’s transactions must be included?  Every transaction they have ever closed?  Every current listing?  All of the above?  Any guidance is appreciated.

ADRE: An advertisement that explicitly states “The properties featured are not representative of the licensee’s transaction history and includes information of the other licensee’s transactions” complies with this Rule.  (updated 2/10/26)

802(A)
Changes delivery of signed documents to a party to expeditiously instead of “as soon as practical.”  Is expeditiously sooner than “as soon as practical”?  Must licensees provide documents at a speed that is impractical?  Any guidance is appreciated.

ADRE: “Expeditiously” means as soon as possible or first available time.  Suggests action completed with a sense of urgency and without unnecessary delays.  (updated 2/10/26)

1101(I)
Struck the language that “A salesperson or broker is not required to have expertise in subject areas other than those required to obtain the salesperson’s or broker’s license.”  Does this mean a licensee must have expertise in subject areas beyond the scope of their license?  If so, what expertise must they have? 

ADRE: A licensee must have expertise greater than the knowledge needed to pass the licensing exam.  The Department gave examples of knowledge that may be needed, which included solar, easements, and the ability to read a preliminary title report.  (updated 2/10/26)

1103(A)(1)(a)
DB shall exercise reasonable supervision and control over the licensed activities of licensees and others in the employ of the broker.  Reasonable supervision and control includes establishment and enforcement of written policies to Review and manage Transactions of all licensees.  Does this mean DBs must review and manage transactions when the licensee sells or buys their own property?  If so, how does this requirement reconcile with subsection A that limits supervision to licensed activities? 

ADRE: A DB does not need to supervise or control transactions where the licensee acts solely as a principal (buyer/seller/tenant/landlord) unless the licensee is using their license in the transaction.  If the licensee advertises the sale/lease of their property in the MLS, utilizes the broker’s or the Arizona REALTORS® forms, or hands out their licensee business card, then the ADRE believes the licensee is conducting licensed activity, and the DB must supervise and control that transaction.  (updated 2/10/26)

1103(B)
DBs must include a progressive disciplinary policy for managing violations of the employing broker’s policies which would also represent a violation of any statutory requirement or prohibition to real estate activity and failure of an employing broker to enforce the disciplinary policy would be a violation of subsection (D).  Can progressive disciplinary policy include ranges of discipline?  (e.g. Fines of $0-$500 for first offense; $1-$1,000 for second offense; $2-$5,000 for third offense).  Will the ADRE be updating the Model ADRE Policy and Procedures Manual?

ADRE: Multiple verbal and written warnings are not sufficient. An example of a compliant discipline policy would be a verbal warning for the 1^st offense, a written warning for the 2^nd offense and a fine for the 3^rd offense.  Failing to turn in transaction documents timely to the DB has been a violation the ADRE has used as an example numerous times.  (updated 2/10/26)

[1] While the new rules took effect without accompanying Substantive Policy Statements, the ADRE has since indicated that it intends to issue them at a future date to provide additional guidance and clarification.