A real estate agent who deliberately conceals their interest in purchasing their principal's property (including through a spouse using a maiden name and false address) engages in conduct so serious that reprimands and fines will ordinarily be manifestly inadequate; cancellation of licence and a period of disqualification will usually be the only appropriate protective order. The absence of actual financial loss to the principal does not diminish the seriousness of the breach. The Tribunal has power under s 103(1) to impose a global penalty for multiple breaches but is not required to first determine separate penalties in isolation.
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