Managing Real Estate Broker License Defense After an Agent’s Misconduct

 Posted on September 30, 2026 in Professional License Defense

If an agent you supervise violates Illinois real estate law, the Illinois Department of Financial and Professional Regulation (IDFPR) may review your own conduct as the designated managing broker. The IDFPR does not automatically discipline you just because a sponsored agent broke a rule. Instead, it investigates whether you fulfilled your own duties. 

If the IDFPR is reviewing you in 2026, The Law Offices of Joseph J. Bogdan, Inc. can help. Our Chicago real estate license discipline defense lawyer can help you respond to the investigation.

Can a Managing Broker Be Disciplined for an Agent's Actions?

A managing broker can face discipline in connection with an agent's misconduct. However, the question the IDFPR asks is not whether an agent did something wrong. It’s whether the broker’s own policies, training, and oversight met legal requirements.

Under 225 ILCS 454/20-20, the IDFPR can discipline a managing broker if the managing broker fails to provide an appropriate written company policy or if the managing broker fails to perform other duties listed in the Real Estate License Act. For example, investigators may review whether a broker trained the agent, enforced office policies, supervised transactions, reviewed advertising, or addressed earlier known problems.

What Supervision Duties Does a Designated Managing Real Estate Broker Have?

Under Illinois law, a broker’s managing responsibilities often include:

• Putting the company's written policies into practice

• Training licensees and employees on company rules and Illinois real estate law

• Helping sponsored licensees with real estate transactions

• Supervising the company's special accounts, including accounts that hold client or transaction funds

• Supervising advertising by licensees in your office

There are additional responsibilities when an agent has not completed the required 45 hours of post-license education. In those cases, the broker must directly handle earnest money, escrow funds, and contract negotiations and approve that agent's advertising.

How Do You Protect Your Real Estate Broker’s License After an Agent's Misconduct?

If IDFPR starts investigating an agent you supervised, gather records showing how you trained that agent, what office policies you required the agent to follow, and how you monitored the agent's transactions, advertising, and handling of client funds. Do not delete, revise, backdate, or replace records after you learn about the investigation.

The IDFPR may contact you by letter, email, phone, or through an investigator if it receives a complaint or begins reviewing conduct connected to your office. The Department also has authority to inspect brokerage offices. They can inspect areas open to the public during normal business hours. 

If you end the agent's sponsorship, document the reason for the decision and the date it took effect. You also need to report the sponsorship change on time. By law, the person or company ending the sponsorship must notify the IDFPR within 24 hours. After the sponsorship ends, the agent cannot perform licensed real estate work until another sponsoring broker registers the agent.

If the IDFPR later issues a final order suspending, revoking, or otherwise disciplining your license, you can ask a circuit court to review that decision. This process is called judicial review. The court does not retry the entire case from the beginning. It reviews the agency's decision and the record to determine whether the IDFPR followed the law and had a sufficient basis for its ruling.

Schedule a Free Consultation With Our Peoria, IL Real Estate License Defense Attorney

Attorney Joseph Bogdan has over 20 years of experience defending licensed professionals. He is both a registered pharmacist and an attorney. He also serves as an expert witness in pharmaceutical matters, including cases involving controlled substances. That work has given him a detailed understanding of how state regulators build supervision and recordkeeping cases.

Contact The Law Offices of Joseph J. Bogdan, Inc. at 630-310-1267 to talk to our Chicago professional license defense lawyer today.