This article is part of an ongoing series covering violations of real estate law. Here, the DRE revoked the California real estate license of a broker who failed to notify the DRE within 30 days of disciplinary action from another licensing entity.
In May 2021, the California Department of Real Estate (DRE) revoked the license of Riordan Zavala, a broker since 2006 operating out of Orange, California.
In 2018, Zavala, then a member of the State Bar, was placed on a two year probation. On May 1, 2020, Zavala was disbarred from the practice of law in California and his name was stricken from the roll of attorneys due to his failure to comply with disciplinary conditions of the probation by failing to:
- timely contact the Office of Probation to schedule a meeting;
- meet with an assigned probation deputy during the probation period;
- submit two quarterly reports to the Office of Probation; and
- update an address change within 30 days of the change.
Zavala failed to report this disciplinary action to the DRE within 30 days.
Failing to notify the DRE about any disciplinary action taken by another licensing entity or authority of the state constitutes cause for suspension or revocation of the licensee under real estate law. [Calif. Business and Professions Code §10186.2]
Thus, to compound the loss of his State Bar license, Zavala’s broker license was also revoked.
Additional reporting that needs to be done within 30 days include:
- the bringing of a criminal complaint, information or indictment charging a felony against the licensee; and
- the conviction of the licensee, including any verdict of guilty, or plea of guilty or no contest, of any felony or misdemeanor. [Bus & P C §10186.2]
Other licensing bodies affect real estate licenses
The revocation of Zavala’s license highlights the importance of knowing real estate law. Further, knowing how licensing bodies and other authorities of the state interact with one another is crucial for those who have multiple licenses and professions.
When probation, disbarment, revocation or any other disciplinary action is taken against a licensee, the licensee is required to timely report this circumstance to the DRE. Nefarious behavior in one area of discipline may be a red flag of nefarious behavior in another.
Zavala lost his license to practice law for failing to timely update his address, among other things. The DRE also requires an address change to be timely submitted to remain licensed. Otherwise, the DRE has the authority to temporarily suspend or permanently revoke a real estate license. [Bus & P C §10165]
Every real estate broker and salesperson needs to inform the commissioner of any change to their mailing address, telephone number and email address no later than 30 days after making the change. [Bus & P C §10162]
To notify the DRE about an address change, timely submit a Salesperson Change Application [RE 214] or Broker Change Application [RE 204], or use the eLicensing online system provided by the DRE.
Reporting updates to the DRE is a crucial component of maintaining licensing. While this includes basic information like mailing address, phone number, and email address, it also includes more substantive matters like criminal convictions and disciplinary action by other government and licensing entities.
Ensure your loss of one source of livelihood does not lead to a loss of a second – your license to practice real estate in California.
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