agency

Customer and Ministerial Acts (DC)

DC agency law is statutory and abrogates conflicting common law. A customer is a person who has not entered a brokerage relationship but for whom the licensee performs ministerial acts, meaning routine acts involving no discretion or judgment, such as unlocking a door, delivering documents, or passing along factual information. Without a brokerage agreement, a person is presumed to be a customer, not a client. Payment of compensation alone does not create a brokerage relationship, and neither does using the MLS.

Exam tip
'No contract, no client. Ministerial means no judgment.' Advising a buyer on what price to offer is not ministerial.
Example
A listing agent sends an unrepresented buyer HOA documents and the open house date. These are ministerial acts, and the buyer remains a customer.

Related terms & state variants

Sources

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Last verified: 2026-10-23