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Sellers · Template

Course-of-dealing pushback

When the agency has routinely sought your approval on small items but then acted unilaterally on a substantial matter — drafting a vendor warranty, contacting your solicitor, engaging a provider at your cost. NZ contract law recognises that established practice affects how the agreement is interpreted. PCCC Rule 9.1 runs alongside, independent of contract.

When to use this

  • The agency has taken a specific action on your behalf that you were not asked to approve.
  • Over the listing period, the agency has consistently asked your approval for smaller matters (wording, scheduling, formatting).
  • The action has a real or potential cost — legal fees, a binding commitment, a provider engagement.

The template

To: [Listing agent name] <[agent email]>

Cc: [Branch manager]

Subject: Re: [Specific action — e.g., Contact with [solicitor name] on [date]]

Hi [agent first name],

Regarding [specific action — e.g., the agency's contact with my solicitor on [date] concerning [subject], or the drafting of the vendor warranty on [date]]:

The pattern of our working relationship since [start of listing date] has been that you have sought my approval before acting on my behalf on substantive matters. Recent examples: [list 2–3 specific occasions where approval was sought — e.g., the wording of the disclosure statement on [date], the open-home timing on [date], the marketing photograph selection on [date]].

On this occasion, the agency took the action without obtaining my prior approval. As a result, I may incur [specific cost — e.g., legal fees from my solicitor, obligation to remediate under the warranty, provider invoice].

Please confirm in writing whether the agency accepts responsibility for any costs arising from this action — yes or no.

If your position rests on a specific clause of the agency agreement, please identify the clause. I note two matters:

  1. NZ contract law recognises that established practice between parties ("course of dealing") affects how a contract is interpreted and applied. The pattern of your requesting my approval since [start of listing date] has established an expectation that approval will be sought on substantive matters.
  2. Rule 9.1 of the Professional Conduct and Client Care Rules 2012 imposes a statutory duty to act in the client's best interests. This duty is independent of any agency-agreement clause and cannot be displaced by contract.

Please reply in writing by [date, 5-7 working days].

Kind regards,
[Your name]

What the reply tells you

  • Acceptance. "You're right, we should have asked first. We will cover any resulting costs." The matter is resolved. Continue with normal sale processes.
  • Specific clause citation. "Under clause [X] we are authorised." The course-of-dealing and Rule 9.1 arguments then apply. If the agency maintains the position, the record supports escalation to an REA complaint or Disputes Tribunal claim.
  • Evasion. "We don't understand the question" or "let's just move forward." Record this. Evasion of a written yes-or-no question about Rule 9.1 responsibility is itself significant in any subsequent proceeding.

Legal basis

Course of dealing — a doctrine of NZ contract law recognising that established practice between parties supplements or modifies the written contract. Discussed in Burrows, Finn & Todd, Law of Contract in New Zealand (the standard NZ textbook).

Estoppel by convention — where both parties have operated on a shared understanding, neither may later assert a position inconsistent with that understanding.

PCCC Rule 9.1 of the Professional Conduct and Client Care Rules 2012: "A licensee must act in the best interests of a client and act in accordance with the client's instructions unless to do so would be contrary to law." Statutory duty; not displaceable by contract.

See Selective Approval Theatre for the pattern in detail.