Under case law, Freeman said, documents produced in the ordinary course of business generally do not fall
under the exemption cited by the Cuomo administration.
If, in this scenario, the resident manager was instructed to immediately remit any security deposits and rents to the brokerage for deposit into its trust accounts, and if he or she were not involved in negotiating and executing leases, no licence would be required
under the
exemption for resident caretakers
cited above (Section 2.14 of the Real Estate Services Regulation).