Under Illinois law, is a consumer who receives services from a licensee always considered a client?

Correct Answer

C) No, some consumers are customers rather than clients, and the full duties of representation attach only when a client relationship has been established.

Illinois law under the Real Estate License Act (RELA) and related rules expressly distinguishes between clients and customers. A client is a consumer who has entered into a brokerage agreement with a licensee, triggering duties such as promoting the client's best interests, confidentiality, and loyalty. A customer, by contrast, receives limited ministerial services without a representation relationship, and the full fiduciary-style duties do not apply. The distinction is fundamental to how Illinois structures agency obligations.