QUESTION: Sir John, what is colorum? Are all colorum agents illegal?
ANSWER: Colorum means unregistered or unlicensed in PRC and they are generally illegal. There are some types of colorum agents that are NOT ILLEGAL such as the holder of Special Power of Attorney (SPA), persons who act in pursuance of court order such as those selling foreclosed properties, receivers/trustees/assignee in bankruptcy or insolvency proceedings.
A colorum who receive "commissions" are already covered by the penalties set forth for illegal real estate service practice stated in RA 9646. However, bank employees are entitled to receive salaries from the bank (but not from the owner of a foreclosed property). Receivers/assignees/trustees can receive property management fees, which the court normally specify in the bancruptcy resolution. SPAs cannot demand compensation, but there is no law that will prevent the owner from giving out-of-the-pocket gratuities to SPAs.