The National Association of REALTORS® issued a policy statement today clarifying its position on Zillow’s new ChatGPT.com integration. In it, NAR reaffirms support for technological innovation while reminding the industry that all new tools must comply with MLS rules and data license agreements.
That is a sensible baseline. But the statement misses both the tree and the forest: the tree being the specific question of control, and the forest being the broader integrity of the Broker Reciprocity system that defines the American MLS.
What NAR said
NAR’s statement outlines that each MLS and Realtor Association is responsible for assessing whether technologies like Zillow’s ChatGPT.com app comply with IDX policy. It advises MLSs to consider whether MLS data is transmitted to an unauthorized party, whether the participant maintains control over their display, and whether all disclosure requirements are met.
It also notes that mobile apps are permitted under IDX rules and that NAR supports any technology that enhances listing exposure and improves property search, so long as it complies with those rules.
What NAR missed
The fundamental question is not whether Zillow followed IDX display conventions within its own environment. It is whether ChatGPT.com, a domain operated by OpenAI, is under Zillow’s control. IDX rules are unambiguous: listing data can only be displayed on websites and applications under the control of the participant. Clearly, ChatGPT.com and the iframe template is not under the control of Zillow, nor is it Zillow’s website. Zillow’s website is Zillow.com.
Language matters. NAR indicates with careful wording that they have not looked at the Zillow app on the website of ChatGPT.com – which is clearly a third party website. They rely solely on public statements from Zillow and ChatGPT.
They say that the display on ChatGPT.com is a mirror of what is on Zillow. Nowhere in the Broker Reciprocity rules are stipulations that mirroring a property search solution on a third-party website is permitted. If this is a new policy statement, then every broker may place their property search solution on any website owned and operated by any third party. Literally, every website in the world would be permitted to display any broker’s property listing search. This is a dramatic new rendering of policy that reaches far beyond the original intent of Broker Reciprocity, whose simplest understanding: You can display my listings on your website if you reciprocate by allowing me to display your listings on my website.
ChatGPT.com is not a Zillow-owned or Zillow-operated site. By allowing Zillow’s app to display MLS listing data there, Zillow effectively extends Broker Reciprocity to a third-party domain under the control of ChatGPT. Brokers have been prohibited from doing that for decades. If any broker could syndicate IDX listings onto other global platforms, the entire reciprocity framework would collapse.
How enforcement should work
NAR correctly points out that each MLS is responsible for enforcement. That means that NAR’s policy statement is not claiming in any way that Zillow’s publication of listings on the ChatGPT.com domain is authorized. NAR also somewhat mischaracterizes how disputes should be raised. When one broker believes another is misusing IDX data, the remedy is not an MLS compliance inquiry alone. It is a professional standards complaint.
Brokers are accountable to one another through the REALTOR® Code of Ethics and the cooperative agreements that govern MLS participation. If a broker believes that Zillow’s use of ChatGPT.com is Zillow’s website domain and is not under the control of Zillow, that complaint should be filed as a violation of the Broker Reciprocity display limitation.
Why this matters
Broker Reciprocity was built on trust and mutual restraint. Each participant agreed to share listings only within clearly defined boundaries on broker-controlled websites and apps so that cooperation could thrive without giving up control of the data.
Expanding display to third-party AI platforms without explicit authorization erodes that trust. It sets a precedent that data licensed for display on Zillow.com could soon appear on any conversational or search platform, from Bing.com to Yahoo.com to Perplexity.com, etc. without brokers’ knowledge or consent.
What happens next
MLSs have a duty to seek clarity. They can and should request detailed documentation from Zillow about how listing data is being transmitted, stored, and displayed on ChatGPT.com. They should also confirm whether that display meets the participant control test and whether brokers have granted permission for this type of exposure.
If the answer is no, enforcement should follow the established path: a professional standards complaint initiated by a participant, reviewed by the professional standards committee, and adjudicated according to existing IDX rules.
The bigger picture
NAR’s policy statement offers caution but avoids clarity. Until the association clearly defines what control means in the age of AI, it risks losing both the tree and the forest.
How to issue a professional standards complaint
If a broker or MLS participant believes that another participant has violated IDX rules or misused MLS data, the process for filing a professional standards complaint is straightforward and confidential:
- Identify the rule or article violated.
Review your local MLS rules and the REALTOR® Code of Ethics, particularly Article 12 (truth in advertising and representation) and the MLS policy on Broker Reciprocity. Note the specific section or rule that appears to have been violated. - Document the evidence.
Gather screenshots, URLs, or other documentation showing where and how the listings were displayed outside an authorized domain or application. Include date stamps or examples of attribution issues if relevant. - File the complaint with your local association.
Submit your written complaint to the Professional Standards Administrator at your local REALTOR® association. Many associations provide a standard form that requires your contact information, the respondent’s name, and the alleged rule violation. - The association reviews for validity.
The Grievance Committee will review the submission to determine if it merits a hearing. If accepted, the matter is referred to a Professional Standards hearing panel composed of peers who review evidence and testimony. - Resolution and enforcement.
If the panel finds a violation, they may impose sanctions ranging from warnings to suspension of MLS access. Decisions can typically be appealed within the timelines set by your local association.
This process exists to protect fairness, transparency, and cooperation. Filing a complaint is not punitive; it is how brokers preserve the trust and integrity that make Broker Reciprocity possible.
Here is NAR’s policy statement:
Implementing and integrating new technologies, like artificial intelligence (A.I.), into the home-buying and selling process has the potential to better serve consumers by enhancing the exposure of MLS listings and improving property search. Provided the use of technology is in accordance with MLS rules and data license agreements, NAR recognizes the importance that innovation plays in fostering more transparent, competitive, and fair housing markets. Compliance with MLS rules further fulfills the necessary display requirements and required authorizations, such as from listing brokers, that avoid misuse of MLS data.
For enforcement, each MLS is individually responsible for conducting its own assessment of technologies that use and display MLS data. This includes considering known public information and determining whether the MLS needs more information from the parties involved or otherwise as part of its evaluation assessment.
To determine if Zillow’s ChatGPT application complies with IDX policy, an MLS should consider things such as whether MLS data is being transmitted to an unauthorized party, if the displaying Participant maintains “control” over their display, and if the display fulfills the disclosure and display requirements outlined in local IDX rules. It should also be noted that the display of MLS data on mobile apps is permitted under the existing IDX policy.
To support MLSs, REALTORS®, and the consumers they serve, NAR will continue to monitor the development and use of similar technologies and work with industry stakeholders to provide needed guidance, resources, and educational materials.
Talking Points
- Zillow developed a new ChatGPT app to allow consumers to initiate home searchers through AI.
- This is a first of its kind for real estate on an AI platform.
- Based on what Zillow and ChatGPT have said publicly, the information available through the Zillow app on ChatGPT is controlled by Zillow, mirrors what’s on Zillow’s website and their mobile app, and is not retained, indexed, or trained by ChatGPT.
- Zillow manages the display on its app, including all field-level controls and ensures MLS and legal compliance for fields, disclaimers, and attributions.
- As long as the use of MLS listings complies with MLS rules, NAR supports efforts to better serve homebuyers and sellers by enhancing the exposure of home listings and improving property search.
- Compliance with MLS rules is determined by each MLS.
- MLSs have the ability to ask Zillow for more information if they believe that’s necessary for their assessment of local MLS Rules and data license agreements.
- Other brokerages and MLSs can create their own apps on ChatGPT or other AI platforms in a manner similar to what Zillow has developed for ChatGPT.
- NAR continues to monitor how Zillow’s app displays information, and staff is available to discuss Zillow’s app with anyone who has questions or believes it’s not compliant with MLS rules.
- NAR is collaborating with RESO, CMLS, and other stakeholders to promote awareness, education, and the potential need for new MLS policies related to displaying listings using AI/LLM.
