The Board in response to comments advocating a requirement to offer a written document defining duties scope of services and disclosure (customarily known as a contract); replies it "does not have the statutory authority to regulate firms."  Recommend statutory review to determine whether the Commonwealth has authority over a firm (an entitity with an organizing principle); to wit:

 C. D. ] A licensee who has direct knowledge that another individual or firm may be violating any of the provisions of this chapter or the provisions of Chapter 23 (§ 54.1-2300 et seq.) of Title 54.1 of the Code of Virginia shall immediately inform the board in writing and shall cooperate in furnishing any further information or assistance that may be required.