1. The Defendant imposes an administrative fine set forth in Nos. 4, 5, 10, 11, 15, 17, and 22 of the attached list against the Plaintiff.

1. Basic facts

A. A regional housing association is a regional housing association under the Housing Act, which completed the authorization of establishment on January 18, 2017, in order to implement the business of newly constructing apartment units (hereinafter “instant apartment units”) and supplying them to its members, etc. (hereinafter “instant business”). A regional housing association is an organization temporarily organized to prepare for the implementation of the instant project.

B. The instant promotion committee selected D (hereinafter “D”) as the agent of the instant project, and D was a sales agency of the instant apartment complex, and D was selected as E (hereinafter “E”) as the sales agency of the instant apartment complex.

C. On November 25, 2015, the Plaintiff submitted to D a letter of intent to participate in construction (hereinafter “instant letter of intent to participate in construction”) with respect to the instant project, as follows:

A letter of intent to participate in construction

(b)a requirement for project participation 1) An application for approval for the project plan of this project corresponding to the proposed paragraph (a) above is received from the approving authority and us (Plaintiff);

hereinafter the same shall apply.

2) We have no civil or criminal responsibility for all disputes, such as securing land ownership, granting authorization and permission process, and raising the problems of a member or a person who wishes to join an association in connection with the project, etc., to be established in the future, only if internal investment deliberation is to pass through, prior to the conclusion of the construction contract. If a dispute is brought against us, us must settle the dispute at the expense of Ha, promoting, or cooperative regardless of us’s participation in the construction of the project. 2) The M/H (Public Relations) establishment of the project and the recruitment of members, and the name “A (State)” of “A subject to preferential bargaining,” but the “member contribution” and the “member contribution paid in the course of inviting members.