All appeals by the Defendants are dismissed.

1. Summary of grounds for appeal (misunderstanding of legal principles and improper sentencing)

A. In light of the legal principles, the first instance court interpreted Article 85 subparagraph 9 of the Act on the Maintenance of Urban and Residential Environments (hereinafter “Do Act”) to the effect that a promotion committee shall punish a person entrusted to implement a rearrangement project by a promoters’ association without registration under Article 69 (1) of the said Act, regardless of whether the promotion committee legally obtained approval from the head of the Si/Gun under the said Act, but such interpretation goes against the principle of statutoryism by extensively interpreting or analogically interpreting penal statutes in the direction unfavorable to the defendant.

No license shall be granted.

B. The first deliberation punishment (each fine of KRW 2 million) against the illegal Defendants is too unreasonable.

2. Determination

A. Regarding the assertion of misunderstanding of legal principles, Article 69 (Registration of Specialized Management Business for Rearrangement Projects) (1) of the related regulations (registration of Specialized Management Business) (1) A person who intends to entrust or seek advice on any of the following matters from the promotion committee or the project implementer, shall register with the Mayor/Do Governor or the Mayor/Do Governor, who has prepared the standards for capital, technical personnel, etc. prescribed by Presidential Decree (excluding modification of minor matters prescribed by

Provided, That this shall not apply to a government-invested institution, etc. prescribed by Presidential Decree which conducts business related to rearrangement and improvement, such as housing construction and appraisal.

1. Vicarious execution concerning the consents to partnership establishment and to rearrangement projects;

2. Vicarious execution of affairs concerning the application for authorization on establishment of an association;

3. Review on feasibility and preparation of a plan for implementing improvement projects;

4. Support for the business to select the designer and work executor;

5. Agency for affairs concerning the request for a project executor;

6. Vicarious execution concerning the formulation of management and disposal plans;

7. Where the head of a Si/Gun has selected a management entity specialized in improvement projects pursuant to Article 77-4 (2) 2, the following affairs necessary for establishing the promotion committee:

(a) the requisition of written consent;