An unlicensed transaction coordinator can legally handle most of the administrative work in a real estate file: entering listings, assembling closing documents, ordering inspections, and chasing signatures. What they cannot do is exercise judgment. Negotiating, advising on price or terms, showing property, and originating documents all require a license in most states. The boundary is not drawn by job title. It is drawn by discretion, and it shifts from state to state in ways the popular checklists get wrong.
What an unlicensed transaction coordinator actually spends the day doing
The 2024 NAR Member Profile reports that 15% of REALTORS work with a personal assistant, and that 46% of those assistants are unlicensed. The same report lists what those assistants spend their time on: processing new listings and entering them in the MLS (82%), managing closing paperwork (62%), preparing comps (62%), and placing or tracking listing advertising (60%).
The four most common assistant tasks are not filing and phone-answering. They are MLS data entry, closing paperwork, pricing work, and advertising, and every one of them sits within reach of the license boundary. Nearly half the people doing that work hold no license at all.
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Put real numbers on it. In a 40-agent brokerage, roughly six agents work with an assistant. Around three of those assistants are unlicensed. Two of the three are preparing comps. Comps are the single task where two of the largest state regulators point in opposite directions, which means a brokerage operating in more than one state can have two people doing identical work where one is compliant and the other is not. Same job title, same task, different answer.
The discretion test
Most published guidance on what an unlicensed transaction coordinator may do is a list of allowed and forbidden tasks. Lists age badly, they never cover the task in front of you, and they conflict across states. A better approach is to test the task itself. Four questions decide whether work crosses the license line.
Note: this is a practical screen for operators, not legal advice. Your state commission’s text governs.
1. Does it require an opinion about value, price, or terms?
Assembling data is clerical. Deciding what the data means is licensed activity. Arizona states this directly, prohibiting unlicensed staff from providing “advice, pricing, or opinions of value to a consumer.”
2. Does it influence a party’s decision to enter or change a deal?
This is negotiation, and it is the one prohibition that holds in every state examined. Texas requires a license to “solicit listings or to negotiate.” California warns that courts read negotiation broadly enough to include activity that assists in the negotiation or closing of a transaction.
3. Does it create or alter the substance of a document, rather than transcribe it?
Typing a contract at a licensee’s direction is permitted in Texas. Originating one is prohibited in Arizona. The difference is authorship, not keystrokes.
4. Does it put the unlicensed person alone with a prospect and a property?
Texas defines showing to include “unlocking or providing access onto or into a property,” which means handing over a lockbox code can be unlicensed practice even if no conversation happens.
The test also explains an exception that confuses people. California permits an unlicensed transaction coordinator to prepare a comparative market analysis, but only “subject to the approval of, and for use by, the licensee.” That is not a contradiction of question one. The mechanical assembly moves to the assistant while the opinion, the approval, and the delivery stay with the licensee. The discretion never transfers.
| Task | Test it trips | Typical outcome |
|---|---|---|
| Entering a listing in the MLS from a licensee-approved sheet | None | Permitted |
| Assembling a comp set for licensee review | 1 (partially) | Permitted in CA, prohibited in AZ |
| Telling a caller the list price already advertised | None, if self-identified as unlicensed | Permitted in TX |
| Answering why the seller priced it that way | 1 | Prohibited |
| Giving a buyer’s agent a lockbox code | 4 | Prohibited in TX |
| Drafting an addendum for the agent to review | 3 | Prohibited in AZ, permitted in TX if directed |
| Calling a lender for a status update | None | Permitted |
| Asking a seller to accept a later closing date | 2 | Prohibited everywhere |
Where states disagree about the unlicensed transaction coordinator
The widely copied “five things an unlicensed assistant can never do” article is wrong in at least two of the five largest markets. Only the negotiation prohibition is universal. The rest vary, and the variation runs in both directions.
| State | Governing source | What makes it different |
|---|---|---|
| California | Bus. & Prof. Code 10133.2; DRE unlicensed assistant guidelines | Most permissive on pricing. Unlicensed staff may prepare a CMA for licensee approval, and may cold-canvass for general interest. |
| Texas | 22 Tex. Admin. Code 535.4 and 535.5, both amended effective 1/1/2024 | Strictest on access. “Showing” includes unlocking a door or hosting an open house. Clerical staff must identify themselves as unlicensed to callers. |
| Arizona | ADRE Substantive Policy Statement 2025.02, revised February 2025 | Most explicit prohibitions, and the newest text. Bars originating documents and any opinion of value. |
| Washington | RCW 18.85.151(5) and (13) | The outlier. Unlicensed staff may show rental units and execute leases under direct instruction, but only in property management. |
| Florida | Fla. Stat. 475.01(1)(a) and 475.42(1)(a) | No published FREC guidance exists at all. Only the statutory definition and a third-degree felony penalty draw the line. |
Florida is the one most often misreported. Searching for Florida rules on unlicensed assistants returns confident task lists attributed to the regulator. The Florida Real Estate Commission has published no such document. The commonly circulated list originates with a trade association, not with FREC, and no Florida Administrative Code rule on point exists. A brokerage relying on that list is relying on convention, not law.
Washington is worth a second look for a different reason. Its unlicensed assistant guidance page now sits on a legacy state subdomain, and the Department of Licensing states that the guidance is being updated. The statute is stable, but the interpretive layer is in motion. Anyone citing a Washington task list should check whether it predates the rewrite.
What enforcement looks like when it lands
Regulators do act on unlicensed transaction coordinator work, and the published record is specific. In an October 2022 North Carolina Real Estate Commission bulletin, a Greensboro broker was disciplined after the Commission found he “employed an unlicensed administrative assistant” and “allowed the unlicensed assistant to show properties for sale on three separate occasions.” The Commission suspended his license for twelve months, then stayed the suspension. Three showings, one broker’s license.
The penalties behind these rules are not administrative slaps. California can fine an individual up to $20,000 with up to six months in county jail, and up to $60,000 for a corporation. Texas treats unlicensed practice as a Class A misdemeanor carrying up to $4,000 and a year in jail, and TREC can add administrative penalties of up to $5,000 per violation, where each day a violation continues can count separately. In Florida, operating without a license is a third-degree felony.
There is a second exposure that catches brokers who never intended to break anything. California makes it unlawful for a broker to “retain, compensate, directly or indirectly, any person for performing any of the acts within the scope of this chapter who is not a licensed real estate broker.” Florida has a parallel prohibition on sharing a commission with an unlicensed person. Paying an unlicensed transaction coordinator a per-file fee for administrative work is fine. Paying them a slice of the commission for work that turned out to be licensed activity is a separate violation from the activity itself.
The supervision failure is its own charge as well. California disciplines a broker who “failed to exercise reasonable supervision over the activities of his or her salespersons,” and the state regulator’s own August 2025 consumer alert ranked failure to supervise as the second most common enforcement violation and employing unlicensed individuals as the third. Those are the regulator’s words about its own docket, not an industry prediction. For the broader picture of what else draws citations, our breakdown of common compliance violations covers the adjacent failure modes.
Supervision is a systems problem, not a memory problem
Here is where most brokerages get this wrong. They treat the license boundary as something a well-trained unlicensed transaction coordinator keeps in their head. That works at five files. It stops working at fifty.
Every task in a file has to be classified as clerical or licensed. The classification changes by state. It changes again when a coordinator supports agents in two states. The licensee’s approval has to happen before the work goes out, not after. And a year later, when a state commission asks who prepared a document and who approved it, someone has to produce the answer. A brokerage running twelve agents across three states is asking one person to apply a shifting four-part legal test dozens of times a day, from memory, while also closing files.
That is not a training problem. It is a design problem. The boundary has to live in the workflow rather than in a person’s recall, which means four things have to be true of the system itself:
- Tasks arrive already classified, so clerical work and licensed work are not two items on the same undifferentiated to-do list.
- Nothing needing licensee sign-off can leave the file until that sign-off is recorded. Remembering to ask is not a control.
- The rules know what state they are in. Assign the same comp task in Phoenix and in Sacramento and it should behave differently, because it legally does.
- Every action writes down who did it and who approved it. That is the difference between answering a commission inquiry and reconstructing one.
This is the argument for treating coordination as infrastructure. ReBillion operates as an AI control plane that orchestrates your TMS, CRM, signature, and communication tools as one system. The classification and the approval record then hold across every file instead of varying with whoever is staffing it. An end-to-end audit trail and provable supervision turn out to be the same capability wearing two names. A broker who can answer “who approved this, and when” in seconds is in a different position from one who cannot, and that difference is architectural.
None of this removes the licensee from the loop. It does the opposite. It makes the licensee’s approval a required, recorded step instead of an assumed one, which is precisely what broker of record liability turns on. Brokers building this into their operations from the start should start with the brokerage compliance checklist, and Texas brokerages should read it alongside the state specifics in our Texas transaction coordinator guide. If you want to see how the control plane handles the approval and attribution layer, the ReBillion pricing page lays out what each tier includes.
Frequently asked questions
Can an unlicensed transaction coordinator show a property?
In most states, no. Texas is the strictest, defining showing to include unlocking or providing access onto or into a property, and hosting an open house. Even handing over a lockbox code can qualify. Washington is the exception: unlicensed staff may show rental units and execute leases under direct instruction, but only in property management, not in sales.
Can an unlicensed transaction coordinator prepare a CMA?
It depends on the state, and this is where national checklists fail. California expressly permits an unlicensed transaction coordinator to prepare a comparative market analysis, subject to the approval of and for use by the licensee. Arizona expressly prohibits unlicensed staff from providing pricing or opinions of value. In Washington, broker price opinions require a license.
Can a broker pay an unlicensed transaction coordinator a commission split?
No. California makes it unlawful for a broker to compensate, directly or indirectly, an unlicensed person for acts requiring a license, and Florida separately prohibits sharing a commission with an unlicensed person. A flat fee or hourly rate for genuinely clerical work is the standard compliant structure.
What are the penalties for using an unlicensed transaction coordinator improperly?
California allows fines up to $20,000 and six months in county jail, rising to $60,000 for a corporation. Texas treats it as a Class A misdemeanor with up to $4,000 and a year in jail, plus TREC administrative penalties up to $5,000 per violation, with each day potentially counting separately. Florida classifies unlicensed practice as a third-degree felony.
Does an unlicensed transaction coordinator have to say they are unlicensed?
In Texas, yes. Clerical or administrative employees may confirm advertised information about size, price, and terms only when identified to callers as such. Other states do not impose an equivalent disclosure requirement in their published text, which makes self-identification a sensible default policy rather than a universal rule.
Is a transaction coordinator required to be licensed?
No state issues a transaction coordinator license, so no state requires one. The question is always which tasks the role performs. An unlicensed transaction coordinator doing purely administrative work is fine, while the same title doing negotiation, pricing advice, or property showings is not. The title is unregulated; the activity is not.
About the author
Written by Vikas Malpani, co-founder and CEO of ReBillion, a CAR-certified transaction coordinator who has built transaction operations for brokerages across multiple states. Connect on LinkedIn.
Last reviewed July 2026. Statutory citations were verified against primary regulator sources at the time of writing. State rules change; confirm current text with your state real estate commission before setting brokerage policy. This article is operational guidance, not legal advice.
Written by Vikas Malpani
Vikas Malpani is the CEO and Co-Founder of ReBillion and a CAR-Certified Transaction Coordinator. A serial real estate technology entrepreneur with 15+ years across technology and real estate operations, he was named to MIT Technology Review's TR35 list of young innovators. At ReBillion he leads the AI systems that deliver compliant, accurate transaction coordination for brokerages and agents across all 50 US states. Connect with Vikas on LinkedIn: https://www.linkedin.com/in/vikasmalpani/
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