Three states give three answers on what an unlicensed coordinator may do

California publishes a checklist and a guide. Texas answers the question with 'it depends'. Florida has no single page at all, and the statute does the work instead.

Key points

There is no federal rule on transaction coordinator scope. Every answer is a state answer.

California's DRE publishes both a web page and a detailed PDF guide on unlicensed assistants.

Texas TREC frames the answer around TRELA and Rules 535.4 and 535.5.

Florida has no single FREC page on unlicensed assistant duties; section 475.42 of the Florida Statutes governs unlicensed activity.

NAR's state-by-state table on unlicensed assistants carries a 2017 date and should not be relied on alone.

The question a coordinator gets asked more than any other, usually by a new agent and usually on a Friday, is whether they can just call the lender. The honest answer is that it depends on the state, on what is said on the call, and on whether the coordinator holds a licence. What it never depends on is how urgent the file is.

There is no national scope of practice for transaction coordination. There is no federal regulator, no reciprocity, and no single definition of the role. What exists is fifty separate treatments of unlicensed assistance, written by real estate commissions that were mostly thinking about administrative staff in a brokerage rather than an independent contractor running forty files for six agents.

California: the checklist state

The California Department of Real Estate publishes guidance on unlicensed assistants as a web page and backs it with a detailed PDF guide. The structure of the California approach is a list: activities an unlicensed person may perform, and activities requiring a licence. That makes it the most quotable of the three, and the one most often cited outside California by coordinators who do not realise they are quoting another state's regulator.

California is also the state with the most developed professional infrastructure around the role. The California Association of REALTORS runs the Certified Transaction Coordinator credential and hosts a public TC directory, and the California Association of Transaction Coordinators is the only verified state association for the profession.

Texas: the conditional answer

The Texas Real Estate Commission addresses the question in guidance titled around whether unlicensed individuals can help with Texas real estate transactions, and answers it: it depends. The guidance points to the Texas Real Estate License Act and to Rules 535.4 and 535.5, which set out what constitutes acting as a broker and what an unlicensed person may do on behalf of one.

The practical difference from California is that Texas asks the coordinator to reason from the statute rather than read a list. That is harder to hand to an agent as a boundary, and it is the reason Texas coordinators tend to write their own scope letters.

Florida: the statute and the enforcement programme

Florida is the gap. The Division of Real Estate sits under the Department of Business and Professional Regulation, and DBPR runs an unlicensed activity programme, but there is no single clean state page setting out what an unlicensed assistant may and may not do. Section 475.42 of the Florida Statutes governs unlicensed activity, and the working duty guidelines that circulate among Florida coordinators are generally PDFs published by local boards rather than by the state.

Verification note. TC Bulletin was unable to locate a single FREC-hosted page setting out permitted unlicensed assistant duties in Florida. If one exists, write to the desk and we will correct this story and date the correction.

The nine-year-old table everyone cites

The National Association of REALTORS maintains a state-by-state unlicensed assistants table and a field guide to personal assistants. Both are genuinely useful as an orientation. The table, however, carries a 2017 date, and state regulators have kept publishing since. Any scope decision that matters should be checked against the state commission's current page, not against the table.

Confirm which state's rule actually governs the file, not the state the coordinator lives in.

Read the current regulator page, then the statute or rule it cites, before writing a scope letter.

Treat NAR's table as a map, not as authority.

Where a licensed coordinator is doing licensed work, be explicit about which brokerage they are hanging that licence with.

Primary sources for this story

California DRE, unlicensed assistants guidance

California DRE, guide to unlicensed assistants (PDF)

Texas Real Estate Commission Guidance citing TRELA and Rules 535.4 and 535.5

Florida DBPR, Division of Real Estate

Florida DBPR unlicensed activity programme

NAR field guide to personal assistants

Sources cited

California DRE

Texas TREC

Florida DBPR

NAR