TC licensing · State comparisonTransaction coordinator license requirements by state: what an unlicensed TC may and may not do
The regulators in these seven states address transaction coordinators through their rules on unlicensed assistants – lists of which tasks count as brokerage and which don't. The common ground is clear: administrative work under a licensee's direction – tracking documents and deadlines, gathering information, ordering services, scheduling and typing forms a licensee prepared or approved – is allowed, while discussing, explaining or negotiating contract terms, showing property, soliciting business and commission-based pay stay with licensees. The states differ at the edges. Texas says an unlicensed person may not review a contract or facilitate a transaction (TREC guidance). California's DRE lets an unlicensed assistant review files for completeness, with the licensee making the final determination. New Mexico expressly allows a coordinator directed by the broker to gather and follow up on transaction information after a contract is executed, but bars attending a closing without the broker (16.61.21 NMAC). New Jersey bars answering any questions on title, financing or closings (Real Estate Commission guidance). Utah limits an assistant's courier work to delivering documents without discussing or completing them, and requires pay at a predetermined rate not contingent on transactions (Utah Admin. Code R162-2f-401g). South Carolina puts its list in the statute (S.C. Code §40-57-135(K)), and North Carolina's Commission keeps explaining offers and contracts with licensed brokers.
The states
Texas (TREC)
Administrative work as directed; an unlicensed person may not review a contract or facilitate a transaction.
California (DRE guidelines)
Most coordination work with the broker's knowledge and consent; no discussing terms.
North Carolina (NCREC)
Compile documents and type forms; only brokers discuss or explain contracts.
South Carolina (§40-57-135(K))
Statutory list of what unlicensed staff may not do; no explaining documents or commission-based pay.
New Mexico (16.61.21 NMAC)
Post-contract coordinator role allowed under a broker's direction; no preparing contracts or attending closing alone.
New Jersey (Commission guidance)
Track documents and follow up on loans after contract; no answering title, financing or closing questions.
Utah (R162-2f-401g)
Broker permission; only tasks that need no license – no completing forms; pay not contingent on transactions.
What stays with licensees in these states
- Discussing, explaining or negotiating contract terms with anyone outside the firm.
- Showing property and soliciting buyers, sellers or listings.
- Pay based on a percentage of commission or the success of the deal.
Questions about transaction coordinator licensing
Do I need a real estate license to be a transaction coordinator?
It depends on the state and the tasks: in these seven states, administrative coordination under a licensee's direction is allowed without a license, but explaining or negotiating terms, showing property and soliciting business require one.
Can an unlicensed TC be paid a percentage of the commission?
South Carolina's statute bars pay based solely on real estate activity, such as a percentage of the commission (§40-57-135(K)); Utah requires a predetermined rate not contingent on transactions or set by commission sharing (R162-2f-401g(3)); and New Jersey's Commission says pay shouldn't depend on the success of the activity.
The state guides
Track each deal's deadlines and documents in ClosingCode, with an owner and a due date on every task.
Start free trialSources: TREC guidance on unlicensed individuals (2024); California DRE Guidelines for Unlicensed Assistants (2018); NCREC Bulletin on unlicensed assistants; S.C. Code §40-57-135(K); 16.61.21 NMAC; New Jersey Real Estate Commission guidance on unlicensed assistants (2015); Utah Admin. Code R162-2f-401g – read for the linked guides.
General information, not legal advice. The broker decides what an assistant does. ClosingCode is software; it is not a law firm or brokerage. This guide is not a substitute for the advice or services of an attorney.