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Virginia · 18VAC135-20-335Do transaction coordinators need a license in Virginia? The Board's two lists

A Virginia Real Estate Board regulation effective April 1, 2026 splits brokerage work into two lists (18VAC135-20-335). Only a licensee may show property, hold an open house, answer questions on listings, title, financing, closing, contracts, brokerage agreements and legal documents, discuss, explain, interpret or negotiate a contract or listing with anyone outside the firm, or negotiate commissions and referral fees (subsection A). An unlicensed individual may, among other things, do general clerical work and give information shown on the listing, submit listings and changes to the MLS, follow up on loan commitments after the contract is ratified, schedule appointments, record and deposit escrow funds, prepare contract forms for the licensee's and supervising broker's approval, assemble closing documents, obtain public information from government offices, and do anything else in the regular course of business that doesn't need a license (subsection B). The supervising broker must take reasonable steps so that only licensees do licensed work, and must adequately supervise all unlicensed individuals or entities associated with the firm or its licensees (18VAC135-20-165).

Unlicensed staff may (subsection B, selection)

  1. Loan follow-up

    Follow up on loan commitments after the contract is ratified.

  2. Closing file

    Assemble closing documents; obtain public information from government offices.

  3. Forms

    Prepare contract forms for the licensee's and the supervising broker's approval.

  4. Escrow and scheduling

    Record and deposit escrow funds; schedule appointments.

Only licensees may (subsection A)

  1. Show and host

    Show property or hold an open house.

  2. Answer questions

    On listings, title, financing, closing, contracts, brokerage agreements and legal documents.

  3. Explain or negotiate

    A contract, listing or lease with anyone outside the firm.

  4. Fees

    Negotiate or agree to commissions, splits, management or referral fees.

What an unlicensed TC can do

  • Run the post-ratification checklist – loan commitment follow-ups, deadlines, the closing file.
  • Route any question from the other side about title, financing, closing or contract terms to the licensee.
  • Work under the supervising broker, who must supervise unlicensed staff (18VAC135-20-165).

Questions about Virginia TC licensing

Can an unlicensed transaction coordinator work in Virginia?

Yes, within 18VAC135-20-335(B) – for example following up on loan commitments after ratification, assembling closing documents and preparing contract forms for the licensee's approval – but not answering questions on title, financing, closing or contracts (subsection A).

Can unlicensed staff handle earnest money in Virginia?

They may record and deposit escrow funds (18VAC135-20-335(B)(9)); the broker's escrow rules still apply.

Related guides

Give each deadline and follow-up an owner in ClosingCode, so the licensee sees the questions that need a license.

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Sources: 18VAC135-20-335 (effective April 1, 2026) and 18VAC135-20-165 (law.lis.virginia.gov, read October 26, 2026).

General information, not legal advice. 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.