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This page is not legal advice. It is only general information. Before acting, check the laws of your state and talk with your own legal counsel.
Unlicensed TCs and assistants · Effective as of October 12, 2026
State Rules for Paying Unlicensed Transaction Coordinators
Below is a list of states that have rules or guidance on how an unlicensed assistant or transaction coordinator can be paid, including whether they can be paid only when a transaction closes. Select a state or a category to filter the list. Limits on what an unlicensed person can do apply in every state, however they are paid.
50 of 50 states
| State | Status | What the rule says | Source |
|---|---|---|---|
| AlabamaAL | No specific pay rule | Clerical and administrative duties only. No pay-structure rule found. | NAR state tableApr 2020 |
| AlaskaAK | No specific pay rule | Detailed list of permitted admin tasks. No pay-structure rule found. | NAR state tableApr 2020 |
| ArizonaAZ | Barred or needs a license | Unlicensed assistants are paid for their work, unrelated to the transaction. If paid on any basis that relies on the sale, they must be licensed. A 2021 bill to formally allow unlicensed TCs did not pass. | AZ Dept. of Real Estate FAQcurrent |
| ArkansasAR | Barred or needs a license | Unlicensed assistants may be employed only at a salaried or hourly rate (A.C.A. 17-42-104). | NAR state tableApr 2020 |
| CaliforniaCA | No specific pay rule | DRE allows unlicensed TCs to do admin and file review. B&P 10137 bars paying unlicensed people for licensed acts. No rule against per-file pay found. | CA DRE guidecurrent |
| ColoradoCO | Regulator flags it | Position 20 names TCs and lists 14 permitted tasks. It says payments to an unlicensed REAP contingent on closing may violate RESPA. Position statement, not a rule. | CO Position 20 (via TC Bulletin)Aug 2026 |
| ConnecticutCT | No pay based on sales | Commission policy: unlicensed assistants may not be paid on the basis of commission, or any amount based on listings, sales, etc. | NAR state tableApr 2020 |
| DelawareDE | No specific pay rule | Only licensees may host open houses or show. No pay-structure rule found. | NAR state tableApr 2020 |
| FloridaFL | No specific pay rule | FREC lists permitted tasks. Licensees may not share compensation with unlicensed persons for licensed work (475.25(1)(h), 475.42). No per-file rule found. | Florida Realtors legal librarycurrent |
| GeorgiaGA | No specific pay rule | Rule 520-1-.07 lists permitted and barred tasks. No pay-structure rule found. | NAR state tableApr 2020 |
| HawaiiHI | No specific pay rule | Commission guidance on barred activities. No pay-structure rule found. | NAR state tableApr 2020 |
| IdahoID | Per-transaction allowed | Guideline 17: unlicensed assistants may be paid on a flat fee transaction basis or salary/hourly. Licensees should not share commissions with them. | Idaho REC Guideline 17May 2023 |
| IllinoisIL | No specific pay rule | 68 Ill. Adm. Code 1450.740 lists barred tasks. No pay-structure rule found. | NAR state tableApr 2020 |
| IndianaIN | No specific pay rule | 876 IAC 8-1-7 lists barred tasks. No pay-structure rule found. | NAR state tableApr 2020 |
| IowaIA | No specific pay rule | Rule 193E-7.13 (now renumbered under 481) is activity-based only. Broker needs a written policy on support staff. | Iowa Admin. Code 193E-7.132025 |
| KansasKS | No specific pay rule | Newsletter guidance on barred tasks. No pay-structure rule found. | NAR state tableApr 2020 |
| KentuckyKY | No specific pay rule | 201 KAR 11:440 bars unlicensed staff from attending closings. No pay-structure rule found. | NAR state tableApr 2020 |
| LouisianaLA | No pay based on sales | Commission guidance: may not be paid on the basis of real estate activity, such as a percentage of commission or any amount based on listings, sales, etc. | NAR state tableApr 2020 |
| MaineME | No specific pay rule | No published guidance found. | NAR state tableApr 2020 |
| MarylandMD | No pay based on sales | MREC guidelines: may not be paid on the basis of real estate activity, such as a percentage of commission or any amount based on listings, sales, etc. | NAR state tableApr 2020 |
| MassachusettsMA | No specific pay rule | Division guidance: avoid direct client contact, no attending closings or walk-throughs, no follow-up contact with buyers and sellers. No pay-structure rule found. | Berkshire REALTORS summary2017 guidance |
| MichiganMI | No specific pay rule | License law bars sharing a fee or commission with an unlicensed person. No specific per-file rule found. | NAR state tableApr 2020 |
| MinnesotaMN | No specific pay rule | Unlicensed cold-callers must be paid hourly, flat fee or salary. No rule on TC pay found. | NAR state tableApr 2020 |
| MississippiMS | No specific pay rule | Unlicensed staff may not attend closings or walk-throughs without a licensee. No pay-structure rule found. | NAR state tableApr 2020 |
| MissouriMO | No pay based on sales | 20 CSR 2250-8.010: may not be paid on the basis of real estate activity, such as a percentage of commission or any amount based on listings, sales, etc. | NAR state tableApr 2020 |
| MontanaMT | No specific pay rule | Board guidelines on barred tasks. No pay-structure rule found. | NAR state tableApr 2020 |
| NebraskaNE | No pay based on sales | Commission policy: may not be paid on the basis of real estate activity, such as a percentage of commission or any amount based on listings, sales, etc. | NAR state tableApr 2020 |
| NevadaNV | No specific pay rule | Informational bulletin on barred tasks. No pay-structure rule found. | NAR state tableApr 2020 |
| New HampshireNH | No specific pay rule | Commission list of approved tasks. No pay-structure rule found. | NAR state tableApr 2020 |
| New JerseyNJ | No specific pay rule | Commission guidance on barred tasks. No pay-structure rule found. | NAR state tableApr 2020 |
| New MexicoNM | No specific pay rule | Rule 16.61.21.8 allows an unlicensed coordinator to follow up after contract. No pay-structure rule found. | NAR state tableApr 2020 |
| New YorkNY | Barred or needs a license | If paid per completed transaction, the assistant must be licensed and paid directly by the broker. Hourly, per activity, or salary is fine. | NY Dept. of Statecurrent |
| North CarolinaNC | Barred or needs a license | Unlicensed assistants may be paid salary or hourly, but not per transaction, including closing bonuses. | NC REALTORS legal Q&Acurrent |
| North DakotaND | No pay based on sales | Commission article: may not be paid on the basis of real estate activity, such as a percentage of commission or any amount based on listings, sales, etc. | NAR state tableApr 2020 |
| OhioOH | No specific pay rule | Division pronouncement on barred tasks. No pay-structure rule found. | NAR state tableApr 2020 |
| OklahomaOK | No specific pay rule | No published guidance found. | NAR state tableApr 2020 |
| OregonOR | No specific pay rule | Guideline bars giving instructions to inspectors or appraisers. Regulator is considering a formal TC rule (2026). No pay rule found. | TC Bulletin on OregonAug 2026 |
| PennsylvaniaPA | No specific pay rule | Commission guideline on barred tasks. No pay-structure rule found. | NAR state tableApr 2020 |
| Rhode IslandRI | No pay based on sales | Policy L-97-1: may not receive pay computed on the basis of sales activity, listings, sales or rentals. | NAR state tableApr 2020 |
| South CarolinaSC | No pay based on sales | 40-57-135(K)(8): may not be paid solely on a percentage of commission or an amount based on listing or sales compensation. | Blair Cato on SC Practice Act2017 law |
| South DakotaSD | No pay based on sales | Commission guidelines: may not be paid on the basis of real estate activity, such as a percentage of commission or any amount based on listings, sales, etc. | NAR state tableApr 2020 |
| TennesseeTN | No pay based on sales | Commission policy: may not be paid on the basis of real estate activity, such as a percentage of commission or any amount based on listings, sales, etc. | NAR state tableApr 2020 |
| TexasTX | No specific pay rule | TCs are not defined in TREC rules. Unlicensed staff cannot show, open doors, or host open houses. No per-file pay rule found. | TREC article2024 |
| UtahUT | Barred or needs a license | May be paid at a predetermined rate not contingent on real estate transactions. No commission sharing with unlicensed assistants. | NAR state tableApr 2020 |
| VermontVT | No specific pay rule | No published guidance found. | NAR state tableApr 2020 |
| VirginiaVA | Per-transaction allowed | April 2026 rewrite removed the non-contingent pay requirement. Virginia REALTORS says per-transaction pay is now permitted. Activity limits in 18VAC135-20-335. | Virginia REALTORSJun 2026 |
| WashingtonWA | No specific pay rule | Unlicensed TCs may be paid directly by the broker for non-brokerage work. No per-file rule found. Unlicensed staff may not hold trust funds. | Washington REALTORS2022 |
| West VirginiaWV | No specific pay rule | WV Code 30-40-5 limits unlicensed tasks. No pay-structure rule found. | NAR state tableApr 2020 |
| WisconsinWI | No specific pay rule | Wis. Admin. Code RL 17.12 lists barred tasks. No pay-structure rule found. | NAR state tableApr 2020 |
| WyomingWY | No specific pay rule | No published guidance found. | Not covered by NAR table |
No pay based on sales. These states do not allow an assistant to be paid a percentage of commission, or any amount based on listings or sales. A flat fee paid only at closing is not a percentage, but a regulator could still read the rule to cover it. Treat these states as a gray area that leans toward no.
No specific pay rule. We did not find a rule on how to pay an unlicensed assistant in these states. Most still do not allow paying an unlicensed person for work that needs a license, so a per-closing fee is safest when the assistant keeps to administrative tasks.
Last reviewed. Many rows come from the NAR state table, which was last reviewed in April 2020. Rows dated 2023 or later were checked against newer state material. This page is effective as of October 12, 2026 and is general information only, not legal advice.
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