What Can a Transaction Coordinator Do in Florida Without a Real Estate License?
Florida has no TC license. An unlicensed TC may do administrative work but not broker acts like negotiating. Here is where Chapter 475 and FREC draw the line.
TALLAHASSEE · October 29, 2026
An unlicensed transaction coordinator (TC) in Florida may do administrative support work, but may not do anything Florida law defines as broker activity. That means no negotiating, no quoting price advice, and no subjective answers to buyers or sellers. The line comes from Chapter 475, Florida Statutes, and from a list of tasks the Florida Real Estate Commission (FREC) has informally approved.
First, a correction on the rule number
Many Florida training materials cite Rule 61J2-5.016 as "the unlicensed assistant rule." It is not. Rule 61J2-5.016 covers the license status of officers and directors of brokerage corporations.
The FREC list of assistant tasks is not a formal rule either. FREC informally updated its list of permissible activities at its November 2018 meeting. Florida Realtors describes it as a list of informally approved activities.
Transaction coordinator is not a license category
Chapter 475 licenses brokers, broker associates and sales associates. It does not create a license for transaction coordinators. A TC working without a license is, under Florida law, an unlicensed person. The same limits apply whether the TC is on staff or works for an outside firm.
What the FREC list allows
The FREC list includes these tasks, among others:
- Answer and forward phone calls
- Assemble closing documents
- Obtain public records from the courthouse or utility districts
- Follow up on loan commitments after a contract is negotiated, and get status reports
- Type contract forms for approval by the licensee and supervising broker
- Schedule showing appointments for the licensee
- Act as a courier for documents
- Receive, record and deposit earnest money, security deposits and advance rents
- Submit listings and changes to a multiple listing service (MLS)
Two limits run through the list. Ads, flyers and contract forms need approval from the licensee and the broker. Questions can be answered only if they are objective and the answer comes from licensee-approved printed material. At an open house, an assistant "may not answer questions" and must direct them to the licensee.
What the law prohibits
FREC does not publish a separate "cannot do" list. The prohibited zone comes from the statute. Section 475.01(1)(a) defines a broker as a person who, for compensation, sells, buys, rents or negotiates real estate for others. The definition also covers anyone who "directs or assists" in the negotiation or closing of a transaction.
Under s. 475.42(1)(a), acting as a broker or sales associate without an active license is a third-degree felony. In practice, an unlicensed TC should not negotiate terms, give opinions on price, or offer subjective advice about contract choices. Those tasks belong to the licensee.
Where broker supervision comes from
Section 475.25(1)(u) allows discipline of a broker who fails "to direct, control, or manage" a broker associate or sales associate. Section 475.25(1)(h) bars paying a fee to an unlicensed person for referrals or for any service listed in the broker definition. Florida Realtors also notes that licensees may not aid or assist an unlicensed person to practice real estate. FREC's own list ends with a reminder: "The broker shall foster the education."
Three questions to ask any TC service
- 1What tasks do you perform, in writing? The list should match administrative work, not negotiation or advice.
- 2How are you paid? Florida Realtors' 2019 legal guidance urges brokers to set clear office policies for assistants. Pay tied to licensed acts raises s. 475.25(1)(h) questions.
- 3What happens when a party asks you a judgment question? The answer should be: it goes to the licensed agent or broker.
What This Means for Your File
HTC operates strictly within the unlicensed assistant boundary. We prepare documents, track dates, coordinate communication and organize the file. We do not quote prices, negotiate terms, interpret contracts, or advise on broker or client decisions. Those stay with the licensed agent and managing broker. The boundary is not a limitation. It is what makes a defensible file possible. This week, pull the written scope for every TC touching your files, staff or outside. Confirm with your broker that each task on it sits on the administrative side of the line.
🛡 SAFEGUARD YOUR LICENSE · This is how HTC operates. Your broker's license, your reputation, and your client's transaction depend on the TC honoring these boundaries. That's why we do this the way we do — every file, every time.
Frequently Asked Questions
Is there a transaction coordinator license in Florida?
No. Chapter 475 licenses brokers, broker associates and sales associates. A TC working without a license is an unlicensed person under Florida law, whether on staff or with an outside firm.
Can an unlicensed TC answer questions from a buyer or seller?
Only objective questions, answered from printed material the licensee has approved. Judgment questions go to the licensed agent or broker. At an open house, an unlicensed assistant may not answer questions.
Can an unlicensed TC handle earnest money?
The FREC list of permitted tasks includes receiving, recording and depositing earnest money, security deposits and advance rents.
Is Rule 61J2-5.016 the unlicensed assistant rule?
No. Rule 61J2-5.016 covers the license status of officers and directors of brokerage corporations. The list of assistant tasks is informal FREC guidance, updated at its November 2018 meeting.
Related: How HTC Works
Sources & References
- Florida Statutes, Chapter 475, Part I (2025), incl. ss. 475.01, 475.25, 475.42
- FREC, Permissible Activities of Unlicensed Assistants (informally updated Nov. 2018), as posted by Pinellas REALTOR Organization
- Florida Realtors, A Detailed Look at Florida Real Estate Licensing Law
- Florida Realtor magazine, Law & Ethics, September 2019 (Meredith Caruso)
- Fla. Admin. Code R. 61J2-5.016 (License Status of Active Officers and Directors)
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This article is educational and does not constitute legal advice. Consult a Florida real estate attorney for guidance on your specific situation.
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