Most states require a broker to supervise transaction records. Far fewer tell you when the review has to happen. We read the statutes and administrative codes for 22 states to find out which ones actually put a clock on it — and only four do.
How often must a broker review agent transaction files?
In most states, no interval is stated. The broker must supervise transaction records, but no deadline is named. Of 22 states we verified, only four set an explicit clock: Arizona (10 business days), Oregon (7 banking days), Washington (5 business days, new brokers), and Utah (settlement statements at closing).
That gap is the real answer to the question, and it is why the question is so often answered badly. A search usually returns Arizona’s rule, because Arizona is one of the few states that names a number — which leaves the impression that a 10-day standard applies generally. It does not.
The practical consequence: a brokerage cannot look up “the” review deadline, because for most states there isn’t one. What exists instead is a supervision duty whose adequacy gets judged after something goes wrong.
Which states set an explicit review deadline?
Four of the 22 we checked. Arizona is the broadest and strictest. Oregon covers every document of agreement. Washington and Utah both set a clock, but each applies to a narrow slice rather than to every file.
| State | Deadline | What it covers | Authority |
|---|---|---|---|
| Arizona | 10 business days after execution; broker initials and dates the document on the signature page | Listing, purchase, and nonresidential lease instruments. Residential leases are not on the list. Written delegation to an employed associate broker is permitted. | A.R.S. § 32-2151.01(G) |
| Oregon | 7 banking days after the document is accepted, rejected, or withdrawn | Every document of agreement generated in a transaction — the broadest explicit rule we found. | OAR 863-015-0140 |
| Washington | 5 business days from mutual acceptance | Only contracts involving brokers licensed under two years. | WAC 308-124C-125(9)(c) |
| Utah | At or before closing | Only final settlement statements, reviewed for content and accuracy. Other documents fall under a systems-based supervision standard with no clock. | Utah Admin. Code R162-2f-401c(1)(c) |
What does your state require?
Below is what we verified in each of 22 states: whether the broker has an affirmative duty to review transaction documents, whether any deadline attaches, and how long records must be kept. Retention rules are far more consistent than review rules.
| State | Broker review duty | Deadline | Retention | Authority |
|---|---|---|---|---|
| Arizona | Review each executed instrument, initial and date it | 10 business days | 5 years | A.R.S. § 32-2151.01 |
| California | Systems to “review, oversee, inspect and manage” transactions and material documents | None stated | 3 years | 10 CCR § 2725; B&P § 10148 |
| Colorado | “Ensuring all transaction files are reviewed for the required documents” | None stated | 4 years | 4 CCR 725-1, R6.3.C, R6.20 |
| Florida | Supervision, framed as a disciplinary standard | None stated | 5 years | Fla. Stat. § 475.25(1)(u); § 475.5015 |
| Georgia | None located — distribution and retention only | — | 3 years | Ga. R. 520-1-.10(4) |
| Illinois | Supervise and assist licensees in transactions | None stated | 5 years | 68 Ill. Adm. Code 1450.705; 1450.755 |
| Maryland | Review of executed contracts, leases, and brokerage agreements, listed as a supervision factor | None stated | 5 years | COMAR 09.11.05.03; Bus. Occ. § 17-507 |
| Michigan | None located | — | None for transaction files; 3 years trust/escrow only | MCL 339.2505(3); R 339.22134(8) |
| Minnesota | “Ongoing monitoring” of listing and purchase agreements and documents received by the office | None stated | 6 years | Minn. Stat. § 82.73 subd. 3; § 82.72 subd. 3 |
| Missouri | Closing statements reviewed for accuracy | Day of closing (closing statements only) | 3 years | 20 CSR 2250-8.020; -8.150; -8.160 |
| Nevada | Systems to “review, oversee and manage” transactions and material documents | None stated | 5 years | NAC 645.600; 645.650 |
| New Jersey | None located — supervision only | — | 6 years | N.J.A.C. 11:5-4.2; 11:5-5.4 |
| North Carolina | BIC supervises brokers and retains records; no document-review duty | — | 3 years | 21 NCAC 58A .0110(g); .0108(a) |
| Ohio | Oversee and direct the brokerage; no document-review duty | — | 3 years | ORC 4735.18(A)(24); 4735.081(C) |
| Oregon | Review each document of agreement | 7 banking days | 6 years | OAR 863-015-0140; ORS 696.280 |
| Pennsylvania | None — “adequate supervision” only | — | 3 years | 63 P.S. § 455.604(a)(16); 49 Pa. Code § 35.286 |
| South Carolina | BIC “shall review and approve all forms of” listing, agency, offers, contracts, and leases | None stated | 5 years | S.C. Code § 40-57-135 |
| Tennessee | “Adequately supervise” | None stated | 3 years | Tenn. R. 1260-02-.40(1) |
| Texas | Respond to sponsored agents — not a document-review duty | 2 calendar days (response only) | 4 years | 22 TAC § 535.2 |
| Utah | Settlement statements reviewed for content and accuracy; systems standard for other documents | At/before closing (settlement statements) | 3 years | R162-2f-401c; -401k(2)(b) |
| Virginia | Available “at reasonable times to review and approve all documents” | None stated | 3 years | Va. Code § 54.1-2110.1 B 1; 18VAC135-20-185 |
| Washington | Review brokerage service contracts | 5 business days (new brokers only) | 3 years | WAC 308-124C-125(9)(c); -110(2) |
Retention clocks do not all start at the same moment. Arizona runs from termination of the transaction; Texas from closing, contract termination, or end of the transaction; California from closing, or from the listing date if the deal never closed; North Carolina from disbursement of all funds or conclusion, whichever is later. Illinois states a five-year period without saying when it starts.
How long must a brokerage keep transaction records?
Three to six years in the states we verified. Three years is the most common. Oregon, Minnesota, and New Jersey require six. Michigan is the outlier: it sets no general retention period for transaction files at all.
- Three years — California, Georgia, North Carolina, Ohio, Pennsylvania, Tennessee, Utah, Virginia, Washington
- Four years — Texas, Colorado
- Five years — Arizona, Florida, South Carolina, Nevada, Maryland, Illinois
- Six years — Oregon, Minnesota, New Jersey
Michigan deserves its own line. Michigan real estate law sets no general retention period for transaction files. The three-year figure widely attributed to it comes from a trust and escrow account rule — a different category of record entirely.
A brokerage using that number as its file-retention standard is working from a rule that does not say what it is being cited for.
Which deadlines get misquoted as file-review rules?
Three, constantly. Each is a real deadline in a real rule — none of them is a file-review deadline. If you have been told your state requires review within a set number of days, check which of these is actually being cited.
- Texas, two calendar days. This governs how quickly a broker must respond to a sponsored sales agent. Texas is in fact the most emphatic of the states we read in the other direction: its rule states plainly that a broker is not required to supervise sales agents directly.
- Florida, monthly. The broker must review, sign, and date the trust-account statement-reconciliation. It has nothing to do with transaction files.
- North Carolina, three days. This is the agent’s duty to deliver executed documents to the firm — not the broker’s duty to review them.
And the most-repeated citation error in this whole subject: Arizona’s 10-business-day rule is in the statute — A.R.S. § 32-2151.01(G) — not in administrative rule A.A.C. R4-28-1103, which is what most write-ups cite.
We read R4-28-1103 in full. It requires broker policies to review and inspect material documents, and it contains no time period whatsoever. If a source cites the rule for the 10-day deadline, that source has not read it.
What should a multi-state brokerage actually do?
Stop trying to review on a calendar. The brokerages that stay clean review every file at the same two points — when it goes under contract and before it closes — so compliance never depends on remembering to run a sweep, and the strictest state’s standard becomes the house standard.
Working to the strictest rule you operate under is simpler than maintaining eight different ones, and it satisfies the states with no stated interval by definition. If you operate in Arizona or Oregon, their clocks are effectively your clock everywhere.
Reviewing at closing is also what most regulators effectively expect regardless of what the rule says about timing, because the file has to be complete and retained from that point forward. A review that happens after closing is documentation; a review that happens before it is compliance.
For what that review should actually check — completeness, execution, internal consistency, and jurisdiction — see what a broker file review is and what it covers. For who carries the liability when it goes wrong, see who is responsible for transaction compliance.
Common questions about broker file review requirements
Does every state require a broker to review transaction files?
No. Every state we verified imposes a supervision duty of some kind, but several — Georgia, Ohio, Michigan, Pennsylvania, New Jersey, and North Carolina — impose record duties with no affirmative document-review mandate located at all.
Which state has the strictest broker file review rule?
Arizona. It requires review within 10 business days of execution, and the broker must place their initials and the review date on the document itself, on the same page as the parties’ signatures. Oregon is close behind at 7 banking days, and applies to a broader set of documents.
Can a broker delegate file review to someone else?
Usually yes, and Arizona says so expressly — a designated broker may authorize an employed associate broker in writing to review and initial on their behalf. What cannot be delegated is the responsibility. The designated broker answers to the regulator regardless of who did the work.
How long does a brokerage have to keep transaction files?
Three to six years in the states we verified, most commonly three. Check the start date as well as the length, because they differ: some run from closing, some from disbursement of funds, and some from the listing date when a deal never closes.
Does this cover all 50 states?
No. We verified 22 states against primary sources and stopped there rather than filling the rest from secondary summaries. Where a rule could not be confirmed on a state-hosted source, we left it out rather than guess. One wrong legal citation costs more trust than ten missing states.
If a state auditor does come calling, the request centers on exactly these records — we’ve walked through what happens in a broker audit step by step.
One standard, every state you operate in
Empower reviews transaction files against state-specific requirements nationwide, inside your existing systems and under your brand. One consistent standard instead of a separate reviewer per state, run as compliance outsourcing for brokerages.
Read next
- What does real estate compliance outsourcing include? — meeting these state requirements with an outside team.
- Compliance and operations support for brokers — how Empower works with brokerages.
- AI compliance review for real estate files — how AI plus human review scales across states.
