A commission disbursement authorization, the CDA, is the document a brokerage issues to the title or escrow company instructing how the commission is to be paid at closing: how much goes to the brokerage, how much to the agent, what is deducted, and who signs for it. Agents experience it as the form that releases their check. The brokerage should experience it as something else: the last compliance decision made on the file, because a brokerage that issues a CDA is certifying that the file behind it is complete enough to be paid on.
Why it matters: in our own admin records, commission instructions are the single most requested back-office task: 35.3% of 394 admin requests logged in July and August 2026, ahead of billing questions and every other category. The CDA is where the agent’s money and the broker’s file requirements meet, on a deadline set by the closing date. Whatever a brokerage’s compliance process is, this is where it either finishes in time or gets skipped.
What a CDA actually contains. The property and closing date; the total commission due to the brokerage per the listing or written buyer agreement; the split between brokerage and agent; itemized deductions (referral fees, transaction fees, E&O charges, outstanding balances the agreement allows the brokerage to offset); the payee names and payment instructions for each share; and an authorized signature from the brokerage. It reconciles three documents at once: the commission agreement with the client, the agent’s compensation agreement with the brokerage, and the closing statement. Any mismatch among the three surfaces here or not at all.
The disbursement is the deadline the review actually runs on. We review on the order of 12,000 transaction files a month, and on nearly all of them the disbursement date, not the brokerage’s stated policy, is what sets the real review deadline. A file can be incomplete for weeks without consequence. It cannot be incomplete on the day the CDA is due. Either the review finishes and the check releases, or the check waits, or (the quiet failure) the CDA goes out on an unreviewed file because the closing table is calling. That is why disbursement and compliance review are one workflow at brokerages that run them well: the file is reviewed as it moves, so the CDA is a formality by the time it is due, and the agent’s check arrives when promised.
What varies, and what to check. In every state the commission belongs to the brokerage, because license law generally bars an agent from being paid by anyone but their broker. Direct payment of the agent’s share from the closing table is a broker-authorized exception where state law permits it, not the default. The instrument also goes by other names in other markets (a commission demand or commission statement), is addressed to the closing attorney in attorney-closing states, and on a cooperating-broker side often does not exist at all: the commission arrives from the listing brokerage after closing. Who at the brokerage may sign the authorization, what the agreement lets the brokerage deduct or withhold, and how post-closing corrections are handled should all be written down before the first closing, in the agent agreement and its fee schedule and in the brokerage’s own procedures.
The honest limits on this piece: the 35.3% figure is from Empower’s own admin-request records over two months of 2026, a snapshot of what our partner brokerages’ agents ask for, not an industry statistic. CDA practices, who may receive commission directly from escrow, and required forms vary by state and by title company; this is a description of the operational role the document plays, not legal or tax advice.
Where that leaves it: the CDA is the one compliance document with a payday attached, which makes it the most reliable forcing function a brokerage has. Treat it as a payment form and the file review becomes optional under deadline pressure. Treat it as the certification it actually is (the review is done, the three documents agree, pay the people) and the brokerage gets a compliance process with a natural finish line on every file, because every file has a closing date.
Frequently Asked Questions
What is a CDA in real estate?
A commission disbursement authorization is the document a brokerage issues to the title or escrow company at closing instructing how the commission should be paid: the total due to the brokerage, the split between brokerage and agent, itemized deductions, payee details, and an authorized brokerage signature. It reconciles the client commission agreement, the agent’s compensation agreement, and the closing statement. Practices and forms vary by state and title company.
Who prepares and signs the commission disbursement authorization?
The brokerage prepares and signs it, through an authorized person at the brokerage or its back office acting on the brokerage’s behalf under written procedures, because the commission is owed to the brokerage under the client agreement and the agent is paid from it under the agent agreement. Who may sign depends on brokerage policy; whether the closing agent may pay the agent’s share directly, rather than the brokerage receiving all of it and paying the agent, is a broker-authorized exception where state license law permits it.
Why is the CDA connected to compliance review?
Because issuing it certifies the file is complete enough to pay on, and it arrives on a hard deadline: the closing date. Brokerages that review files as they move treat the CDA as a formality; brokerages that review after closing face a choice at every closing between delaying the agent’s check and paying on an unreviewed file. Running disbursement and review as one workflow removes that choice.
What is the most common back-office request from agents?
In Empower’s own records, commission instructions, at 35.3% of 394 admin requests logged in July and August 2026, ahead of billing and every other category. It is a snapshot of partner brokerages, not an industry figure, but it points at the same thing agents already know: the disbursement is the back-office moment they care about most.
