California Broker of Record /
Designated Officer Readiness Checklist

Broker of Record vs. Designated Officer

Broker of Record (BOR) is commonly used business language for the responsible California broker supervising licensed activity. The exact DRE licensing arrangement depends on how the business is organized.

Designated Officer (DO), or designated broker-officer, is the broker-officer through whom a California corporation is licensed as a real estate broker. DRE states that the designated corporate officer is responsible for supervising and controlling licensed activities performed for the corporation by its officers and employees. Business and Professions Code §10159.2 places responsibility for supervision and control on that designated officer. [1][2]

Structure decision checklist

• Confirm the exact legal entity that will sign client agreements, receive compensation, advertise, and hold trust funds.
• Confirm whether that entity is an individual/sole proprietorship, California corporation, foreign corporation qualified in California, LLC, partnership, or another structure.
• Confirm whether the entity already has a DRE license, license number, designated officer, branch offices, and approved DBA/fictitious business names.
• If using a corporation, review DRE's current Corporation License guidance and RE 201 before assuming a DO filing is sufficient. [1][3]
• Confirm the proposed designated officer holds the required corporate officer title; “broker/officer” itself is not an official officer title. [1]
• Identify directors, policy-making officers, and natural persons owning or controlling more than 10% for the RE 212 analysis. RE 212 is required only when applicable under its instructions. [1][5]
• List every location where licensed activity will be conducted and determine whether RE 203 branch licensing applies. [6]
• List each salesperson and broker-associate affiliation/change that may require DRE filing, including RE 214 or RE 215 as applicable. [1][7]
• Do not begin covered activity under a proposed structure until the licensing path, effective dates, and written supervision arrangement are confirmed.

Entity and Operating Records

Broker supervision system

California Regulation 2725 describes reasonable supervision as including policies, rules, procedures, and systems to review, oversee, inspect, and manage licensed activity as appropriate. A responsible broker may use others to assist but does not relinquish overall responsibility. [4]

• Written office policy and compliance manual matched to actual business activities.
• Named responsibility for intake, advertising approval, document selection, signatures, transaction milestones, file completion, and escalation.
• Pre-use review process for websites, DBAs, social media, signs, applications, listings, rental advertising, and email signatures.
• Broker checkpoints occur during the workflow—not only after a lease is executed or sale closes.
• Procedure for urgent complaints, demands, fair-housing concerns, DRE or government notices, claims, trust shortages, insurance lapses, and suspected fraud.
• Training and documented acknowledgment for licensees and staff.
• Calendar for license, insurance, DBA, entity, branch, agreement, and recurring compliance deadlines.
• Monthly reporting process covering properties/units, leases, sales, trust accounts, personnel changes, complaints, and material operational changes.

Define the Activity Before Selecting Forms

Contracts, forms, and communications

• Inventory every management agreement, lease, addendum, notice, disclosure, listing/buyer agreement, offer form, vendor agreement, and internal template currently used.
• Identify the source, version/date, license or membership restriction, and approved use for each form.
• Do not treat access to CAR, AOA, AAGLA, AIR CRE, or another library as legal advice or permission to redistribute proprietary forms.
• Identify local ordinances and counsel-reviewed documents that may be needed for each county/city and property type.
• Create a controlled template library so staff cannot use superseded documents from old emails or personal drives.
• Define when the broker must review a new form, unusual clause, nonstandard deal, legal demand, or disputed notice.
• Retain complete, readable, searchable files with signed versions, attachments, delivery evidence, communications, and accounting records.

Insurance and risk transfer

• Current E&O and general liability policies match the named entity and actual management, leasing, and sales activities.
• Workers compensation, cyber, crime/fidelity, auto, property, and other coverage reviewed with qualified insurance professionals as applicable.
• Loom Realty and Kayla Jane Bramante shown as additional insureds where the written BOR/DO agreement requires it.
• Expiration tracking, renewal evidence, claim reporting, and immediate lapse notification procedures are documented.

Trust Account Control Is a Launch-Critical Workstream

DRE identifies trust-fund handling and recordkeeping as common enforcement problem areas. Its guidance cites Business and Professions Code §10145 and Regulations 2831, 2831.1, 2831.2, 2832, 2832.1, and 2834. [8] DRE provides example records including RE 4522, RE 4523, and RE 4525; businesses may use other systems only if they contain required information and enable tracing and reconciliation. [9][10]

Account and authority inventory

• List every operating, rent, deposit, reserve, and other account touching client or tenant money.
• For each account, record bank, exact title, masked account number, purpose, beneficiaries/properties, opening balance, and responsible entity.
• Identify all signers, online users, payment processors, bookkeepers, software integrations, ACH rules, wires, cards, and positive-pay controls.
• Confirm account titling and authorized signers with the broker, bank, and current law. DRE warns that owners generally are not authorized signers on a broker trust account and that the broker retains responsibility. [11]
• Document receipt, deposit, disbursement, transfer, returned-payment, chargeback, void, stale-check, owner-payment, tenant-refund, and security-deposit procedures.

Records and monthly close

• Chronological trust cash record for every trust account, including the information required by Regulation 2831 (DRE example: RE 4522). [9][10]
• Separate beneficiary/transaction or property-managed ledger with running balances (DRE examples: RE 4523 or RE 4525). [9][10]
• Bank statement and complete transaction support: deposits, receipts, checks, ACH/wires, voids, adjustments, and source documentation.
• Monthly bank reconciliation and monthly reconciliation of the trust cash record to the total separate beneficiary/property records under Regulation 2831.2. [8][10]
• Written explanation and correction evidence for every difference, unidentified amount, negative beneficiary balance, shortage, stale item, or uncleared deposit.
• Broker review record identifying month, account, preparer, reviewer, date, exceptions, corrective action, and resolution.
• Separate accounting package for each trust account; do not combine account reconciliations into an unverifiable summary.
• Retention and retrieval procedure consistent with applicable DRE record requirements and the written BOR/DO agreement.

What to Send for a BOR / DO Fit Review

• Entity documents and current Secretary of State status.
• Ownership, officer, director, employee, contractor, and licensee roster.
• DRE entity, broker, officer, branch, DBA, salesperson, and broker-associate records.
• Plain-language description of current and proposed licensed activities.
• Service counties, properties, units, active leases/listings, and expected monthly volume.
• Current/proposed management, leasing, and sales agreements and forms.
• Websites, social pages, signs, advertisements, email signatures, and public brand names.
• Insurance policies, endorsements, expiration dates, and open/past claims.
• Complete trust account inventory and most recent reconciliation package for each account.
• Property management/accounting software, file storage, security, and access map.
• Complaints, demands, DRE/government notices, audits, investigations, litigation, and disputes.
• Target launch or transition date and any deadline created by a departing broker.

Final yes/no questions

• Can the company identify the legal entity, license structure, responsible broker/DO, and effective date before covered activity begins?
• Can Loom access the people, systems, advertising, files, and accounting records needed for real supervision?
• Are the company's owners and operators willing to follow written policies, checkpoints, monthly reporting, and escalation requirements?
• Are trust fund records current, traceable, balanced, and available for review?
• Have all material complaints, discipline, investigations, claims, ownership changes, and operational risks been disclosed?
• Is there enough time to complete agreements, insurance, entity work, DRE filings, system access, and training before launch or transition?

Situations that usually require more work before approval

California DRE Forms, Rules, and Guidance

1. [1] California DRE, Corporation Licenses: dre.ca.gov/licensees/Corporation.html
2. [2] California Business and Professions Code §10159.2, designated officer supervision and control: Official California Legislative Information
3. [3] California DRE, Corporation License Application (RE 201): dre.ca.gov/files/pdf/forms/re201.pdf
4. [4] California DRE, 2026 Real Estate Law; see Commissioner's Regulation 2725, Broker Supervision: dre.ca.gov/Publications/RealEstateLaw.html
5. [5] California DRE, Corporation Background Statement (RE 212): dre.ca.gov/files/pdf/forms/re212.pdf
6. [6] California DRE, Branch Office Licenses / RE 203 guidance: dre.ca.gov/Licensees/BranchOffice.html
7. [7] California DRE, Corporation License application package and affiliation forms: dre.ca.gov/Forms/100-298.html
8. [8] California DRE, Most Common Enforcement Violations (trust funds and broker supervision): Official DRE Licensee Advisory
9. [9] California DRE, Trust Fund Record Keeping Information (RE 4521): dre.ca.gov/files/pdf/forms/re4521.pdf
10. [10] California DRE, Trust Fund Forms RE 4522, RE 4523, RE 4524, and RE 4525: dre.ca.gov/forms/4500-4699.html
11. [11] California DRE, Trust Fund Signatories: What You Need to Know (Nov. 14, 2025): Official DRE Update
12. [12] California DRE, Certification—Assignment of Supervisory Responsibility (RE 210): dre.ca.gov/files/pdf/forms/re210.pdf
13. [13] California DRE, Public License Lookup and Licensee Information: dre.ca.gov/Licensees/

Prepared as a Loom Realty readiness tool. Updated August 18, 2026. © 2018–2026 Loom Realty. California Broker: Kayla Jane Bramante, CA DRE #02017652.