Frequently Asked Questions
Does my locator commission need to be in writing?
Yes. Once apartment locators are required to hold an active real estate license, any compensation paid to them for procuring a tenant becomes a real estate commission. In every U.S. state, real estate commissions must be agreed to in writing. Therefore, verbal apartment locating commissions are legally non-compliant, unenforceable, or both.
- Effective 2025, all 50 states require apartment locators to hold an active real estate license. (see state licensing requirements)
- With all 50 states now requiring licensure, apartment locating is unequivocally recognized as a regulated real estate activity.
- State law requires that real estate commission be in writing and issued by the party offering the commission. Verbal commission agreements no longer align with licensing laws or modern compliance standards. For example:
- Locator referrals are no longer informal marketing arrangements, they are regulated real estate transactions.
- There isn’t a minimum or standard commission rate. The owner or manager can offer any dollar amount or percentage of the rent as commission and is only payable if a referral signs a lease and moves in. (Federal Trade Commission and National Association of Realtors)
- The owner or manager can change the commission at any time.
- Apartment communities are not required to work with every apartment locator. Apartment communities should only accept referrals from locators they intend to pay a commission.
- Apartment communities are not required to pay all locators the same commission. They can have different commission agreements with different locating companies.
Are apartment locators required to hold a real estate license?
Yes. As of 2025, all 50 states require apartment locators to hold an active real estate license. Apartment locating is a form of real estate representation, and licensed status ensures that locators are subject to state laws, regulatory oversight, and professional accountability—just like residential and commercial real estate agents.
All states requiring locators to have a real estate license is critical for protecting both property owners and renters.
- For property managers, verifying every locator has a license helps prevent fraudulent commission invoices submitted by unlicensed individuals or marketing companies. A licensed locator must operate through a broker, follow state commission rules, and is legally accountable for how referrals are generated and represented.
- For renters, licensure provides an important layer of consumer protection. If a tenant is treated unfairly or misled, they have formal recourse through the state real estate licensing board—protections that do not exist when referrals are handled as informal marketing arrangements.
Licensing also elevates apartment locating beyond simple advertising.
- A real estate license carries fiduciary duties, ethical obligations, and legal standards that govern how referrals are made, how clients are represented, and how compensation is earned. This distinction matters, particularly as states have moved toward stricter enforcement and written commission requirements.
The National Association of Apartment Locators (NAAL) strongly encourages property managers to work exclusively with NAAL members.
- NAAL members not only hold active real estate licenses but also agree to abide by NAAL’s Code of Ethics and Standards of Practice—standards that exceed minimum state licensing requirements.
- This added layer of accountability promotes transparency, professionalism, and consistent business practices across markets.
Some apartment communities rely on vendor credentialing as a safeguard against unlicensed locators.
- Vendor credentialing platforms do not verify real estate licenses.
- Neither does the IRS. A W-9 confirms tax reporting information only—it is not proof that a locating company or agent is legally licensed to perform real estate services.
Verifying licensure and working with NAAL members remains the most effective way for property managers to ensure compliance, reduce risk, and build long-term relationships with qualified, ethical apartment locators.
How can locators help the Directory succeed?
One signup and one invitation from each locator quickly builds the participation needed to move the industry forward. It costs nothing to participate, carries no risk, and helps show the industry that locators are aligned and ready for progress.
Sign up for a free NAAL locator account.
Download and share our one-page flyer with other locators. It clearly explains the benefits of signing up.
Help build locator participation so NAAL can move to the next phase of inviting property managers by February 1, 2026.
What is the NAAL Commission Directory?
The NAAL Commission Directory is a centralized, online platform where apartment communities can post their locator commission terms and referral instructions in writing—for free. It is free for apartment locators, property managers, and approved apartment locating databases to access and use.
The Directory was created in response to nationwide licensing requirements that now classify apartment locating as a regulated real estate activity in all 50 states. By posting commissions in writing, property managers reduce risk, avoid misunderstandings, and ensure commission disclosures align with real estate licensing and compliance expectations—while giving locators clear, accurate information before submitting a referral.
Why can’t the Directory address faster commission payments right away?
Faster, more reliable commission payments are a top priority—but adoption comes first. Asking property managers to change multiple procedures at once would slow participation and limit impact.
The Directory’s initial focus is ensuring complete commission terms are posted in writing, including the commission rate, client registration, vendor credentialing, and invoicing instructions. Centralizing this information eliminates today’s reliance on verbal phone confirmations, call recordings, and repeated email verification, which are outdated, inconsistent, and create risk for both locators and property managers.
Establishing clear, written commission disclosures creates the foundation needed to improve payment timelines and enforcement in the next phase.
How does the Directory improve accuracy and accountability?
The Directory maintains a time- and date-stamped record of commission terms so locators and property managers can verify exactly what was offered at the time a referral was submitted. This replaces verbal conversations and phone recordings with clear, written documentation and helps prevent disputes caused by policies changing after the fact.
Property managers may offer any commission amount they choose and may change their commission as often as needed, at no cost. The Directory does not control, recommend, or influence commission rates. It simply provides a reliable way for locators to confirm what is being offered on any given day and it gives property managers the flexibility to adjust their commission at any time or indicate they are not work with locators.
Texas experiences more friction around commission collection than other states due to high locator volume and long-standing reliance on verbal disclosures. In states where written commission agreements are already common, commissions are typically paid faster and disputes are less frequent. The Directory reduces this friction by making commission terms and referral instructions easy to verify—without dictating rates or terms.
Can the Directory help with escalations or denied commissions?
Eventually, yes. The current focus is adoption and clear written disclosure so commission terms and referral instructions are documented upfront. Once locators and property managers are actively using the Directory, NAAL can explore ways to support escalation and dispute resolution based on the written commission terms in effect at the time of referral.
In future phases, NAAL intends to work collaboratively with management companies to better understand the operational, accounting, and compliance challenges that can delay commission payments. At the same time, NAAL will identify practical ways locators can improve documentation, invoicing, and submission practices to reduce friction and support timely payment—without dictating commission amounts, timelines, or uniform rules.
Delayed payments will happen from time to time but we should be able to work together to reduce the average number of days it takes to collect commission invoices. Better documentation on the front-end will automatically reduce denied payments because it will be clear which locator is the procuring cause of the lease.
Will property managers have to update information frequently?
Property managers create a free account, select the communities they manage, and are authorized to post commission terms and invoicing instructions. Once a property is claimed, only that management user can update its information. Managers can log in at their convenience to update commissions or indicate they are not working with locators.
Updates are only needed when commission terms change and each change capture a time and date stamp. There is no required update schedule or ongoing maintenance if nothing has changed.
The Commission Directory is designed to reduce administrative burden, not add to it. By updating commission information in one place and sharing it across the industry, we can avoid repetitive emails, calls, and verification requests. There will be a delicate balance in the beginning to inform and invite management users via email but not inundate inboxes with spam. We may allow locators to use the platform to send a limited number of emails, but we want to avoid inbox fatigue, increase spam, and ultimately reduce participation.
We plan to work with regional managers and local apartment associations to encourage adoption and minimize the burden on onsite staff. The long-term goal is for commission updates to become a simple, routine step whenever a change is made.
Can this data be integrated with other locator platforms?
Yes, but only during the 3rd phase. Connecting with platforms such as Smart Apartment Data, Spark, ALN, or ADS would help keep commission information consistent across the industry. However, only after there is strong participation from both locators and property managers will we invite technology users to sign up in the 3rd phase
In the early stages, commission data will only be shared with approved technology partners and provided in simple formats, such as Excel. As adoption grows, NAAL plans to support direct data syncing.
To protect property managers, NAAL will approve technology partners before any data is shared. The approval process will be free and designed to confirm that partners operate within the apartment locating space. Property managers will know which approved partners have access to their commission data.
Because this type of shared commission data has never existed in the industry, NAAL is committed to moving forward carefully. Privacy, transparency, and responsible data use are top priorities.
Are apartment communities required to work with every locating company?
No. Apartment communities are not required to work with every apartment locating company. Apartment locators are licensed real estate agents who work only by agreement with a property owner or the owner’s representative. A community may choose which locating companies it accepts referrals from and may decline to work with any locator based on past experience or internal policies.
If a community works exclusively with one or two approved locating companies, listing those approved partners in the locator commission database helps prevent unapproved referrals and reduces confusion for both leasing staff and locators. Property management and onsite teams have an ethical responsibility to accept referrals only from locators they intend to compensate. Clearly disclosing participation, approval status, and commission policies upfront promotes transparency, protects all parties, and supports long-term, trust-based referral relationships built on qualified leads.
Are apartment communities required to pay every locating company the same commission?
No. Apartment communities are not required to pay every locating company the same commission. Commission amounts are determined by agreement between the property owner (or the owner’s representative) and the licensed real estate agent or brokerage. A property owner may have different commission agreements with multiple apartment locating companies, provided the terms are properly disclosed and none of the agreements constitute an exclusive listing unless explicitly intended.
Apartment locating follows the same legal and contractual principles as residential and commercial real estate. If a locating company delivers a higher level of service, stronger screening, or more qualified referrals, a property owner may choose to compensate that company differently than others. To avoid misunderstandings, commission terms should always be documented in writing. Property managers may also request that the locator’s broker or company owner provide a written commission agreement to ensure clarity and compliance for all parties involved.
Does the National Apartment Association (NAA) govern locators?
No. The National Apartment Association (NAA) does not govern apartment locators. NAA is a trade organization created to represent and support apartment owners, developers, and property management companies. Its mission, advocacy efforts, and educational resources are focused on the ownership and management side of the multifamily housing industry.
While the National Association of Apartment Locators (NAAL) supports the work NAA does on behalf of property owners and managers, NAA does not have regulatory authority over apartment locators and does not establish standards, ethics, or best practices for the locating profession. As a result, NAA membership does not provide direct benefits, guidance, or representation for apartment locators.
Apartment locators are governed by their respective state real estate licensing authorities and, for those seeking industry-specific standards and advocacy, by professional organizations dedicated to the locating industry, such as NAAL.
Does the National Association of Realtors (NAR) govern locators?
No. The National Association of Realtors (NAR) does not govern apartment locators. NAR is a voluntary trade association that real estate professionals may choose to join, primarily to gain access to Multiple Listing Services (MLS), advocacy resources, and professional education related to residential and commercial real estate sales.
NAR does not have regulatory authority over apartment locators and does not establish rules or standards for the apartment locating industry as a whole. Apartment locators are governed by their respective state real estate licensing authorities, not by NAR. Only those locators who voluntarily choose to join NAR are subject to its membership rules and Code of Ethics; locators who are not members have no obligation to NAR and are not under its authority.