All States
Transparency

Research Gaps

These are the 90 open questions in this guide: claims we could not verify against primary sources yet, conflicts between our sources, and states we have not fully researched. If you know something about one of these, tell us in the community.

We are not attorneys and this is not legal advice.
These summaries are our reading of the bills and public reporting. Laws change fast and we may have something wrong or out of date. Always confirm with a real estate attorney licensed in your state before structuring a deal. Spot an inaccuracy? Tell us in the Skool community and we will fix it.
Alabama
  • Whether a true double close (you take title and never assign the equitable interest) escapes the Section 8-42-2 disclosure duties is not tested in the courts. The plain text keys the duties on marketing and transferring an equitable interest, which a double close arguably does not do, but subsection (a) also references your intent to assign at contract signing. Give the disclosures anyway if you ever market the contract before taking title.
Alaska
  • No wholesaling-specific statute found in our sources as of 2026-07-07; not independently verified against the state legislature.
Arizona
  • Novation is untested here. The statute triggers on assigning 'that same contract' (44-5101(D)(2)); a true novation is a new contract, so it arguably escapes, but no Arizona case tests this. Treat as Gray.
  • Pending bill number: third-party video commentary says HB 2486 (sponsor Rep. Oscar de los Santos, introduced January 21, 2026, House Commerce and Rules committees); the same source's written report lists it as 'SB 2486 introduced 1/1/26.' Status is as of early 2026 and unverified since.
  • The AG lawsuit details come from a single piece of video commentary (an industry source interviewing attorney Jeff Watson) and describe allegations in a civil complaint, not adjudicated findings.
Arkansas
  • No wholesaling-specific statute found in our sources as of 2026-07-07; not independently verified against the state legislature.
Colorado
  • No wholesaling-specific statute found in our sources as of 2026-07-07; not independently verified against the state legislature.
Connecticut
  • Property scope: 'residential real property' is defined only by cross-reference to C.G.S. Section 20-311, which is not reproduced in our source file. Whether vacant residential land or 2-4 unit and larger multifamily are inside the definition is unresolved. Read 20-311 before building a land or multifamily strategy on this.
Delaware
  • Whether marketing a deal to end buyers BEFORE closing (the normal double-close workflow) is reached by the wholesaling definition. Taking title means you never assign an equitable interest, but the definition still triggers on 'marketing and advertising for the assignment of an equitable interest,' so pre-title marketing of the assignment is gray. Confirm with a Delaware attorney.
  • Entity sale (selling LLC membership instead of assigning the contract). The definition keys on 'marketing and advertising for the assignment of an equitable interest in an agreement of sale,' which a membership sale arguably is not, but the 'attempts to engage in a wholesale transaction' language (effective February 26, 2027) is broad. Untested. Treat as gray.
  • Whether a single one-off assignment counts. The definition and the narrowed owner exemption both use 'the business of' wholesaling and 'engaged in wholesaling as a business,' which reads as a course of conduct rather than one incidental deal, but Delaware has not defined the threshold. Unknown.
Florida
  • PRIMARY-SOURCE VERIFICATION NEEDED. This entire page rests on one secondary source, the Google deep research report. Our third-party industry report does not mention Florida at all, so nothing here could be cross-checked. Verify against the Florida statutes and legislature before relying on it.
  • The status call (none) is an inference. The Google report says Florida wholesaling operates under Chapter 475 'rather than a singular, consolidated wholesaling bill,' but its comparison table lists Florida as 'Existing' regulation, which reads as if Florida has a wholesaling law. Chapter 475 is Florida's general real estate licensing law, not a wholesaling statute, so we classify Florida as having no wholesaling-specific law.
  • No pending Florida bill appears in either report. Given how large the Florida wholesaling market is, absence of evidence is weak here; check the current legislative session directly.
  • The Section 475.42 marketing rule, the up to $5,000 per violation fine figure, and the escrow timing rules are all single-sourced from the Google report.
Georgia
  • SB 90's notices clearly attach to physical mail (the second notice is keyed to the envelope or the postage-bearing portion of the piece). Whether an 'unsolicited written inquiry' also reaches email, text, or other digital messages is not settled by the statute text. Treat digital outreach conservatively.
  • The Atlanta ordinance sets its penalty by cross-reference to Atlanta City Code Sec. 1-8, whose exact text was not independently pulled. Secondary reporting puts the ceiling at a $1,000 fine and up to six months in jail, consistent with Georgia's general municipal-penalty cap.
  • A later 2024-session bill may have added fair-market-value or county-assessed-value language to O.C.G.A. 10-1-393.19 that is not in SB 90's enrolled text. Verify before treating the two notices below as the complete required wording.
Hawaii
  • No wholesaling-specific statute found in our sources as of 2026-07-07; not independently verified against the state legislature.
Idaho
  • No wholesaling-specific statute found in our sources as of 2026-07-07; not independently verified against the state legislature.
Illinois
  • The 'Class A misdemeanor' criminal characterization is not in the fetched statute sections (225 ILCS 454/1-10, 5-20, 20-20); it is attributed to a third-party report. Confirming it would require pulling the criminal-penalty section (225 ILCS 454/20-10). Kept hedged on the page.
  • The seller-disclosure duties (disclose equitable interest, tell the seller about the right to an independent appraisal and legal advice, disclose transaction income) are not in the fetched sections and are single-sourced to a third-party report. Kept attributed.
  • Whether publicly marketing the PROPERTY before taking title on a planned double close triggers brokerage exposure is not squarely addressed by any source.
  • Whether a licensed brokerage firm or subagent may wholesale on behalf of clients (as opposed to for their own account) is single-sourced to the Google report and is not resolved by the fetched statute sections.
  • The private-marketing workaround (marketing only to a known buyer list) is single-sourced and labeled a gray area by its own author; it is not a statutory safe harbor.
Indiana
  • The statute uses 'residential, single-family home' but never defines it. Coverage of 2-4 unit properties, condos, and mobile homes is unverified; the land, commercial, and larger-multifamily exclusion is inferred from the single-family wording.
  • Dispo-side marketing (offering your contract to cash buyers) may be covered: the trigger reaches soliciting the 'sale or purchase' of a single-family home, and the statute does not exempt the buyer-facing side. Treat dispo marketing as potentially in scope until tested.
  • In-person, face-to-face solicitation (a door knock or kitchen-table pitch) may fall outside the statute's 'solicitation' definition, which lists print, electronic, and broadcast methods (phone calls, texts, and social media included) but not in-person contact. Unsettled.
Iowa
  • The Iowa Real Estate Commission was directed to adopt implementing rules (543B.6A(5)). Those administrative rules were not reviewed and may add disclosure, form, or process requirements.
  • The statute does not specify the content of the executed agency agreement that must be given to all parties (543B.6A(3)(b)); the Commission's pending rules may define it.
  • The exact operational requirements of the 'represented by a real estate broker' path (agency-agreement terms, level of broker supervision) are set out only in outline in the statute and await the Commission's rules.
Kansas
  • No wholesaling-specific statute found in our sources as of 2026-07-07; not independently verified against the state legislature.
Kentucky
  • The line between permissible private transfer and 'advertising' (for example, at what size an email blast to a buyers list becomes public marketing) is not defined in the statute or settled by quoted case law. Verify with a Kentucky attorney.
  • The specific criminal and civil penalties for unlicensed practice live in the general licensing-penalty sections (KRS 324.990 and related), which were not part of the HB 62 amendment and were not pulled. The amended text (KRS 324.020) confirms only the Commission's injunctive-relief power (324.020(6)). Treat the misdemeanor and civil-fine exposure as likely but unquoted.
Louisiana
  • The mandatory LREC cancellation notice form was not yet published as of July 8, 2026. Confirm it is live on the LREC website before writing contracts.
  • The statute is silent on when the 1 percent deposit must be funded (confirmed). The deferral structure suggested by an industry source (deposit due 24 hours after the 5 day cancellation window ends) is that source's contract drafting, not statute or case law, and is untested with the LREC.
  • Whether a disclosure printed inside the purchase contract satisfies 'before the execution of each related contract' is one industry source's reading. The statute does not require a separate document, but no regulator guidance confirms in-contract disclosure is enough. Verify.
  • The word 'novation' never appears in the statute. Coverage of novations is inferred from the 'directly or indirectly' definition language and asserted only in third-party commentary. Verify with a Louisiana attorney.
  • The funded double close conclusion rests on reading definition prong (b) in the negative (you provided all funds, so prong (b) does not reach you). No case law or LREC guidance exists yet.
  • Section 2 grandfathers contracts 'completed' before the effective date. 'Completed' could mean signed or closed. Do not rely on grandfathering for deals signed before August 1 but closing after it without attorney confirmation.
Maine
  • No wholesaling-specific statute found in our sources as of 2026-07-07; not independently verified against the state legislature.
Maryland
  • The statute uses 'owner-occupied residential property' but does not define 'owner-occupied' or fix the moment occupancy is measured (contract date vs closing). Confirm before treating a recently vacated house as exempt.
Massachusetts
  • No wholesaling-specific statute found in our sources as of 2026-07-07; not independently verified against the state legislature.
Michigan
  • Entity/LLC sale is still an open question. Assigning the membership interest in an LLC that holds the contract, instead of assigning the contract itself, is not addressed anywhere in the introduced bill text. We are not calling this one either way.
  • MCL 339.2503(2) is genuinely ambiguous on its face. It could strip the owner exemption from a wholesaler's own assignment of their own equitable interest (the more natural reading, given 2501(x)/(z) already classify wholesaling as broker activity), or it could carve out a brand new exemption specifically for equitable-interest assignments. Flagging this, not resolving it. Do not treat 2503(2) as a safe harbor.
  • This is still only the introduced version of the bill. No committee hearing, vote, substitute, or engrossed text exists yet, so nothing below is final language. Re-verify against legislature.mi.gov before relying on any specific provision.
Minnesota
  • No wholesaling-specific statute found in our sources as of 2026-07-07; not independently verified against the state legislature.
Mississippi
  • No wholesaling-specific statute found in our sources as of 2026-07-07; not independently verified against the state legislature.
  • Dead-bill details (HB 1682 and SB 2692, died in committee 2026-02-03) come from a single third-party industry report only; verify current status on the Mississippi legislature site before relying on them.
Missouri
  • SB 973 signature not yet confirmed. As of July 8, 2026 the Senate bill page shows 'Delivered to Governor' as the latest action and no signing is posted on governor.mo.gov. If the Governor signs it or lets it become law without signature by the deadline (on or about July 15, 2026), the August 28, 2026 effective date holds; if vetoed, none of this takes effect. Re-check before acting.
Montana
  • No wholesaling-specific statute found in our sources as of 2026-07-07; not independently verified against the state legislature.
Nebraska
  • The statute does not define what counts as 'publicly' marketing. The exact statutory text of the trigger is now on file and quoted below, but the public vs private line (where a targeted buyer list stops being private) rests on Nebraska Real Estate Commission guidance, not on a statutory definition. The private marketing strategy still turns on that unquoted line.
  • The 2025 amendment (LB 187) excludes 'a vacant lot' but does not define the term. Whether a parcel with a demolished or uninhabitable structure, agricultural land, or a lot with minor improvements counts as a 'vacant lot' is untested. The precise effective date of LB 187 is not on file, but as a 2025 enactment the carve-out is in force now.
  • Penalties for unlicensed brokerage under the Nebraska Real Estate License Act (fines, cease and desist, criminal exposure) are not spelled out in the statute text on file. The penalty section below is generic license-law exposure; get the specifics from the Act or a Nebraska attorney.
  • The NREC 'Commission Policy and Interpretation on Wholesaling Activities' is cited by URL in the sources but its content is not on file. Its position on private, targeted marketing, and on the seller-agent relationship when a licensee helps a wholesaler, is unverified and could be stricter than assumed.
Nevada
  • No wholesaling-specific statute found in our sources as of 2026-07-07; not independently verified against the state legislature.
New Hampshire
  • No wholesaling-specific statute found in our sources as of 2026-07-07; not independently verified against the state legislature.
New Jersey
  • No wholesaling-specific statute found in our sources as of 2026-07-07; not independently verified against the state legislature.
New Mexico
  • No wholesaling-specific statute found in our sources as of 2026-07-07; not independently verified against the state legislature.
New York
  • No wholesaling-specific statute found in our sources as of 2026-07-07; not independently verified against the state legislature.
  • Online chatter about New York 'banning wholesaling' circulates constantly; none of our three source reports substantiates a statewide wholesaling statute. Verify against current NY legislation before relying on this page for a large deal.
North Dakota
  • The statute is silent on double closings and novations. The double close and take-title conclusions below are derived from the definition's trigger words (profit from the transfer of an equitable interest), not from any double-close provision.
  • The statute does not define what counts as publicly marketing versus private marketing. The private marketing loophole rests on the word publicly in 43-23-06.1(9)(i) with no statutory definition.
  • The statute does not state a specific penalty for unlicensed brokerage in North Dakota (fine amounts or criminal exposure are not in chapter 43-23's fetched text). Only the contract cancellation remedies are documented.
Ohio
  • HB 287 (still pending in the House Development Committee) also amends the real estate broker license law (R.C. 4735.18 and 4735.24) on top of re-enacting the same 5301.95 disclosure. Our sources do not detail the exact licensee impact of those two amendments, so treat that part as unsettled until the bill text is confirmed.
Oklahoma
  • The $5,000 per violation fine plus up to six months imprisonment for unlicensed marketing under the 2021 act appears only in the Chico report and is not in the fetched statute text. Verify.
  • No source defines the unit count or scope of residential real estate for either bill. Vacant land, 5+ units, and commercial coverage is untested here.
  • The takedown conclusion (buy first with no pre-arranged buyer, then resell) escapes both laws on the quoted trigger words, but it is also a product the third-party source sells, so this conclusion comes from a source with a commercial interest in it. Treated as sound on the text, flagged for bias; verify independently.
Pennsylvania
  • State effective date: the official palegis.us Act-52 status page prints only 'Effective 180 DAYS' from the July 8, 2024 enactment, which computes to January 4, 2025; some secondary/law-firm sources cite January 9, 2025. This page uses January 4.
  • Pennsylvania realty transfer tax applies to each deed and raises double close costs (higher in Philadelphia), but current rates are not covered in the sources; verify before pricing a double close.
Rhode Island
  • No wholesaling-specific statute found in our sources as of 2026-07-07; not independently verified against the state legislature.
South Carolina
  • Specific civil and criminal penalty amounts for unlicensed practice are not in the statute text on file; Chapter 40-57's general penalty provisions were not part of the fetched sections. Assume standard licensing-law exposure and confirm the exact figures.
  • The statute does not define 'residential real estate' by unit count and is silent on vacant land. The non-residential question is further clouded because the broker definition (marketing real estate owned by another for compensation) is not limited to residential.
South Dakota
  • No wholesaling-specific statute found in our sources as of 2026-07-07; not independently verified against the state legislature.
Tennessee
  • The statute creates a private right of action with a two-year limit running from the contract's execution (66-4-403(b)), but it does not spell out damages or fine amounts, so the exact civil exposure is open.
  • The 2021 unlicensed-brokerage case (rendered in a video transcript as 'Sota v. Presidential Properties LLC') is Title 62 Real Estate Broker License Act case law, separate from SB 909, and the citation and spelling are unverified. Confirm before relying on it.
Texas
  • Whether the telemarketing regime reaches a wholesaler's BUY-side outreach is untested. Chapter 302's registration trigger keys on a 'seller or salesperson' inducing someone to 'purchase, rent, claim, or receive an item,' which a buy-side cold-caller arguably is not; chapter 304's no-call rules more plausibly reach a cold call to buy. No Texas regulator or court has resolved it. Treat cold outreach as covered, but the edge is untested.
Utah
  • No wholesaling-specific statute found in our sources as of 2026-07-07; not independently verified against the state legislature.
Vermont
  • No wholesaling-specific statute found in our sources as of 2026-07-07; not independently verified against the state legislature.
  • Our sources cite a 2026 Vermont Legislature research summary on investor-owned residential properties and housing affordability; it is not a wholesaling bill, but we have not reviewed the underlying document.
Virginia
  • How an 'occasion' is counted is undefined in the statute: § 54.1-2100 clause (iii) includes 'offers to sell' and 'offers to buy,' which read literally could count failed or unaccepted offers, not just closed assignments. No Virginia guidance in the fetched sections defines the term.
  • Whether the two-occasion count aggregates across multiple entities under common control is not addressed in § 54.1-2100 or the exemptions in § 54.1-2103.
  • Exact penalties for unlicensed brokerage, and whether criminal charges attach, are not contained in the definition and exemption sections fetched (§§ 54.1-2100, 54.1-2103); those provisions live elsewhere in Title 54.1 and are not verified here.
Washington
  • Self-representation: RCW 61.40.010(4) exempts a deal where the buyer or seller is 'represented by a real estate broker licensed in accordance with chapter 18.85 RCW.' Whether holding your own Washington broker license and self-representing satisfies that exemption (versus a separate broker actually representing a party) is untested. Treat self-representation as Gray until a Washington attorney confirms it.
  • Waiver: the statute does not say whether the seller can waive the appraisal and cancellation rights. Assume non-waivable until confirmed.
West Virginia
  • STATUS CONFLICT, resolved to none: our triage sheet lists West Virginia as pending, and the third-party industry report files HB 4493 under 'Known Pending Bills,' but that same report's own status line reads 'Failed / Did not advance beyond committee' with a last action of committee referral on January 20, 2026, the day after introduction. With no further movement recorded and the 2026 regular session long over as of 2026-07-07, we treat the bill as dead. Verify on the WV legislature site.
  • Bill number discrepancy: the written industry report says HB 4493; the same source's video commentary calls the same 'Abolishment of Wholesaling Act' HB 3501. Unresolved; confirm the number before citing it.
  • Scope conflict inside our sources: the written report says the bill expressly excluded transactions where the purchaser takes legal title first (so double closing was outside it), while the video claims the definition would also reach double closes and novations. We credit the written report because it describes the exclusion specifically, but the full bill text is not in our files.
  • Single-author sourcing: everything here comes from one third-party industry source. West Virginia does not appear in the Google report or the Chico report.
Wyoming
  • No wholesaling-specific statute found in our sources as of 2026-07-07; not independently verified against the state legislature.