Committee flags privacy, cross‑broker risks from transaction coordinators and recommends education/writing group

The advisory committee spent significant time on transaction coordinators (TCs), distinguishing clerical (unlicensed) work from licensed brokerage activity and highlighting data‑privacy risks when client files leave a sponsoring brokerage’s control.

Members asked whether a licensed TC may work for multiple brokers or sit outside the country; staff and several members said the governing distinction is whether the TC is performing licensed activities. If the TC performs brokerage functions and is licensed, members said those activities normally should be conducted only for the sponsoring broker; if the TC performs clerical, unlicensed tasks, different rules apply. Several members emphasized that even unlicensed TCs pose privacy risks when they receive client personal data and advised stronger brokerage privacy policies and disclosure language when outside parties will have access to client files.

Suggestions included a required disclosure to clients when a TC or outside showing service will have access to confidential information, stronger broker policies to authorize and document any non‑sponsored TC arrangements, and routing such matters to the broker‑responsibility writing group for considered guidance. No formal regulatory change was adopted at the meeting.