Property management trust account rules by state
By the Propfina team · Published · Updated
Property managers in 25 states must reconcile their trust accounts monthly, and only Arizona, Colorado and New Mexico name a “three-way reconciliation” in rule text. Records must be kept 2 to 8 years. The table below covers all 50 states and DC, checked against statutes and commission rules on November 3, 2026.
It is for property managers and their bookkeepers who hold rent and owner money for other people and want the rule for each state in one place, with the citation. A trust account here means a bank account that holds money belonging to owners and tenants, kept apart from the manager’s own operating money.
Method
Sources. For each state we read the real estate licensing statute and the licensing board’s or commission’s rules, and the landlord-tenant statute for security deposits. Every row links the pages we read. Where the official site would not load without JavaScript or blocked downloads, we used Justia’s copy of the same statute or Cornell’s copy of the rule and say so in the source notes. That applies to parts of Alabama, Arkansas, Georgia, Mississippi, New Jersey, New Mexico, Tennessee, Utah and West Virginia.
Date checked. November 2 and 3, 2026. Several rules changed in 2026: Virginia replaced 18VAC135-20-180 with -181 on April 1, 2026, West Virginia’s rule took effect April 7, 2026, and Iowa renumbered its rules to 481 IAC chapter 2013 in June 2026.
What the columns mean. “License” is whether managing rentals for others for pay needs a license, with the main exemption. “Reconciliation” gives how often the rule requires one and whether the rule uses the words “three-way reconciliation”. Many states require the same three-balance match (bank, journal, sum of ledgers) without that label; the citation shows which. “Record retention” is the period for trust and property management records.
What “none found” means. We read the licensing statute and rules and found no such requirement. It does not mean the state forbids the practice, and a lender, an owner contract or an auditor may still require it. We found no “not public” cells.
The table
| State | Regulator | License to manage rentals for others? | Trust account for rent and owner funds? | Reconciliation | Security deposits | Record retention | Audit or annual filing | Citations | Source URLs |
|---|---|---|---|---|---|---|---|---|---|
| Alabama | Alabama Real Estate Commission (AREC) | Yes: Rule 790-X-1-.03(1) covers leasing/PM incl. collecting and escrowing rent/deposits. Exempt: owners (34-27-2(b)(1)). | Yes: separate federally insured account in Alabama financial institution (34-27-36(b)(8)b); PM funds held by qualifying broker (790-X-3-.03). | None found; three-way not named | Max one month’s rent (35-9A-201); no separate-account or interest provision; broker-held deposits are trust funds (790-X-3-.03(6)). | 3 years (34-27-36(b)(8)c, (b)(30)) | Office inspections incl. past 6 months’ bank statements (790-X-3-.09); account info on request (790-X-3-.03(4)). No annual filing found. | Ala. Code 34-27-2(b)(1), 34-27-36(b)(8), (b)(30), 35-9A-201; Ala. Admin. Code 790-X-1-.03, 790-X-3-.03, 790-X-3-.09 | 1 2 3 |
| Alaska | Alaska Real Estate Commission (Div. of Corporations, Business & Professional Licensing) | Yes: collecting rent/practicing PM needs license (AS 08.88.161(3),(4)). Exempt: owner managing own property; entity employees for entity-owned property (08.88.900(a)(1),(9)). | Yes: separate trust account for deposits and rents (AS 08.88.351(a)(3)); federally insured Alaska bank, titled ‘trust account’, filed with Commission (12 AAC 64.180). | Monthly; three-way not named | Landlord deposits in trust account at bank/S&L/escrow agent where practicable; may share account with prepaid rent if separately accounted; no interest requirement (AS 34.03.070(c)). | 3 years from end of management contract (AS 08.88.351(a)(1),(c)) | Commission inspections and complete audits, noticed or unnoticed (12 AAC 64.135); trust account info filed with Commission (12 AAC 64.180(b)). | AS 08.88.161, 08.88.351, 08.88.900, 34.03.070; 12 AAC 64.135, 64.180, 64.210, 64.220 | 1 2 3 4 5 |
| Arizona | Arizona Department of Real Estate (ADRE) | Yes: broker includes renting/leasing and collecting rent for others for compensation (32-2101(51)). Exempt: owners; on-site managers/leasing agents; one nonresidential manager (32-2121(A)). | Yes: PM accounts designated trust; all owner monies unless owner directs otherwise; deposit within 3 banking days; insured Arizona depository (32-2174, 32-2151(A)). | Monthly; “three-way reconciliation” named | Max 1.5 months’ rent; no separate-account/interest rule (33-1321); rental agreement states deposit disposition (32-2174(E)); identify nonowner tenant monies (32-2151(C)(3)). | Financial records 3 years; rental agreements 1 year after expiration (32-2175); transaction records 5 years (32-2151.01) | Routine audits on request (32-2175(I)). No annual filing found. | A.R.S. 32-2101(51), 32-2121(A), 32-2151, 32-2151.01, 32-2174, 32-2175, 33-1321 | 1 2 |
| Arkansas | Arkansas Real Estate Commission (Dept. of Labor & Licensing) | Yes: real estate or property management broker license (17-42-103(12), Act 392 of 2025). Exempt: owners, resident on-site managers, limited salaried leasing employees (17-42-104(a)). | Yes: separate FDIC-insured trust account or escrow agent, titled trust/escrow, non-interest-bearing except IREBTA; reported to Commission; deposit within 3 days (17 CAR 220-1007). | Monthly; three-way not named | All deposits in principal broker’s trust account (220-1007(h)); lease states where held (220-1008(b)(6)); Ark. Code 18-16-301 to -306 sets max/refund, no interest. | 3 years, including reconciliations (220-1006(b)(3), 220-1007(g)(2)(B)) | Records open to Commission investigative staff (220-1006(b)(3), 220-1007(g)(3)); trust account info filed with Commission (220-1007(e)). | Ark. Code 17-42-103(12), 17-42-104(a), 18-16-301 to -306; 17 CAR 220-1006, 220-1007, 220-1008, 220-1020, 220-1021 | 1 2 |
| California | California Department of Real Estate (DRE) | Yes: broker license for leasing/renting/collecting rents for others for compensation (B&P 10131(b)). Exempt: resident apartment managers, hotel/motel managers (10131.01); corporate officers (10133). | Yes: funds not in neutral escrow or principal’s hands go to trust account at California bank, broker as trustee, within 3 business days (B&P 10145; 10 CCR 2832). | Monthly; three-way not named | Held by landlord for tenant; no statewide separate-account or interest rule; max 1 month (2 for small landlords); 21-day return (Civ. 1950.5). Broker-held = trust funds. | 3 years (B&P 10148(a)) | Records available for DRE examination; audit on sufficient cause, cost charged on 10145 violation (10148). No annual PM filing found. | Cal. B&P Code 10131(b), 10131.01, 10133, 10145, 10148; 10 CCR 2831.2, 2832; Cal. Civ. Code 1950.5 | 1 2 3 |
| Colorado | Colorado Real Estate Commission / Division of Real Estate (DORA) | Yes: broker includes renting/leasing for compensation (C.R.S. 12-10-201(6)(a)). Exempt: own property; salaried on-site apartment managers; condo on-site managers (12-10-201(6)(b)). | Yes: separate trust/escrow accounts, at least one for rents and one for security deposits; deposit within 5 business days (4 CCR 725-1 Rules 5.2, 5.5, 5.7). | Monthly; “three-way reconciliation” named | Separate security-deposit escrow account (Rule 5.5); not transferred to owner without tenant written authorization; transfer within 60 days on termination (Rule 5.8). | 4 years (Rule 6.20, transaction files) | Records produced for audit (Rule 5.21); notice of audit selection in rules. No annual filing found. | C.R.S. 12-10-201(6); 4 CCR 725-1 Rules 5.2, 5.5, 5.7, 5.8, 5.14.C, 5.21, 6.20 | 1 2 |
| Connecticut | Connecticut Real Estate Commission and Department of Consumer Protection (DCP); Banking Commissioner for security-deposit complaints | Yes: broker/salesperson license to rent or lease real estate for others for a fee (20-311(15), 20-312). Exempt: owner/lessor and resident on-site staff; attorneys; fiduciaries (20-329). | Yes: separate escrow/trust account in a bank doing business in CT; rental money and security deposits deposited within 3 banking days (20-324k; RCSA 20-328-7a). | None found; three-way not named | Landlord deposits immediately in escrow at CT financial institution; max 2 months’ rent (1 if 62+); annual interest at deposit index; notice to tenant within 30 days (47a-21). | 7 years after transaction closes/escrow disbursed/agreement expires, incl. escrow bank statements, checks, checkbooks (20-325m; RCSA 20-328-3a(b)) | Commission may examine and audit any escrow/trust account whenever deemed necessary (20-324k(b)); records produced on DCP request (20-325m(c)). No annual filing found. | C.G.S. 20-311, 20-312, 20-324k, 20-324l, 20-325m, 20-329, 47a-21, 20-450 to 20-462; RCSA 20-328-3a, 20-328-7a | 1 2 3 4 5 6 |
| Delaware | Delaware Real Estate Commission (Division of Professional Regulation) | Yes: leasing/renting for others (24 Del.C. 2901(a), 2902(a)(2)). Exempt: owners and employees; PM service providers who don’t lease/negotiate, limited by Reg 9.0. | Yes: escrow account in federally insured bank with Delaware offices for rental money; deposit within 72 hours (24 Del.C. 2923(a),(d); Reg 6.4). | None found; three-way not named | Separate escrow ‘security deposits account’ at insured Delaware bank, location disclosed; max 1 month (1-yr+ leases); no interest rule (25 Del.C. 5514(b)). | 3 years (Reg 6.3) | Records open to Commission inspection or audit (24 Del.C. 2923(e)). No annual filing found. | 24 Del.C. 2901, 2902, 2923; 25 Del.C. 5514; 24 Del. Admin. Code 2900 Regs 6.1, 6.3, 6.4, 6.6, 9.0 | 1 2 3 |
| District of Columbia | DC Real Estate Commission (Dept. of Licensing and Consumer Protection, DLCP) | Yes: separate property manager license; brokers deemed qualified (D.C. Code 47-2853.141, .142). Exempt: owner/lessor managing own property; clerical employees (47-2853.181). | Yes: separate account at FDIC-insured DC institution, deposit within 7 days; notify Commission within 14 days (D.C. Code 42-1704(a),(b); 17 DCMR 2702). | None found; three-way not named | Interest-bearing escrow at insured DC institution solely for deposits (14 DCMR 308.3); interest at statement savings rate (311); max 1 month (308.2). | 3 years (D.C. Code 47-2853.197(22)) | Written authorization for Commission to examine escrow accounts ‘at any time’ (42-1704(c); 17 DCMR 2702.5(f)). No annual filing found. | D.C. Code 42-1704, 42-3502.17, 47-2853.141, .142, .181, .197; 17 DCMR 2702; 14 DCMR 308, 311 | 1 2 3 4 5 6 7 8 |
| Florida | Florida Real Estate Commission (FREC) / DBPR Division of Real Estate | Yes: broker includes renting/leasing for others for compensation (F.S. 475.01(1)(a)). Exempt: owners; salaried on-site leasing employees; salaried condo/co-op managers (475.011). | Yes: immediately deposit entrusted funds in escrow/trust account at Florida bank, credit union or S&L; up to $5,000 broker funds in PM account (F.S. 475.25(1)(k)). | Monthly; three-way not named | Separate non-interest Florida account; or interest-bearing (tenant gets 75% of rate or 5% simple); or surety bond plus 5% interest; no commingling (F.S. 83.49(1)). | 5 years (F.S. 475.5015) | DBPR may inspect and audit brokers (F.S. 475.5016); books subject to inspection (61J2-14.012(1)). No annual filing found. | F.S. 475.01(1)(a), 475.011, 475.25(1)(k), 475.5015, 475.5016, 83.49(1); F.A.C. 61J2-14.012 | 1 2 3 |
| Georgia | Georgia Real Estate Commission (GREC) | Yes: broker includes PM (O.C.G.A. 43-40-1, 43-40-30). Exempt: owners and employees; broker employees doing limited PM tasks; some short-term (<90 day) managers (43-40-29). | Yes: federally insured account designated trust, registered with Commission within one month; PM brokers may keep separate rental trust accounts (Rule 520-1-.08(1)(d), (4)). | Monthly; three-way not named | Held in trust in escrow account solely for deposits at regulated bank; tenant told location (44-7-31); no interest rule found; licensee-owners can’t use bond (Rule .08(4)(c)). | 3 years (Rule 520-1-.08(6)(a) reconciliations; 520-1-.07(4)) | Commission trust account examination or CPA report (43-40-20; Rule .08(5)); at renewal submit trust-account summary or CPA report (Rule .08(7)). | O.C.G.A. 43-40-1, 43-40-20, 43-40-29, 43-40-30, 44-7-31; Ga. Comp. R. & Regs. 520-1-.07(4), 520-1-.08 | 1 2 3 |
| Hawaii | Hawaii Real Estate Commission (DCCA Professional & Vocational Licensing; RICO enforces) | Yes: broker includes managing real estate for others (HRS 467-1). Exempt: owners; custodians/caretakers leasing property in their charge; hotel managers (467-2). | Yes: federally insured Hawaii trust account, principal broker as trustee; deposit by next business day; special accounts for rental deposits and receipts (HAR 16-99-3(e), 16-99-4). | None found; three-way not named | Max one month’s rent; no interest or separate-account requirement found (DCCA handbook); broker-held deposits are trust funds (HAR 16-99-3(e), 16-99-4(g)). | 3 years, kept in Hawaii (HAR 16-99-4(b), (f)) | Records and funds subject to Commission inspection (16-99-4(b)). No annual filing found. | HRS 467-1, 467-2; HAR 16-99-3(e), 16-99-4 | 1 2 3 |
| Idaho | Idaho Real Estate Commission (within Division of Occupational and Professional Licenses, DOPL) | No for rental management: ‘broker’ definition covers sales/listing/purchase/option/exchange, not leasing; DOPL says state ‘does not regulate property managers.’ Licensees still bound by chapter 20. | Licensed brokers only: entrusted moneys deposited immediately in neutral ‘real estate trust account’ at approved depository; no commingling (max $300 broker funds). | Monthly; three-way not named | Unlicensed third-party managers: residential deposits in separate account at federally insured institution, apart from operating account (licensees exempt). Refund within 21/30 days, itemized. | 3 calendar years after year of event/closing/final disbursement, incl. trust ledgers and reconciliation records (licensed brokers) | Commission may conduct periodic inspections and audits of trust accounts; CPA audit at broker’s expense if irregularity. Trust-account notice/inspection authorization form filed per account. | I.C. 54-2002, 54-2003, 54-2004(39); 54-2041, 54-2042, 54-2044, 54-2049, 54-2058(2); I.C. 6-321 | 1 2 3 4 5 6 7 8 9 10 |
| Illinois | Illinois Department of Financial and Professional Regulation (IDFPR), Division of Real Estate | Yes: ‘broker’ includes renting/leasing for others and supervising rent collection; residential leasing agent license for leasing-only. Exempt: owners/lessors, their regular employees, on-site resident managers, attorneys, fiduciaries. | Yes: sponsoring brokers keep escrow moneys (incl. security deposits) in separate non-interest-bearing escrow account at federally insured depository; no commingling. Rent owed to owners not ‘escrow moneys.’ | Monthly; three-way not named | Broker-held deposits stay in escrow for lease term unless tenant waives in writing (bold). Itemized damages within 30 days, else refund within 45; interest required at 25+ units. | 5 years for escrow records (journals, statements, ledgers, reconciliations, master log) and transaction/PM records; latest 2 years kept at office | Escrow accounts disclosed to Division at licensure, updates within 10 days; licensure consents to Division examination/audit; escrow records produced within 24 hours on request. | 225 ILCS 454/1-10, 5-5, 5-20, 20-20(a)(17),(18),(22); 68 Ill. Adm. Code 1450.750, 1450.755; 765 ILCS 710/1; 765 ILCS 715/1, 715/2 | 1 2 3 4 5 6 7 8 |
| Indiana | Indiana Real Estate Commission (administered by Indiana Professional Licensing Agency) | Yes: license required to ‘lease, rent, manage’ real estate for consideration. Exempt: own property; owner’s salaried employees; owner of up to 12 apartment units on one/contiguous parcels; broker-supervised apartment leasing staff. | Yes: broker company must maintain clearly identified trust account(s), interest or noninterest bearing, at federally insured institution, for all funds belonging to others; no personal/business funds. | None found; three-way not named | No trust/escrow or interest rule in IC 32-31-3; ‘landlord’ includes rental agents. Return with itemized deductions within 45 days; manager/agent disclosure required. | No general trust-record retention period found; closing statements kept at least 5 years (876 IAC 8-2-3). | Commission may inspect licensee records; broker must give detailed trust-account summary on request of Commission or Attorney General. No annual audit or filing found. | IC 25-34.1-1-2(4), 25-34.1-3-2, 25-34.1-2-5(6), 25-34.1-4-5; 876 IAC 8-1-13, 8-2-2, 8-2-3; IC 32-31-3-3, -12, -14, -18 | 1 2 3 |
| Iowa | Iowa Real Estate Commission (within Dept. of Inspections, Appeals, and Licensing) | Yes: broker includes one who, for compensation, rents/leases or ‘collects… rent for the use of real estate’. Exempt: owners and their full-time staff; resident managers; certain affiliated-entity leasing (543B.7A). | Yes: rents, property management funds and other trust funds go in identified ‘trust’ account at federally insured institution; PM funds may use separate account; no commingling beyond $1,000 for bank fees. | Monthly; three-way not named | Max two months’ rent; held in federally insured institution, not commingled; may be in (common, interest-bearing) trust account; interest first 5 years to landlord; return within 30 days. Tenant ledgers required. | At least 5 years: trust account records and transaction file (after closing); all books, accounts, records for each property managed. | Broker files Consent to Examine and Audit form per trust account (not needed for owner-name PM account) or affidavit if none; Commission random test audits; annual accounting to PM client. | Iowa Code 543B.3, 543B.7, 543B.7A, 543B.46; 481 IAC 2013.1, 2013.2(2), 2013.5 (formerly 193E-13); Iowa Code 562A.12 | 1 2 3 4 |
| Kansas | Kansas Real Estate Commission (KREC) | Residential: no. ‘Lease’ means rent or lease for nonresidential use, so residential management is outside the license act. Nonresidential leasing for others needs broker/salesperson license; exempt: own property, 5%+ owner-employees. | Yes for licensed brokers: separate designated trust account in Kansas (or adjoining state with permission) at insured institution for trust funds in real estate transactions. No KREC trust rule for residential-only managers. | Monthly; three-way not named | Max 1 month’s rent unfurnished (1.5 furnished, +0.5 pets); no escrow, separate-account or interest rule found; return within 14/30 days with itemization; 1.5x damages. | At least 3 years: all records of broker’s real estate business, including trust account records under K.A.R. 86-3-18. | Broker files consent-to-audit form naming each trust account; trust exams and record inspections when Commission directs; ‘report on closing trust account’ within 10 days of closure/change. | K.S.A. 58-3035(f),(j), 58-3037, 58-3061; K.A.R. 86-3-10, 86-3-18, 86-3-22; K.S.A. 58-2550 | 1 2 3 4 5 6 |
| Kentucky | Kentucky Real Estate Commission (within Kentucky Real Estate Authority) | Yes: ‘property management’ for others for a fee is real estate brokerage. Exempt: owner’s/principal broker’s regular employees; persons paid mainly with a rental unit. | Yes: escrow account in Kentucky for money of others; property management accounts kept separate or PM funds identified in escrow records. | None found; three-way not named | Separate account used only for deposits; tenant told bank and account number (URLTA, KRS 383.580, applies where locally adopted). No interest duty found. | 5 years (PM agreements, leases, monthly owner statements, ledgers, bank statements) | Broker signs permit for Commission to audit escrow accounts at licensure/renewal; uncorrected overdrafts (72 hrs) reported. No annual filing found. | KRS 324.010(1),(9); KRS 324.030(5); KRS 324.111; 201 KAR 11:121 (records; property management section); KRS 383.500, 383.580 | 1 2 3 4 5 6 |
| Louisiana | Louisiana Real Estate Commission (LREC) | Yes: property management for others for a fee is real estate activity. Exempt: owners managing own property; broker’s salaried employees with limited duties. | Yes: in-state ‘Rental Trust Account’ for rents and separate ‘Security Deposit Trust Account’; non-interest-bearing unless all parties agree in writing. | None found; three-way not named | Broker must use separate Security Deposit Trust Account (LREC rule). Landlord statute (R.S. 9:3251): return within one month; no separate-account or interest duty. | 5 years (bank statements, ledgers, leases, management agreements, receipts) | None found (no annual audit or escrow filing found in statute or rules). | La. R.S. 37:1431(20)-(21); 37:1438(A)(1),(5),(6); 37:1449(D)-(E); LAC 46:LXVII.1801(D), 1803, 2605, 2607, 2701, 2711, 2713; La. R.S. 9:3251 | 1 2 3 4 5 |
| Maine | Maine Real Estate Commission (Dept. of Professional and Financial Regulation, Office of Professional and Occupational Regulation) | Unclear/likely no: ‘real estate brokerage’ means services ‘calculated to result in the transfer of an interest in real estate’; listed acts cover sale/purchase/exchange only, not leasing or management. | Licensed agencies: yes, federally insured ‘real estate trust account’ for earnest money and other money held as agency. No PM-specific trust rule found. | None found; three-way not named | Not commingled; held in bank account beyond landlord’s creditors; one escrow account allowed; disclose bank and account number on request. No interest duty found. | 3 years (trust records after funds disbursed; brokerage records 3 calendar years) | Office may be examined routinely once each licensing period; director may require written authorization to confirm trust balances. No annual filing found. | 32 M.R.S. §13001(2), §13002, §13178; 02-039 C.M.R. ch. 400 §§3-5; 14 M.R.S. §6038 | 1 2 3 4 5 |
| Maryland | Maryland Real Estate Commission (Maryland Department of Labor) | Yes: brokerage services include leasing and ‘collecting rent’ for another for consideration. Exempt: owner/lessor managing own property unless primary business is brokerage. | Yes: trust money kept separate, solely for trust money, in insured Maryland institution; non-interest-bearing unless parties instruct otherwise; account reported to Commission. | None found; three-way not named | Separate interest-bearing Maryland account used only for deposits (or insured CDs/government securities). Interest on deposits $50+: greater of 1-yr Treasury yield-curve rate or 1.5%, simple. | 5 years (property management: 5 years after management agreement ends) | Escrow bank and account number reported to Commission (changes within 10 days); Commission may inspect records. No annual audit/filing found. | Md. Code, Bus. Occ. & Prof. §§17-101(l), 17-102, 17-501 to 17-505, 17-507; COMAR 09.11.01.06, .07, .11; Md. Code, Real Prop. §8-203 | 1 2 3 4 5 6 7 8 9 |
| Massachusetts | Board of Registration of Real Estate Brokers and Salespersons (Division of Occupational Licensure) | Broker license needed to rent or lease (or negotiate rentals) for others for a fee; no separate PM license. Exempt: owners/lessors and their regular employees managing that real estate. | Yes for transaction money: money held during a sale/purchase/renting transaction goes immediately into bank escrow account unless parties agree otherwise in writing. No PM-specific rule found. | None found; three-way not named | Separate interest-bearing account in a Massachusetts bank, beyond lessor’s creditors. Interest 5%/yr or lesser bank rate, paid yearly (deposit held 1+ year); last-month rent earns interest too. | 3 years (copies of escrow checks); security-deposit records 2 years after tenancy ends | Escrow funds and records subject to Board inspection. No audit or annual filing found. | M.G.L. c. 112, §87PP, §87QQ; 254 CMR 3.00(10); M.G.L. c. 186, §15B | 1 2 3 4 |
| Michigan | Michigan Dept. of Licensing and Regulatory Affairs (LARA) with Board of Real Estate Brokers and Salespersons | Yes: real estate broker includes engaging in property management (leasing/renting others’ property for a fee). Exempt: owner or lessor acting on own property unless as principal vocation. | Yes: broker doing property management keeps property management accounts separate from all other accounts; may bear interest unless the management contract says otherwise. | None found; three-way not named | Deposit in a regulated financial institution; landlord may use funds only if it posts cash/surety bond with Secretary of State. No separate-account or interest rule. | 3 years (trust or escrow account records); no separate PM-account period found | PM records subject to inspection by the department. No annual audit/filing found. | MCL 339.2501(r),(u); 339.2503(1); 339.2512(1)(k); 339.2512c; Mich. Admin. Code R 339.22134; MCL 554.604 | 1 2 3 4 5 |
| Minnesota | Minnesota Department of Commerce (Commissioner of Commerce) | Yes: real estate broker includes one who for another and for a fee ‘rents, manages’ real estate. Exempt: custodian, janitor or employee of owner/manager leasing units in that residential building. | Yes: all trust funds into broker trust account at Minnesota (or examinable) depository; pooled interest-bearing account, interest to Minnesota Housing Finance Agency unless parties agree otherwise. | None found; three-way not named | Not treated as funds held in a fiduciary capacity; no separate-account rule found. Simple interest 1% per year, noncompounded. | 6 years (incl. trust account records, from closing or document date) | Trust bank names/account numbers reported to commissioner; changes reported immediately; 10 days’ notice before closing an account; records open to inspection anytime. No annual filing found. | Minn. Stat. §82.55 subd. 19; §82.56(d); §82.72 subd. 3; §82.75 subds. 1, 5-8, 11; §504B.178 subd. 2 | 1 2 3 4 5 6 |
| Mississippi | Mississippi Real Estate Commission (MREC) | Yes: real estate broker includes anyone who for a fee will ‘rent, lease, manage’ real estate. Exempt: bona fide owners and their regular salaried employees. | Yes (implied): monies of others must not be commingled; broker deposits received funds in trust/escrow account at bank or trust company; rules reference ‘escrow account or rental account’. | None found; three-way not named | Landlord holds deposit for tenant; tenant’s claim has priority over landlord’s creditors. No separate-account or interest requirement. | 3 years after consummation (incl. leases and escrow records) | Escrow records subject to Commission inspection at all times. No annual audit/filing found. | Miss. Code Ann. §73-35-3(1),(8); §73-35-21(1)(f) (as amended by 2026 SB 2748, eff. July 1, 2026); 30 Miss. Admin. Code Pt. 1601, R. 3.1(G), 3.4(C); Miss. Code Ann. §89-8-21 | 1 2 3 4 |
| Missouri | Missouri Real Estate Commission (Division of Professional Registration, Dept. of Commerce and Insurance) | Yes: broker includes one who for others rents, leases or negotiates rentals. Exempt: owner/agent’s employees limited to ministerial tasks (taking applications/rent payable to broker, showing units). | Yes: separate ‘property management escrow account’ for current rents and owner funds; deposit within 10 banking days; broker funds capped at $1,000 for service charges. | None found; three-way not named | Broker: deposits kept intact in escrow account other than PM account unless owner agrees otherwise. Landlord law: federally insured institution; interest belongs to landlord. | 3 years (business books, accounts, PM agreements and records) | Broker files escrow account names/numbers and written authorization for Commission to examine accounts; signs ‘Consent to Examine and Audit’ form on request. No annual filing found. | RSMo §339.010; §339.105; 20 CSR 2250-8.160, 8.220, 8.230; RSMo §535.300 | 1 2 3 4 |
| Montana | Montana Dept. of Labor and Industry, Property Management Licensure program (moved from Board of Realty Regulation, Oct. 1, 2023) | Yes: separate property manager license (or real estate broker/salesperson license). Exempt: owner/relatives, persons leasing 4 or fewer residential units, incidental owner employees, others. | Yes: rents, deposits and other money of others into insured Montana trust account within 3 business days; no sweep accounts or CDs; up to $1,000 personal funds. | Monthly; three-way not named | Property managers must hold security deposits in trust account, even on own property. Landlord-tenant statute: no separate-account or interest provision found. | 8 years after property management agreement ends (trust records, property files) | Trust records kept ‘to facilitate auditing’; department may cite $1,000 per trust-account violation. No annual filing found. | MCA 37-56-101, -103, -104, -106; ARM 24.209.601; MCA 70-25-101 to -206 | 1 2 3 4 5 6 7 8 |
| Nebraska | Nebraska Real Estate Commission | Yes: broker includes one who for compensation negotiates rentals/leases or ‘collects rents or attempts to collect rents’. Exempt: owners and regular employees; resident managers; owner’s relatives; broker’s employees managing for owner. | Yes: separate insured Nebraska checking trust account for all trust funds; separate PM trust account suggested (not mandatory) by Commission manual. | Each bank statement; three-way not named | Residential deposits held by broker in trust; cannot pay owner expenses without tenant and owner written consent. Landlord statute: no separate-account or interest rule found. | 5 years (after consummation/termination; incl. bank statements and reconciliations) | Broker registers each trust account and authorizes Commission examination; statute says examination ‘shall be made annually or at such time as the commission may direct’. | Neb. Rev. Stat. §81-885.01(2); §81-885.04; §81-885.21; 299 NAC ch. 3 (001-004) and incorporated Trust Account Manual (Sales §II; Property Mgmt §III); Neb. Rev. Stat. §76-1416 | 1 2 3 4 5 6 |
| Nevada | Nevada Real Estate Division (Dept. of Business and Industry) and Real Estate Commission | Yes: real estate license plus property management permit (24 hrs instruction). Exempt: owners and regular employees; on-site managers of one property; certain CIC, subsidized-housing managers. | Yes: two separate PM trust accounts, one for rental operations and one solely for security deposits, apart from sales trust accounts; ledger per unit. | Monthly; three-way not named | Broker: separate PM security-deposit trust account required. Landlord statute (NRS 118A.242): no separate-account or interest requirement found. | 5 years after last activity on PM trust account | Yes: annual trust account reconciliation filed with Division by license expiration (or annual exemption declaration); records open to Division audit; deficit >45 days is disciplinable. | NRS 645.019, 645.0195, 645.030, 645.0445, 645.310(4)-(5), 645.6052-.6056; NAC 645.655(8)-(9), 645.805, 645.806; NRS 118A.242 | 1 2 3 |
| New Hampshire | New Hampshire Real Estate Commission (Office of Professional Licensure and Certification) | Yes: broker includes one who for others rents/leases or ‘collects… rent for the use of real estate’. Exempt: owner and owner’s regular employees for owner’s property. | Yes: principal broker holding any monies for others keeps separate escrow/real estate trust account at a New Hampshire financial institution. | Monthly; three-way not named | Held in trust, not mingled with landlord funds; may pool in one NH trust account (or post bond). Interest at bank savings rate if held 1 year or longer. | 3 years (escrow/trust records; transaction records after consummation) | Principal broker signs permit at licensure allowing Commission to audit escrow accounts. No annual filing found. | RSA 331-A:2, :3, :4(I), :13, :26(VIII), (XVIII), (XIX); N.H. Admin. R. Rea 702.01; RSA 540-A:6 | 1 2 3 |
| New Jersey | New Jersey Real Estate Commission (Dept. of Banking and Insurance) | Yes: broker includes one who rents or ‘collects or offers or attempts to collect rent’ for others for a fee. Exempt: bona fide owner/lessor of own property; attorneys, receivers, banks, etc. | Yes: special trust/escrow account(s) at authorized NJ financial institution, separate from personal/business accounts, for all moneys of others; accounts disclosed to Commission. | At least quarterly; three-way not named | Held in trust, not commingled; 10+ units: insured NJ money-market fund or variable-rate interest account; fewer units: NJ interest-bearing account. Interest to tenant yearly; written notices. | 6 years (funds of others from receipt; PM agreements, leases from earlier date) | Records open to Commission inspection on demand. No annual audit or filing found. | N.J.S.A. 45:15-3, 45:15-4; N.J.A.C. 11:5-5.1, 11:5-5.4(a)-(b), 11:5-5.5; N.J.S.A. 46:8-19 | 1 2 3 4 5 6 7 |
| New Mexico | New Mexico Real Estate Commission | Yes: qualifying/associate broker license for ‘managing property for others’ or leasing for others. Exempt: owners, owner’s or broker’s employees managing owned property, attorneys, receivers/trustees. | Yes: separate ‘property management trust account’ for funds of others; PM funds may not go in the sales brokerage trust account. | Monthly; “three-way reconciliation” named | Tenant security deposits go into PM trust account. Lease under 1 year: max one month’s rent; over one month’s rent on annual lease earns interest; return/itemize within 30 days. | Trust records 6 years after transaction; PM records for full agreement term plus 6 years after termination. | PM qualifying brokers file a declaration of intent with the Commission; records subject to Commission inspection and produced on request. No routine annual audit found. | NMSA 61-29-2; 16.61.1.7(UU) NMAC; 16.61.23.8(D), .9(B), .10, .12 NMAC; 16.61.24 NMAC; NMSA 47-8-18 | 1 2 3 4 5 |
| New York | New York Department of State, Division of Licensing Services | Yes: broker includes one who rents or ‘collects or offers or attempts to collect rent’ for others for a fee. Exempt: receivers, court appointees, public officers, attorneys; certain NYC-authorized tenant associations/nonprofits. | Yes: ‘separate, special bank account’ used exclusively for principals’ money, federally insured; deposit within three business days; no commingling. | None found; three-way not named | Held in trust, not commingled, at NY bank; tenant told bank/amount; 6+ units: interest-bearing, 1%/yr admin fee. Cap one month’s rent; return/itemize within 14 days. | 3 years, but 19 NYCRR 175.23 covers residential 1-4 family/co-op/condo sale transactions only; no PM-specific retention rule found. | None found: no audit or trust-account filing requirement found; deposit violations are grounds for DOS discipline (175.3(b)). | RPL §§440(1), 440-a, 442-f; 19 NYCRR 175.1, 175.2, 175.3, 175.23; GOL §§7-103, 7-108 | 1 2 3 4 5 6 7 |
| North Carolina | North Carolina Real Estate Commission | Yes: broker license to lease, rent or offer to rent real estate for others for compensation. Exempt: owners/lessors and W-2 employees, attorneys, court appointees, trustees, limited salaried leasing staff of brokers. | Yes: demand deposit ‘Trust Account’/‘Escrow Account’ at federally insured NC-doing-business institution; deposit within three banking days; non-interest-bearing unless parties authorize in writing. | Monthly; three-way not named | Trust account at licensed insured institution or landlord bond; tenant notified of bank within 30 days. Cap 2 weeks/1.5 months/2 months’ rent by term; refund/itemize within 30 days. | 3 years after all funds disbursed or transaction concludes (or agency agreement ends), whichever later; includes leases and trust records. | Commission may inspect trust records periodically without prior notice; bank must agree to make account records available. No annual audit or filing found. | G.S. 93A-1, 93A-2(a),(c); 93A-6(a)(12), (d), (g); 21 NCAC 58A .0108, .0116, .0117; G.S. 42-50 to 42-56 | 1 2 3 4 5 6 7 |
| North Dakota | North Dakota Real Estate Commission (NDCC 43-23-01) | Yes, broker license (leasing for others counts). Exempt: owners/lessors and their regular employees (NDCC 43-23-07). | Yes. All money of others in separate ND federally insured ‘trust’/‘escrow’ account; trust accounts must be noninterest-bearing. | Monthly; three-way not named | Landlord must hold in federally insured interest-bearing account; interest to tenant unless occupancy under 9 months (NDCC 47-16-07.1). | 6 years from receipt of funds/property | Broker files form authorizing Commission to examine/audit trust account; notify Commission of account changes within 10 days. No annual filing found. | NDAC 70-02-01-15; NDCC 43-23-06.1(9), 43-23-07, 43-23-11.1; NDCC 47-16-07.1 | 1 2 3 |
| Ohio | Ohio Dept. of Commerce, Division of Real Estate & Professional Licensing (Superintendent) and Ohio Real Estate Commission | Yes, broker license (operating/managing/renting for others). Exempt: owners and their regular employees (ORC 4735.01(A)(5), (I)(1)(a)). | Yes. Separate property management trust account in Ohio for rents, security deposits, owner funds (ORC 4735.18(A)(27); OAC 1301:5-5-11). | None found; three-way not named | In PM trust account unless lease/PMA differ. Landlord pays 5%/yr on excess over $50 or one month’s rent after 6+ months (ORC 5321.16). | 3 years from date of transaction | Must submit trust account name, number, depository to Superintendent. No periodic audit or annual filing found in sections reviewed. | ORC 4735.01; 4735.18(A)(24),(26),(27); OAC 1301:5-5-09, 1301:5-5-11; ORC 5321.16 | 1 2 3 4 5 |
| Oklahoma | Oklahoma Real Estate Commission | Yes, license (renting/leasing; controlling rent from SFR residents). Exempt: owners/employees, on-site resident managers (59 O.S. 858-102, 858-301). | Yes, when holding others’ funds (rents, security deposits included); separate federally insured account registered with Commission (OAC 605:10-13-1). | None found; three-way not named | Must be kept in escrow account in Oklahoma federally insured institution (41 O.S. 115). No interest requirement found. | 5 years; for trust records, from date funds disbursed | Register all trust, security deposit and rental management operating accounts with Commission; records open to inspection. No annual audit found. | 59 O.S. 858-102, 858-301; OAC 605:10-13-1(a),(e),(k),(l),(n); 41 O.S. 115 | 1 2 |
| Oregon | Oregon Real Estate Agency | Yes, property manager or principal broker license. Exempt: e.g., full-time employees of an owner managing only employer’s property (ORS 696.030). | Yes. At least one clients’ trust account, plus separate security deposits account if holding deposits (ORS 696.241; OAR 863-025-0025). | Monthly; three-way not named | Separate security deposits account required. Interest-bearing only if PMA allows and tenant approves in writing. | 6 years (after document superseded/terminated) | Agency conducts clients’ trust account reconciliation reviews (OAR 863-025-0090); records open to Commissioner inspection. | ORS 696.020, 696.030, 696.241, 696.280; OAR 863-025-0025, -0028, -0035, -0090 | 1 2 |
| Pennsylvania | State Real Estate Commission (Dept. of State) | Yes, broker license (‘manages any real estate’). Exempt: owners; owner’s multifamily employees without lease/money authority (63 P.S. 455.304). | Yes. Rents go to a rental management account separate from escrow and general accounts; other money of others in escrow (49 Pa. Code 35.321). | None found; three-way not named | Broker holds in escrow until tenancy ends. Landlord: deposits over $100 in escrow at regulated institution; interest after 2nd year, less 1% fee. | 3 years following consummation | Commission may make routine office inspections up to 4 times a year (35.246). No annual filing found. | 63 P.S. 455.201, 455.304; 49 Pa. Code 35.246, 35.286, 35.321, 35.325, 35.328; 68 P.S. 250.511b (L&T Act sec. 511.2) | 1 2 3 4 5 6 7 |
| Rhode Island | Dept. of Business Regulation, Real Estate Section (Real Estate Commission) | Yes, broker license for managing others’ property. Exempt: bona fide owner, lessor or lessee and regular employees (230-RICR-30-20-2.12). | Yes. Escrow account in RI federally insured institution, separate from broker funds (RIGL 5-20.5-26). | Monthly; three-way not named | No separate-account or interest rule found in landlord statute (RIGL 34-18-19); broker-held deposits go to escrow. | 3 years | Broker/office supervisor keeps a monthly report on escrow account status; records available to Commission on demand. No annual filing found. | RIGL 5-20.5-1, 5-20.5-26; 230-RICR-30-20-2 §§2.12, 2.18, 2.20; RIGL 34-18-19 | 1 2 3 4 |
| South Carolina | South Carolina Real Estate Commission (Dept. of Labor, Licensing and Regulation) | Yes, property manager or broker license required. Exempt: unlicensed owners leasing own property (SC Code 40-57-20, 40-57-240). | Yes, when holding trust funds: demand deposit trust account in SC-authorized insured institution (40-57-136(A)). | Monthly; three-way not named | Stay in trust account until lease ends (40-57-136(C)(2)); general ledger of deposits. No interest rule found (27-40-410). | 5 years | Furnish records to Commission on request. No annual audit or filing found. | SC Code 40-57-20, -30, -135, -136(A),(C),(F),(G), -240; 27-40-410 | 1 2 |
| South Dakota | South Dakota Real Estate Commission (Dept. of Labor & Regulation) | Yes, property manager license (restricted broker) or broker. Exempt: owners/regular employees; custodians showing units (SDCL 36-21A-29). | Yes. Broker trust account rules apply to property managers; deposits, rents in federally insured institution (ARSD 20:69:14:04, :11). | Monthly; three-way not named | In federally insured institution; separate balance in owner’s or tenant ledger. No interest rule found (SDCL 43-32). | 4 years after management contract ends | PM records subject to Commission audit (ARSD 20:69:14:05); notify Commission of trust account (36-21A-82). No annual filing found. | SDCL 36-21A-6, -29, -80, -82; ARSD 20:69:14:01-:05, :11, :12; SDCL 43-32-6.1 | 1 |
| Tennessee | Tennessee Real Estate Commission (Dept. of Commerce & Insurance) | Yes, broker license (‘collects rents’). Exempt: owners, limited resident managers; vacation lodging services need a separate firm license (TCA 62-13-104). | Yes. Principal broker keeps escrow account; lease-related trust money in one or more separate escrow accounts (Rule 1260-02-.09(2),(12)). | None found; three-way not named | Landlord must hold in account used only for deposits at regulated institution; tell tenant location (TCA 66-28-301). No interest rule. | 3 years | None found for brokers. Vacation lodging firms must prove escrow account at each renewal (62-13-104(b)). | TCA 62-13-102(4), 62-13-104, 62-13-321; Rule 1260-02-.09, 1260-02-.40; TCA 66-28-301 | 1 2 3 4 5 |
| Texas | Texas Real Estate Commission (TREC) | Yes, broker/sales agent license (leasing; controlling SFR rent). Exempt: owners/owner’s employees, on-site apartment managers (Occ. Code 1101.005). | Yes, if broker accepts trust money (rent, security deposits included); separate accounts by type optional (22 TAC 535.146). | None found; three-way not named | Trust money if broker-held. Landlord must keep accurate deposit records (Prop. Code 92.106); no separate-account or interest rule found. | 4 years from date document received/created | None found; records must be readily available to Commission (535.2(h)). | Tex. Occ. Code 1101.002(1)(A), 1101.005; 22 TAC 535.2(h), 535.146; Tex. Prop. Code 92.106 | 1 2 3 |
| Utah | Utah Division of Real Estate (Dept. of Commerce) and Real Estate Commission | Yes, broker/agent, or property manager license (required from Jan 1, 2027). Exempt: owners, immediate family, bookkeeping/maintenance-only (61-2f-202.5). | Yes, in-state trust account for deposits, rents, owner reserves; separate PM account if 7+ units. Owner and lease may waive for unaffiliated PMs. | Monthly; three-way not named | Held in PM trust account; account non-interest-bearing unless parties agree in writing. No interest rule found in Utah Code 57-17. | 3 calendar years after year PMA ends/transaction closes | Notify Division of PM trust account within 10 business days; records available for audit; report uncured imbalance within 30 days. | Utah Code 61-2f-102(32), 61-2f-201, 61-2f-202.5, 61-2f-309, 61-2f-411; R162-2f-403b; Utah Code 57-17 | 1 2 3 4 5 |
| Vermont | Vermont Real Estate Commission (Office of Professional Regulation, Secretary of State) | No for leasing: broker definition excludes leasing/offering to lease (26 V.S.A. 2211(b)(8)); Commission rule says offering property for lease needs no license. | Only for licensed brokers holding earnest money/contract deposits (26 V.S.A. 2214; Rule 4.7); no rule found for rents. | None found; three-way not named | No statewide separate-account or interest rule (9 V.S.A. 4461); municipalities may adopt ordinances allowing interest. | 7 years (brokerage firm records) | Notify Commission within 10 days of opening trust account; records open to inspection. Rule 5.3 audits cover continuing education only. | 26 V.S.A. 2211, 2214, 2296; VT Real Estate Commission Rules 4.7, 4.14, 5.3; 9 V.S.A. 4461 | 1 2 3 |
| Virginia | Virginia Real Estate Board (Dept. of Professional and Occupational Regulation) | Yes, broker license (leases/rents for others). Exempt: owners/lessors and regular employees; certain common-ownership management corps (54.1-2103). | Yes. Rent, security deposits, application deposits into escrow by 5th business banking day unless principals agree otherwise (54.1-2108.1(B)). | None found; three-way not named | Licensee escrows them; handled under VRLTA. No interest requirement found in 55.1-1226; written interest disclosure if interest-bearing. | 3 years (lease funds: from lease end/involvement end) | Mandatory firm audit by broker or third party within 90 days before firm license expires, on Board form (18VAC135-20-225). | Va. Code 54.1-2100, 54.1-2103, 54.1-2108.1; 18VAC135-20-181, -185, -225; Va. Code 55.1-1226 | 1 2 3 4 5 6 7 8 |
| Washington | Washington Dept. of Licensing (Real Estate Program) | Yes, broker license (leasing/renting for others). Exempt: owners and their employees; limited PM assistants (RCW 18.85.151(1),(13)). | Yes. Trust funds, including PM funds, in a trust account at a recognized Washington depository (RCW 18.85.285; WAC 308-124E-105). | Monthly; three-way not named | Landlord must hold in trust account at WA institution or licensed escrow; interest to landlord unless agreed; tell tenant depository (RCW 59.18.270). | 3 years minimum | None found beyond records open to Department inspection; reconciliations/trial balances must be retrievable on demand. | RCW 18.85.011, 18.85.151, 18.85.285, 18.85.311; WAC 308-124E-105; WAC 308-124C-110; RCW 59.18.270 | 1 2 3 4 |
| West Virginia | West Virginia Real Estate Commission | Yes, broker license (rents, manages, leases). Exempt: owners/lessors; owner’s regular employees with no extra pay (W. Va. Code 30-40-5(c)). | Yes. Brokers holding funds must ‘maintain and reconcile’ trust fund accounts, including security deposits and rental receipts (30-40-18). | Required, no frequency set; three-way not named | Must go into trust fund account; no interest unless rule allows (written agreement, no benefit to broker). No interest rule in 37-6A. | 5 years | Bank-executed trust account statement filed with Commission (30-40-18(i)); Commission may audit trust accounts (174CSR1 15.1). | W. Va. Code 30-40-3, -4, -5, -18; 174CSR1 10.3, 15.1, 15.4 (eff. Apr 7, 2026); W. Va. Code 37-6A | 1 2 3 4 |
| Wisconsin | Wisconsin Real Estate Examining Board (Dept. of Safety and Professional Services) | Yes, broker license (negotiating/promoting rentals for others). Exempt: owner’s/manager’s employees showing units, taking applications (Wis. Stat. 452.01(3)(e)). | Yes. Trust funds incl. rents and security deposits in real estate trust account; firm may deposit directly into owner’s account (REEB 18.031). | Monthly; three-way not named | Treated as trust funds; interest-bearing only with written authorization, none to firm. ATCP 134.06 sets no separate-account or interest rule. | 2 years | Within 10 days of opening, firm files authorization for DSPS to examine and audit trust account records (REEB 18.036). | Wis. Stat. 452.01(2),(3), 452.13, 452.42; Wis. Admin. Code REEB 15.04, 18.02, 18.031, 18.036, 18.13; ATCP 134.06 | 1 2 3 4 |
| Wyoming | Wyoming Real Estate Commission | Yes, license (rents, manages, leases, collects rent for others). Exempt: owners, immediate family, regular employees, resident managers (W.S. 33-28-103). | Yes. Wyoming trust/escrow account, with separate accounts by purpose (e.g., ‘property management trust’, ‘security deposit escrow’). | Monthly; three-way not named | Separate security deposit escrow account required by rule. Interest paid as parties agree. No statutory interest found (W.S. 1-21-1207/1208). | 2 years from latest participation date | Notify Commission of trust account/funds holder; Commission may examine trust accounting records (W.S. 33-28-122(a)(ii)-(iii)). | W.S. 33-28-102, 33-28-103, 33-28-122, 33-28-123; WY REC Rules ch. 5 §1 (018-5 Wyo. Code R. 5-1); W.S. 1-21-1207, -1208 | 1 2 3 |
The table is also available as a CSV, one row per state.
Findings
1. 25 states require a monthly reconciliation
Alaska, Arizona, Arkansas, California, Colorado, Florida, Georgia, Idaho, Illinois, Iowa, Kansas, Montana, Nevada, New Hampshire, New Mexico, North Carolina, North Dakota, Oregon, Rhode Island, South Carolina, South Dakota, Utah, Washington, Wisconsin and Wyoming require it at least monthly. New Jersey requires it at least quarterly, Nebraska after each bank statement, and West Virginia without a stated frequency. We found no reconciliation duty in the other 23 jurisdictions.
2. Only 3 states name a “three-way reconciliation”
Arizona (A.R.S. 32-2151(B)(3)), Colorado (Commission Rule 5.14.C) and New Mexico (16.61.23.12 NMAC) use the term. Many more describe the same three-way match, bank against journal against the sum of owner and tenant ledgers, without the label, including Alaska, Illinois, Iowa, Kansas, North Carolina, Oregon and Utah. For how the match works, see what a three-way reconciliation is and how to do one step by step.
3. Record retention runs from 2 to 8 years
Wisconsin and Wyoming require 2 years. 3 years is the most common period, in 25 jurisdictions. 3 states require 4 years, 11 require 5, 5 require 6, Connecticut and Vermont require 7, and Montana requires 8. We found no property-management retention period for Indiana or New York.
4. 47 of 51 jurisdictions require a license to manage rentals for others
Idaho and Vermont do not license rental management, and Kansas licenses commercial leasing but not residential. Maine’s statute defines brokerage around sales, so coverage of leasing is unclear. Utah adds a separate property manager license on January 1, 2027.
5. Annual filing is rare
Nevada is the only state we found that requires an annual trust account reconciliation filing. Iowa, Kansas and Nebraska use consent-to-audit forms, and most other states rely on inspections and audits on demand. If the bank and ledgers already disagree, start with why the trust bank balance does not match the owner ledgers.
What most states have in common
Three rules show up in nearly every row, whatever the reconciliation schedule.
Owner and tenant money stays out of the operating account. 48 of the 51 jurisdictions require licensed managers to hold rent, owner funds and broker-held deposits in a separate trust or escrow account at an insured bank, usually in the same state. Idaho, Maine and Vermont apply their trust rules to licensed brokers’ sales deposits and say nothing specific about rents.
Deposits have a deadline. Many states set how fast money must reach the trust account: three banking days in Arizona and Connecticut, three business days in California, five business days in Colorado. Late deposits are a common audit finding.
Each owner and tenant needs a ledger. Even states that set no reconciliation schedule require a record for each beneficiary, so a manager can show at any time what part of the bank balance belongs to whom. That ledger is the third number in a three-way reconciliation, which is why the match is good practice even where the rule does not name it.
A small commingling cushion is allowed in some states. Idaho, for example, caps the broker’s own money in the trust account at $300.
Before you rely on a row
Rules change, and a city or county can add security deposit rules on top of state law, as Chicago does. Read the cited section for your state before you change how you handle trust money. Propfina reconciles property management trust accounts monthly for firms that would rather not run the three-way match themselves.
Checked against the sources on November 3, 2026. This is not legal advice.
Frequently asked questions
Which states require a three-way reconciliation for property management trust accounts?
Only Arizona, Colorado and New Mexico use the words "three-way reconciliation" in statute or rule text, as checked November 3, 2026. All three require it monthly. Others, including Alaska, Illinois, Iowa, Kansas and Utah, require the same three-balance match without using the term.
How long must a property manager keep trust account records?
Between 2 and 8 years, depending on the state, as of November 3, 2026. Wisconsin and Wyoming require 2 years, 25 jurisdictions require 3, and Montana requires 8. We found no property-management retention period in Indiana or New York, where the stated rules cover sales files.
Do I need a real estate license to manage rentals for other people?
In most states, yes. 47 of the 51 jurisdictions require a broker or property manager license to manage rentals for others for pay. Idaho, Vermont and Kansas for residential leasing do not, and Maine's statute does not clearly cover leasing. Utah adds a separate property manager license on January 1, 2027.
Do security deposits have to be kept in a separate trust account?
It depends on the state and on who holds the deposit. When a licensed broker holds it, nearly every state treats it as trust money. Landlord-tenant laws add their own rules. Connecticut requires escrow and yearly interest, and Colorado's commission rules require a separate security deposit account.
Does any state require an annual trust account filing?
Nevada does. Brokers who hold trust money file an annual trust account reconciliation with the Real Estate Division by their license expiration date, or an annual declaration that they hold none. Most other states rely on inspections, random audits or a consent-to-audit form instead.