Clear Cooperation Policy Explained for Real Estate Agents

Key Takeaway: The Clear Cooperation Policy requires MLS submission within one business day of public marketing. NAR later added the Multiple Listing Options for Sellers policy, which created a delayed marketing exemption alongside the original rule without replacing it. As of March 2026, Compass, Rocket, and Redfin challenged MLS enforcement in an open letter. Which MLS an agent works in determines whether and how this applies.

TL;DR About the Clear Cooperation Policy

• CCP requires MLS submission within one business day of public marketing.
• NAR adopted a delayed marketing exemption alongside the original rule.
• The exemption does not remove the one-business-day submission clock.
• Compass, Rocket, and Redfin challenged MLS enforcement in an open letter.
• Eleven MLSs were praised; seven were criticized in that letter.
• Signing brokerages pledged to defend affiliated agents from MLS fines.
• Verify current CCP rules with your MLS or broker directly.

The Clear Cooperation Policy is a National Association of Realtors rule requiring a listing broker to submit a property to the MLS within one business day of any public marketing of that listing. NAR has since adopted a companion policy that added a limited exemption alongside the original rule without replacing it.

A common misunderstanding is that NAR repealed the Clear Cooperation Policy or made MLS submission optional. Neither is accurate. The original one-business-day requirement remains in effect. What changed is the addition of a seller-consented exemption that allows a pre-market window before public marketing begins.

Agents evaluating listing strategy should understand that brokerage policy, MLS rules, and NAR policy operate as separate layers. A change at the NAR level does not automatically change what a local MLS requires.

The following sections explain what CCP is, what NAR changed and when, how office exclusives and Coming Soon listings work, what the Compass open letter said, which MLSs were named, and what agents should verify:

What the Clear Cooperation Policy Is

The Clear Cooperation Policy is a NAR rule that applies to agents working with MLS-member brokerages. It requires the listing broker to submit the property to the MLS within one business day of marketing the property to the public.

Public marketing includes yard signs, flyers in windows, digital marketing on public-facing websites, brokerage website displays, email blasts, multi-brokerage sharing networks, and applications available to the general public.

CCP was adopted by NAR in November 2019 and implemented by MLSs beginning May 1, 2020. The policy does not govern private, non-public seller communications. A seller may instruct an agent not to market a property publicly without triggering the submission requirement.

See the full NAR policy text here.

What NAR Changed: The Multiple Listing Options for Sellers Policy

In 2024, NAR adopted the Multiple Listing Options for Sellers policy as a companion to the Clear Cooperation Policy. This policy did not repeal CCP. It added a delayed marketing exemption that MLSs may offer to sellers who choose it.

The delayed marketing exemption allows a seller to request a pre-market window before public marketing begins. During this window, the listing may be shared within the brokerage or on certain platforms without triggering the one-business-day CCP submission clock. The exemption requires the seller to sign a disclosure confirming they understand the trade-offs of withholding the listing from the MLS during that period.

Once the seller consents to public marketing, the one-business-day CCP submission clock starts. The exemption does not extend the submission window after public marketing begins. It only allows a pre-market period before any public marketing occurs. Not all MLSs have implemented the delayed marketing exemption. Agents must verify whether their local MLS offers it and what conditions apply.

What an Office Exclusive Is and How It Differs from an MLS Listing

An office exclusive is a listing marketed only within a single brokerage and not submitted to the MLS. The seller directs that the property not be publicly marketed or shared through the MLS.

An MLS listing is submitted to the cooperative database and made available to all MLS participants. An office exclusive is visible only to agents within the listing brokerage.

The submission requirement is triggered when public marketing occurs. An office exclusive that involves any public marketing triggers the CCP one-business-day window. If no public marketing occurs, the listing may remain as an office exclusive without MLS submission. Sellers who choose office exclusives must sign a disclosure confirming that choice. MLS rules governing office exclusives vary by market.

What a Coming Soon Listing Is and How MLS Rules Apply

A Coming Soon listing is a property being marketed before it is available for showings and before it has reached active MLS status.

Whether a Coming Soon listing triggers CCP requirements depends on the MLS. Some MLSs have a formal Coming Soon status that satisfies CCP by sharing the listing data with all MLS participants. A Coming Soon listing entered into that MLS status complies with the policy. In other markets, a Coming Soon listing marketed publicly outside the MLS triggers the one-business-day submission window.

Local MLS rules on Coming Soon listings vary. What is permitted in one market may not be permitted in another. Agents must verify their specific MLS rules before marketing a property as Coming Soon.

What the Compass, Rocket, and Redfin Open Letter Said

In March 2026, Compass International Holdings, Rocket, and Redfin sent an open letter to MLS leaders arguing that CCP enforcement restricts seller choice and conflicts with agents’ fiduciary duty.

Fiduciary duty is the legal obligation of an agent to act in the best interest of their client. The letter argued that an agent who follows a seller’s informed marketing decision should not face MLS fines or discipline for doing so.

The letter pledged that the signing companies would defend their affiliated agents who face MLS fines or sanctions for following seller-directed marketing plans. It also publicly evaluated individual MLSs on their enforcement posture, listing some as praised and others as criticized. That evaluation is the signing companies’ own assessment, not a regulatory determination.

The Full List of Praised and Criticized MLSs

The March 2026 open letter evaluated individual MLSs on enforcement posture and placed each into one of two groups.

Eleven MLSs were praised for policies the signing companies described as supportive of seller choice: BAREIS MLS, Bright MLS, Canopy MLS, HAR, MLS Listings, MLSPIN, MRED, Realtracs, SFAR MLS, The MLS/CLAW, and Unlock MLS.

Seven MLSs were criticized for policies described as restrictive: ARMLS, CRMLS, FMLS, Georgia MLS, NWMLS, OneKey MLS, and StellarMLS.

These designations reflect the signing brokerages’ assessment only. They are not a regulatory or legal determination. Agents working in any of these markets should verify current local MLS rules directly with their MLS or broker.

See the Bright MLS research on office exclusives here.

The Counterargument: Who Actually Benefits from Less Enforcement

The case for reduced CCP enforcement is framed as seller choice and fiduciary obligation. The letter’s position is that sellers should direct how their property is marketed without agents facing MLS discipline.

The counterargument identifies a different set of interests. Less enforcement benefits large brokerages with established internal buyer networks, which can match buyers to listings before the MLS receives them. Buyer agents at smaller brokerages cannot show clients listings withheld from the MLS. Buyers using the MLS for a full inventory view do not see listings held in office exclusive or pre-market status.

Bright MLS research from April 2025 found no price advantage for sellers who used office exclusives, and found they took longer to sell.

Why Agents Are Hearing Conflicting Information About MLS Rules Right Now

Three misunderstandings are common in how agents interpret the current dispute.

The first is that the open letter changed MLS rules. It did not. The letter is a public statement and legal pledge. MLS rules remain in effect unless a specific MLS has formally amended them.

The second is that CCP has been repealed. It has not. The Multiple Listing Options for Sellers companion policy added a delayed marketing exemption that operates alongside CCP, not in place of it.

The third is that all MLSs are now non-enforcing. Some MLSs have adjusted their policies. Others have not. An agent cannot assume their MLS changed its rules because a different MLS in a different market did.

What Agents Also Ask About the Clear Cooperation Policy

What exactly did NAR change about the Clear Cooperation Policy?

NAR adopted the Multiple Listing Options for Sellers policy, which added a delayed marketing exemption alongside the original CCP. The exemption allows a pre-market window before public marketing begins, with seller consent and a signed disclosure. The one-business-day submission clock still starts once public marketing occurs. CCP itself was not repealed or replaced.

Does the delayed marketing exemption apply in every MLS?

The delayed marketing exemption is available only in MLSs that have implemented it. NAR adopted the framework, but local MLSs control whether they offer it and under what conditions. An agent cannot assume the exemption is available in their market without confirming with their MLS directly.

What is the difference between a Coming Soon listing and an office exclusive?

A Coming Soon listing is pre-market but intended for eventual MLS submission at active status. An office exclusive is kept within one brokerage and never submitted to the MLS. Public marketing of either type may trigger CCP submission requirements depending on the local MLS. Agents must verify local rules before using either listing type.

What does the Compass open letter mean for agents who are not at Compass?

The letter commits Compass, Rocket, and Redfin to defend their affiliated agents from MLS fines for following seller-directed marketing plans. Agents at other brokerages are not covered by that pledge. They remain subject to their brokerage policies and local MLS rules. Agents at non-signing brokerages should confirm their local MLS rules and their brokerage’s position independently.

Why This Matters Before You Join eXp Realty

The Clear Cooperation Policy has not been repealed. The Multiple Listing Options for Sellers policy added a limited exemption alongside it, not in place of it. CCP enforcement is determined at the MLS level. Whether the delayed marketing exemption is available depends on which MLS an agent works in.

At eXp Realty, all agents receive the same core brokerage platform, including compliance, compensation, and access to company divisions. What differs is the sponsor ecosystem an agent aligns with. The sponsor an agent selects shapes which tools, training, and attraction systems they have access to, including how listing compliance frameworks are addressed within that ecosystem. Understanding the current CCP structure helps agents evaluate listing decisions without relying on inaccurate headlines.