Limits on what an unlicensed property manager can do?

[Jade Smith]

We are a small vacation rental company that manages short-term rentals for homeowners in Los Angeles. We manage ONLY transient occupancies - i.e short term stays under 30 days, for which no brokers license is required. (In California - to property manage rentals above 30 days, we would need to have a brokers license)

We have gotten some requests from guests for stays above 30 days (usually 2-3 months). Instead of denying them, can we refer them directly over to the owner for them to sign a lease with the owner who is willing to effectively manage the contract, payment and relationship BUT would still want to retain us (albeit for a lower fee) to deliver ONLY guest and property care activities (guest communications, organizing cleaning, lawn and pool care etc). 

Would this be permitted if we are unlicensed? Essentially it would be supporting the owner to manage their property, and steering clear of any activities that we see as being clearly licensed activities - negotiating, taking payments etc. 

Thanks in advance to anyone willing to help me think this one out!

Also, would love suggestions for how we could partner with a licensed broker to accommodate these MTR requests.  For example, could we partner with a licensed broker who could handle the negotiation and money and we handle all the things related to guest and property care? Would he/she need to “employ” us, so to speak? 

(For context, we are in the luxury market and the guests are very demanding - they want lots of communication, concierge etc.. and maintenance, lawn care, gardening etc is time consuming.. so there’s a big job beyond just brokering and managing managing funds)

[Michael Smythe]

@Jade Smith under your proposal, you would probably need an agent license to work with a broker.

Hopefully, you have a copy of the regulations that allow your interpretation of California licensing requirements and didn't depend on someone's opinion:)