Yes, but since January 4, 2025 wholesaling is licensed real estate activity in Pennsylvania. Anyone who markets or assigns a contract to buy a 1 to 4 unit Pennsylvania home for a fee, without taking title first, needs a real estate license (63 P.S. 455.201). Sellers can cancel a wholesale contract until midnight of the 30th day after signing or until the deed transfers, whichever comes first (63 P.S. 455.610). If the required disclosures are missing, they can cancel any time before the deed transfers.
Act 52 of 2024 (Senate Bill 1173) was signed July 8, 2024 and took effect 180 days later, on January 4, 2025. It amended the Real Estate Licensing and Registration Act, or RELRA.
A wholesale transaction is "undertaking to promote the sale, exchange or purchase of an equitable interest or other interest in residential property with the intent to assign, sell or otherwise transfer the interest for a fee, commission or other valuable monetary consideration without having taken title as the owner of record of the interest" (63 P.S. 455.201). Residential property means one to four dwelling units in Pennsylvania.
RELRA does not define equitable interest. The Commission's regulatory counsel described the typical deal at a November 3, 2025 meeting. A wholesaler signs a purchase agreement with the owner, then sells that agreement to another buyer for a profit without taking title.
Wholesaling "whether for the person or for another" is now broker activity, and a salesperson may do it only for their employing broker (63 P.S. 455.201). The owner exclusion "shall not apply to a wholesale transaction" (63 P.S. 455.304). Doing or advertising this work without a license is unlawful (63 P.S. 455.301).
Every wholesale sales agreement must prominently state four things (63 P.S. 455.610(e)). (1) It is a wholesale transaction, and the licensee intends to assign or sell the interest for a fee without taking title. (2) The consumer may get an appraisal from a Pennsylvania certified appraiser, consult a licensee outside the wholesaler's brokerage, or see a lawyer, before or after signing. (3) The consumer may cancel within the 30 day window described below. (4) All payments the consumer made will be refunded within ten business days after a cancellation notice is received.
The statute lists the content but prescribes no exact wording. The Commission must set the manner and method by regulation, and that rule (16A-5629) was still in development at its August 4, 2026 meeting. Because the statements belong in the agreement, the seller sees them at signing.
Act 52 creates no separate form for the end buyer. Its protections cover "a consumer who is party to a wholesale transaction," a phrase the statute does not limit to sellers (63 P.S. 455.610(a)).
Philadelphia also requires a city wholesaler license, and the city's disclosure form says Philadelphia Code 9-5205 requires a signed homeowner disclosure at least three days before an offer.
You can cancel until midnight of the 30th day after you signed, or until conveyance, whichever comes first. If any required statement is missing, you can cancel any time before conveyance. The right "shall not be waivable" (63 P.S. 455.610(a)).
Send notice by certified mail with return receipt, or by email, hand delivery or another bona fide method that gives you a receipt. It takes effect on the postmark, transmission or deposit date (63 P.S. 455.610(b)).
Within ten business days after the notice is received, all payments of any kind you made must be refunded, and the broker or salesperson must confirm in writing that the agreement is void. You keep any promotional gifts and owe no damages (63 P.S. 455.610(c), (d)). The statute does not address a deposit the wholesaler paid.
The Commission can suspend or revoke a license and fine up to $1,000 for misrepresentation, missing disclosures, bad faith and other violations (63 P.S. 455.604(a)). It can also impose civil penalties up to $10,000 per violation on licensees or unlicensed people who violate RELRA (63 Pa.C.S. 3108(b)(4)).
Unlicensed practice is a summary offense the first time, with a fine up to $500, up to three months in jail, or both. A repeat offense is a third degree felony carrying a $2,000 to $5,000 fine, one to two years in prison, or both (63 P.S. 455.303). An unlicensed person cannot sue in Pennsylvania to collect pay for licensed work (63 P.S. 455.302).
Homeowners can file a complaint through PALS. If you win a final court judgment against a licensee for fraud, misrepresentation or deceit and cannot collect, the Real Estate Recovery Fund may pay up to $20,000 per claim (63 P.S. 455.803).
Get licensed. Salespersons need 75 hours of instruction, a passed exam and a broker's sworn promise to supervise and train them (63 P.S. 455.521, 455.522). Brokers need 240 hours, three years as a salesperson or the equivalent, and the broker exam (63 P.S. 455.511).
Get paid through your broker. A salesperson may accept pay for licensed work only from the employing broker (63 P.S. 455.604(a)(12)). Commission prosecutors discussed how that applies to assignment fees in November 2025, and no rule has been adopted.
Market under the brokerage. Salesperson ads must show the employing broker's business name and phone number in equal size (49 Pa. Code 35.305).
Check your deal structure. The statute does not say directly whether a double close falls outside the definition, so get a Pennsylvania real estate lawyer's opinion first.
As of October 29, 2026, no later act has changed the wholesale provisions. Regulation 16A-5629 remained open in the Commission's August 4, 2026 minutes, and its counsel said in May 2026 that most of the statute is self-effectuating, meaning it applies without a rule. Members agreed in November 2025 that wholesaling needs its own consumer notice, which does not exist yet. No wholesale rule appears on the IRRC list of Commission regulations.
House Bill 600 would create a separate state wholesaler license with a three day disclosure and a do-not-solicit list. It has sat in the House Professional Licensure Committee since February 12, 2025.
In August 2025 Commission counsel said Philadelphia's license conflicts with state law when issued to people the Commission has not licensed.
This is information, not legal advice.
Read the agreement. A Pennsylvania wholesale contract must prominently say the buyer intends to assign or sell it for a fee without taking title (63 P.S. 455.610(e)). Ask whether the buyer will close with its own money and take the deed in its own name. Then look up the person and the company on PALS. If they plan to assign and hold no license, you can report them to the State Real Estate Commission.
Act fast and in writing. You can cancel until midnight of the 30th day after signing, or until closing, whichever comes first, and any time before closing if the required statements are missing. Use certified mail with return receipt, or email or hand delivery with a receipt. Any money you paid must come back within ten business days after your notice is received, with written confirmation that the contract is void. You owe no damages (63 P.S. 455.610).
No. Buying and closing in your own name is not a wholesale transaction. The license rule attaches when you market or assign the contract for a fee before taking title, and doing that through an LLC changes nothing. The broker definition covers anyone who wholesales "whether for the person or for another" (63 P.S. 455.201), and the owner exclusion does not apply (63 P.S. 455.304). In November 2025, the Commission's senior prosecutor said an LLC can sign a purchase contract but cannot promote the sale without a license. Unlicensed wholesaling risks civil penalties up to $10,000 per violation and criminal charges (63 Pa.C.S. 3108, 63 P.S. 455.303).
Act 52 leaves assignments legal for licensees and sets the rules. A licensed broker, or a salesperson working for one, may assign a contract on a 1 to 4 unit Pennsylvania home when the agreement carries the four required statements and the seller's cancellation right is honored (63 P.S. 455.201, 455.610). The Commission is still drafting a rule on how those statements must be presented, so have a Pennsylvania real estate lawyer review your contracts.
Pennsylvania is one of 51 jurisdictions in our state-by-state wholesaling law table, which covers licensing, seller disclosures, and cancellation windows everywhere in the U.S. If you already have a cash offer, here is how to compare cash offers line by line.