This update is to let you know what has happened, what we’ve done about it, and what comes next.

TDLR (Recent) History

August 28, 2025
TDLR emailed RASs announcing two forms:

• A revised Owner Agent Designation (OAD) form, and
• A new Limited Liability Ownership (LLO) form.

The message indicated the new OAD form would be required as of November 1, which suggested there would be time for:

• Training,
• Owner and designer education, and
• Stakeholder feedback.

September 7, 2025
Without advance notice, major programming changes were pushed into the Texas Architectural Barriers online System (TABS). These changes affected how projects could be registered and what documentation was required.

September 9, 2025
An email update was sent to RASs after the changes were already live. At that point, we learned that:

• • Any project owned by an LLC, PLLC, LP, LLP, or Ltd now must include:
    • The LLO form, and
    • Either the Texas Secretary of State record or Articles of Formation for the entity.
    • Existing projects where the entity “doesn’t have a representative on staff” also must submit an LLO and supporting documents; no definition was included for “representative on staff.”
    • Practically, projects owned by these entity types cannot be registered or advanced in TABS without this ownership documentation.

What APA Texas Chapter Has Done So Far

Over the last year, APA TXC has participated in several Zoom meetings and submitted multiple letters and comments to TDLR and the Elimination of Architectural Barriers (EAB) Advisory Board, including:

• Requests for advance review of new and revised forms before rollout.
• Requests for clear, published guidance on what documents are acceptable for ownership verification.
• Strong recommendation that ownership verification occur at the earliest stage—before issuing a TABS number—to avoid late-stage rejections.
• Questions about the “triggers” that cause TDLR to require additional documentation (email domains, care-of addresses, property management companies, etc.).
• A request for enforcement data to see whether this added paperwork has actually improved accessibility outcomes (fines, corrections, enforcement per month, etc.).

We also submitted:

• A public comment to the EAB Advisory Board, explaining how the new requirements have:
  • Increased RAS workload,
  • Created confusion and fear, and
  • Reduced time available for plan reviews and inspections.
• Presented comments during the public portion of the Advisory Board meeting, summarizing those concerns and asking for a review of EAB’s process.
• A formal request for a statewide training session, emphasizing that:
  • One-on-one conversations TDLR mentions in the staff report are not enough,
  • RASs are receiving inconsistent information, and
  • We need standard training available to all RASs.

Importantly: Our most recent letter to TDLR was never answered.

Texas Chapter Meeting & Ongoing Discussion

In October, APA TXC held a Texas Chapter meeting specifically to discuss the LLO/OAD rollout, the increased workload on RASs, and strategies for advocacy and communication with TDLR.

Remember that the APA online forum is always open for members to share questions, experiences, and suggestions. If you’re struggling with these new requirements or seeing patterns in how projects are being handled, the forum is a place to compare notes and support each other in real time.

New Letter to the New TDLR Director

Because there is now a new Director at TDLR, APA TXC has prepared a new, consolidated letter that:

• Brings the Director up to speed on:
  • Past requests,
  • The rollout of the LLO and OAD forms,
  • The shift in workload onto RASs, and
  • The lack of response to our previous correspondence.
• Reaffirms that:
  • RASs do not accept ownership verification as part of our role,
  • The current process has created significant inefficiencies and risk, and
  • The administrative burden is undermining our core mission: accessibility.
• Renews our specific requests (see below).
• Formally requests an in-person meeting with Steven Bruno, the Deputy Executive Director to discuss solutions.

What We’re Asking TDLR For (Again)

In the new letter, APA Texas Chapter has renewed and clarified these key requests:

1. Statewide, standardized training for all RASs
   • Covering the LLO and OAD forms, ownership verification expectations, acceptable documents, and triggers.
   • Conducted as an official session, and made publicly available.
2. Clear, comprehensive written guidance
   • Step-by-step instructions and examples of acceptable documentation.
   • Published guidance on verification triggers (e.g., email domain issues, care-of lines, property management owners).
3. Stakeholder review of forms prior to enforcement
   • Allow APA, APA TXC, and other stakeholders to review and comment on proposed form changes before they go live.
   • Revise the new forms to eliminate mistakes and confusion
4. Reassessment of the scope of the RAS role
   • A clear determination of whether shifting ownership verification to RASs is appropriate and within the intent of our licensure.
   • If it remains in place, adjust processes to reduce duplication and confusion.
5. Enforcement data and outcomes
   • Data showing whether the added ownership requirements have actually improved accessibility and enforcement, rather than just increased administrative work.
6. An in-person meeting
   • A request for the new Director to meet with APA TXC leadership and key program staff to discuss these issues and build a path forward.

Looking Ahead: January Conference Session with TDLR

We know that members want direct, live communication with TDLR. To support that, there will be at least one session at the January APA conference with Marsha Godeaux and TDLR staff specifically focused on these issues.

This will be an important opportunity to:

• Hear directly from TDLR about the intent and expectations of the new process,
• Ask questions in a public setting, and
• Provide feedback as a group.

More details about the session time and format will be shared as the conference schedule is finalized.

How You Can Help

We’ll continue to keep members updated as we receive information or responses from TDLR. In the meantime, you can:

• Share your experiences
  • If you have specific examples of delays, confusion, or issues caused by the LLO/OAD rollout and ownership requirements, please send them to the APA Texas Chapter leadership or post in the APA forum.
• Document your time and issues
  • Track how much time you are spending on ownership verification tasks and related emails. This data may help demonstrate the actual burden compared to the “11% inefficiency” cited by TDLR.
• Contact TDLR to share your concerns
• Participate in discussions and training
  • Join the APA forum conversations, attend Texas Chapter meetings, and plan to participate in the January conference session with TDLR.

If you have questions, comments, or want to get more involved in advocacy efforts, please reach out to the APA Texas Chapter leadership.

We’ll continue to push for a process that is fair, efficient, and focused on what matters most: accessible buildings and environments for Texans.