According to Jan Holle, Chief Compliance/Audit Investigator for the Nevada Real Estate Division, “Yes. Every broker has to fill out either Form 546 or 546A. Technically, neither form has anything to do with property management or whether a broker has a permit or not. Which form to submit has everything to do with whether a broker is handling monies. Some brokers do property management and never handle any money. Therefore, that property manager would complete Form 546A. Some brokers handle client monies that are not rents or security deposits. That broker would be required to have a trust account and submit Form 546 every year.
The confusion for many brokers is that they assume that both forms are related to property management only. That would be a false assumption. Again, which form the broker is required to complete and submit every year is determined by whether or not the broker has handled any client monies during the past year.
I wrote an article on this subject for the last Open House Newsletter of 2018.
[see: September/October/November 2018 Open House Newsletter]