Cold-list sourcing for CAM audit partners: public lease records, SEC filings, and franchise FDDs
Most white-label CAM audit partners I talk to are stuck on inbound. They wait for introductions from their CPA or attorney network, they wait for organic traffic from their hub page, and they wait for warm introductions from existing clients. The wait works at low volume but it does not scale. The partners who scale the practice past a single advisor are the ones who learn to build cold prospect lists from public sources and run structured outbound to the right tenants.
I built CAMAudit because the audit market was bottlenecked by tenant awareness. After running detection engine analysis against published reconciliation samples and seeing the consistency of finding patterns across tenant types, I have a working view of which tenant profiles produce the strongest engagements. This article translates that into the public-record sources partners use to find those tenants directly, plus the practical mechanics of building a usable list from raw data.
Cold list: A prospecting list of named tenants identified through public records or third-party data sources, where the tenant has had no prior contact with the partner. Cold lists are the foundation of outbound prospecting and require enrichment (contact lookup, fit check scoring) before outreach. Partners sometimes maintain cold lists separately from warm lists (referrals, inbound inquiries, networking contacts).
The five public sources for tenant identity
Five public sources, in rough order of usefulness for partners building from scratch.
| Source | What it shows | Cost | Best for |
|---|---|---|---|
| County recorder memorandums of lease | Tenant name, landlord name, property, sometimes term | Free, manual | Local market prospecting |
| SEC 10-K filings | Multi-location tenant property portfolios | Free (EDGAR) | Public-company multi-unit targets |
| Franchise FDD filings | Franchisee names and locations | Free or low cost (state registries) | Franchise vertical prospecting |
| Business license filings | Newly-signed tenant identity | Free, manual | New-tenant outreach |
| CRE permit data | Build-out and tenant improvement signals | Free or low cost | Confirmation and timing |
Each source has its own date, gaps, and cost. Check a lead in more than one source when you can.
County recorder memorandums of lease
A county may record a short lease notice. It may name the parties and site. Check it before using any fact.
Rules differ by state. A missing record does not prove there is no lease. County data is only one lead source.
Search the recorder index for memorandums of lease (sometimes labeled MOL or memorandum of lease agreement) filed in the past 24 to 36 months on commercial properties in the target area. Cross-reference with the property address to confirm commercial use rather than residential.
The data quality varies by county. Larger urban counties have searchable online indexes and digitized images. Smaller counties require in-person research at the recorder office. Partners targeting urban markets get further on this source than partners in rural markets.
SEC 10-K real estate disclosures
Public companies are required to disclose material lease commitments in their annual 10-K filing. The disclosures appear in two places: the Properties section (Item 2 of the 10-K) and the Operating Leases note in the financial statements.
The Properties section gives a portfolio overview, sometimes with property-by-property detail. The Operating Leases note gives the aggregate rental commitments by year for the next five years and after.
Use a 10-K to find listed sites. Check the company site for current roles. A job title alone does not prove the buyer.
EDGAR search at sec.gov is free. Search by SIC code (industry classification) to find all public companies in retail (5331, 5411, 5812, etc.), restaurants, healthcare, or other target verticals. Then pull the most recent 10-K and read the Properties and Operating Leases sections.
Franchise disclosure documents (FDDs)
Franchise FDDs are federally regulated pre-sale documents that franchisors provide to prospective franchisees. They contain 23 standardized disclosure items. For prospecting, the relevant items are item 20 (current and former franchisees) and item 12 (territory).
Item 20 disclosures list every current franchisee with the franchisee company name and the location address. For a 200-unit franchise system, that is a 200-row list of named multi-unit tenants. The list is updated annually with each FDD revision.
State FDD registries vary. California, Minnesota, Wisconsin, and several other states maintain searchable FDD databases at the state level. Federal FDDs are required but there is no central federal database. Partners targeting franchise verticals build a workflow around the state databases plus direct franchisor outreach for the FDDs not registered in those states.
Some franchise groups lease more than one site. Check each site and lease on its own. Do not assume the same CAM terms apply across all sites.
Business license filings as a freshness signal
Some cities post license records. Check the date and source. Do not infer a lease date from the license.
This is the timing window where CAM questions are most acute. The tenant has just received their first reconciliation statement, has questions about what they are paying, and has not yet been auditing. They are ideal cold outreach targets.
CRE permit data for confirmation
A permit may help check a site address. It may name the builder. Match it with another public source.
Cross-referencing permit data with business license data and recorder memorandums produces a high-confidence identification of new tenants in the target market. A property with a recent tenant improvement permit, a recent business license filing, and a recorded memorandum of lease is almost certainly a real, recently-signed tenant who is in the prospect window.
Building the list workflow
The mechanical workflow that turns these sources into a prospect list looks roughly like this.
Choose a small target area. A city or county is easier to check. Add areas after the process works.
Second, pick a target vertical. Multi-tenant retail, multi-tenant office, healthcare, franchise, or industrial. Each vertical has different source weights. Franchise prospects are best sourced from FDDs. Public retail prospects are best from 10-K plus business license cross-reference. Local independent businesses are best from county recorder plus business license.
Third, pull the raw data from the relevant sources. Expect 200 to 500 raw records per quarter for a single metro area in a single vertical.
Fourth, enrich the contact data. The public sources name the company but rarely the contact person. Use LinkedIn, ZoomInfo, or similar services to find the CFO, controller, or real estate manager at each named company.
Fifth, score against the ICP scorecard. Annual CAM exposure, lease type, remaining term, and reconciliation history are the variables that predict engagement ROI. Most prospects on the raw list will not pass scoring. Discard the misses and focus the outreach on the green prospects.
The ratio of raw records to qualified prospects to engaged clients is roughly 100 to 15 to 2 in a well-run outbound process. Partners who plan around those ratios scale predictably. Partners who expect 1-to-1 conversion get demoralized fast.
Compliance notes
Public records are public, but how partners use them matters. Cold outreach to a named tenant identified through county recorder data is normal business prospecting and is legal in every state. State-specific rules apply for certain professional categories. Attorneys have UPL and solicitation rules at the state bar level. CPAs have AICPA solicitation rules. Tenant rep brokers have state brokerage licensing rules. Each professional category should consult its own ethics rules before designing the outreach mechanics.
Do not misrepresent how the data was obtained. "I saw your lease memorandum on the recorder index" is fine. "We have a tip from a landlord" is not. Honesty about sourcing protects the relationship and stays inside any reasonable interpretation of professional ethics rules.
For an overview of the white-label CAM audit service that supports outbound prospecting, see the CAMAudit white-label CAM audit service. Audit pack details are reviewed on the public pricing page.