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 referrals 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, qualification scoring) before outreach. Partners typically 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 different completeness, different freshness, and different research cost. Partners typically combine two or three rather than relying on any single source.
County recorder memorandums of lease
Many commercial leases are recorded with the county as a memorandum of lease. The memorandum is a short legal document, typically one to three pages, that puts the public on notice that a lease exists between the named parties for the named property. It does not include the financial terms, but it includes everything a partner needs for prospecting: tenant identity, landlord identity, property identity, and sometimes term length.
Recording is voluntary in most states. Sophisticated tenants record memorandums to protect their leasehold interest in the event of landlord default or property sale. Less sophisticated tenants do not record. This means the recorder data is biased toward larger, better-counseled tenants, which is exactly the prospecting profile partners usually want.
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.
For prospecting, the value is in identifying which public companies have meaningful retail, office, or industrial footprints and where those footprints are concentrated. A public retail chain with 800 locations is a single account that could produce a portfolio engagement covering hundreds of properties at once. The procurement decision-maker for that account is usually the head of real estate or the CFO, who is identifiable through LinkedIn or through the executive officers section of the same 10-K.
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.
The franchise vertical is one of the strongest CAM audit targets because franchisees typically operate at multi-tenant properties, sign similar lease structures across locations, and have CAM exposure that scales with location count.
Business license filings as a freshness signal
Most municipalities require a business license for commercial occupancy. The license filing names the business, the address, and often the start date. Pulling new business licenses on a quarterly cadence gives partners a fresh list of tenants who have just signed leases and are within the first 12 to 24 months of occupancy.
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.
Business license data is typically available through the city or county clerk office. Larger cities have open data portals. Smaller jurisdictions require manual records requests. The freshness premium is real: a tenant within 18 months of lease signing has stronger audit ROI than a tenant 5 years in, because the early reconciliation periods are still fully within most dispute windows.
CRE permit data for confirmation
County and city building permit data shows tenant improvement permits, build-out permits, and signage permits. Each is a marker that a new tenant is occupying space. Permit data is rarely the primary source because the applicant is often the contractor rather than the tenant, but it is excellent for confirming that a tenant identified through another source is actually occupying.
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.
First, define the target market geographically. Most partners start with a single metro area or county. Statewide is too broad for an initial list and national is impossible without paid databases.
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, Apollo, 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 partner program that supports outbound prospecting, including wholesale pricing and portal access, see the CAMAudit white-label partner program.