Depends on state law, I would imagine. That being said, even in Commiefornia, we managed to buy a rental house outright without either party having a realtor, or one piece of paper signed. Owner to owner executed. Original owner had no note, we weren't financing. So again, I would say, depends on the state and the finances involved. Of course we did a title search and some inspections, but generally the easiest and cleanest real estate transaction we've ever executed.