When Regulation Becomes Endorsement – How the CRB’s Firm Registration List Rewards Non-Reporter-Owned Corporations

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When the California Legislature passed Senate Bill 241 in 2021, the intent seemed straightforward: increase oversight of companies providing court-reporting services by requiring non-CSR-owned firms to register with the Court Reporters Board of California (CRB). It was billed as a transparency measure—an attempt to ensure consumer protection and accountability within a rapidly consolidating industry.

But in execution, that well-intentioned law has backfired. Instead of protecting independent, licensed shorthand reporters, the CRB’s implementation of the “firm registration” program has visibly elevated non-reporter-owned corporations above the very professionals the Board exists to protect.

The Legal Framework That Was Supposed to Protect Reporters

California law has long been clear: only licensed Certified Shorthand Reporters (CSRs), or corporations owned entirely by CSRs, may lawfully provide shorthand reporting services in this state.

Under the Moscone-Knox Professional Corporation Act and Business and Professions Code §§ 8020–8043, shorthand reporting corporations must:

  • Be owned and operated exclusively by licensed CSRs;
  • Identify at least one shareholder’s surname in the corporate name;
  • Include a professional designation such as “Shorthand Reporting Corporation”, “Certified Shorthand Reporter (C.S.R.)”, or “A Professional Corporation.”

These provisions serve a clear purpose: they ensure that the people controlling the company are the licensees, not venture capitalists, investors, or holding companies with no professional accountability to the courts.

A “shorthand reporting corporation” is a professional entity bound by both corporate law and professional ethics, answerable directly to the CRB. For decades, this framework preserved integrity in the production of official records.

Enter SB 241: Transparency or Trojan Horse?

In 2021, SB 241 introduced a new requirement: any firm not wholly owned by California-licensed CSRs—that is, any entity controlled by non-licensees but offering court-reporting services—must register with the CRB and designate a “Reporter-in-Charge” (a full-time California CSR).

The idea was to bring unlicensed intermediaries under limited CRB jurisdiction, allowing the Board to track and, if necessary, discipline them. The statute also required those firms to pay annual registration fees and to disclose ownership and contact information.

But here’s the irony:

  • CSR-owned professional corporations are not required to register, since they’re already governed by the Board through their licenses.
  • Non-CSR-owned conglomerates, however, must register—and once they do, they appear in a public, searchable list on the CRB’s official website.

This creates an optics problem of staggering proportions.

How the CRB’s Website Became a Marketing Platform for Unlicensed Corporations

Today, when attorneys or court administrators visit the CRB’s website looking for “registered firms,” they see names like Veritext, Magna Legal Services, and Planet Depos—massive multistate corporations often owned by private-equity groups or holding companies headquartered out of state.

By contrast, CSR-owned firms—those actually in full compliance with California’s professional corporation statutes—don’t appear anywhere on that list. Their invisibility makes them look less legitimate, even though they are the ones who actually meet the profession’s legal and ethical standards.

This is not a trivial matter of web design; it’s a regulatory imbalance with real-world consequences.

Attorneys browsing the CRB’s official “Registered Firms” page see it as a stamp of approval. They assume registration equals endorsement, or at least licensure. Many don’t read the fine print that quietly states:

“Registration does not constitute endorsement or approval of a firm by the CRB.”

The disclaimer is buried in a footnote. Meanwhile, the large, polished names of non-CSR-owned corporations are featured prominently—imbuing them with the legitimacy that true shorthand reporting corporations once carried under § 8043.

The Impact: Professional Corporations in the Shadows

For CSR-owned professional corporations, the message is clear: you can fully comply with state law, operate ethically, maintain all your licenses, and still appear nonexistent on the state’s own website.

Meanwhile, corporations owned by unlicensed investors—entities the Board was supposed to monitor, not promote—now enjoy a searchable listing, an implied endorsement, and direct access to potential clients browsing the CRB’s site for “registered” providers.

This creates a two-tiered system:

Firm TypeOwnershipCRB RegistrationPublic Visibility
CSR-Owned Shorthand Reporting Corporation100% licensed CSRsOptional❌ Hidden
Non-CSR-Owned FirmNon-licensee ownersMandatory✅ Publicly listed

In effect, the Board is rewarding non-compliance with visibility while penalizing lawful compliance with obscurity.

The Legislative Disconnect

Lawmakers intended SB 241 to enhance oversight—not to provide marketing exposure. But because the CRB’s list is public, searchable, and not clearly differentiated, it now functions as a de facto directory of non-licensee-owned corporations, giving them an edge in an already unbalanced market.

Even worse, it undermines the core tenet of the Moscone-Knox Act: that professional services must be controlled by those qualified and accountable for their outcomes.

This regulatory inversion means that the most compliant firms are the least visible, while the least compliant firms appear the most official—on a government website funded by the very licensees being sidelined.

CRB Oversight vs. CRB Endorsement

To the Board’s credit, the intent wasn’t favoritism—it was oversight. But in practice, oversight has morphed into inadvertent endorsement.

Every listing on the CRB’s registration page includes the firm’s name, location, and designated reporter-in-charge. There’s no label clarifying that these are “Non-Licensee Owned Firms.”
There’s no equal directory for CSR-owned corporations.
And there’s no disclaimer at the top of the list, only buried in small print below.

The result:

  • Attorneys assume those listed are “approved.”
  • Reporters who followed the law to the letter feel excluded.
  • Conglomerates gain a state-backed marketing advantage they could never have purchased outright.

What Needs to Change

To restore fairness and integrity, the CRB should immediately:

  1. Create two separate directories: one for licensed shorthand reporting corporations (CSR-owned) and another for registered non-licensee firms.
  2. Add visible labeling: each entry should clearly state whether the firm is “CSR-Owned” or “Non-Licensee Owned – Registration Only.”
  3. Include disclaimers at the top of the page, not in fine print.
  4. Encourage voluntary registration for CSR-owned firms to appear alongside the others with equal visibility.
  5. Reaffirm that registration ≠ licensure in all CRB communications, to prevent consumer confusion.

These changes would restore parity and transparency without undermining the Board’s oversight goals.

A Call to Action for Reporters

If you’re a California CSR or small agency owner, you can:

  • Submit a public comment to the CRB ahead of its October 17 meeting in Burbank, addressing this imbalance.
  • Cite Business and Professions Code §§ 8020–8043 and the Moscone-Knox Professional Corporation Act.
  • Request a dual-listing system that recognizes compliant shorthand reporting corporations equally alongside registered firms.
  • Contact the Department of Consumer Affairs (DCA) under Gov. Code § 11340.6 to request a regulatory clarification.

This isn’t just about visibility. It’s about the public’s trust in the neutrality, accuracy, and integrity of California’s official record.

If the CRB’s website continues to elevate unlicensed entities while hiding licensed professionals, then our state’s regulatory body has unintentionally become a marketing engine for the very corporations it was created to oversee.

It’s time to fix that.

StenoImperium
Court Reporting. Unfiltered. Unafraid.

Disclaimer

This article reflects my perspective and analysis as a court reporter and eyewitness. It is not legal advice, nor is it intended to substitute for the advice of an attorney.

This article includes analysis and commentary based on observed events, public records, and legal statutes.

The content of this post is intended for informational and discussion purposes only. All opinions expressed herein are those of the author and are based on publicly available information, industry standards, and good-faith concerns about nonprofit governance and professional ethics. No part of this article is intended to defame, accuse, or misrepresent any individual or organization. Readers are encouraged to verify facts independently and to engage constructively in dialogue about leadership, transparency, and accountability in the court reporting profession.

  • The content on this blog represents the personal opinions, observations, and commentary of the author. It is intended for editorial and journalistic purposes and is protected under the First Amendment of the United States Constitution.
  • Nothing here constitutes legal advice. Readers are encouraged to review the facts and form independent conclusions.

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Published by stenoimperium

We exist to facilitate the fortifying of the Stenography profession and ensure its survival for the next hundred years! As court reporters, we've handed the relationship role with our customers, or attorneys, over to the agencies and their sales reps.  This has done a lot of damage to our industry.  It has taken away our ability to have those relationships, the ability to be humanized and valued.  We've become a replaceable commodity. Merely saying we are the “Gold Standard” tells them that we’re the best, but there are alternatives.  Who we are though, is much, much more powerful than that!  We are the Responsible Charge.  “Responsible Charge” means responsibility for the direction, control, supervision, and possession of stenographic & transcription work, as the case may be, to assure that the work product has been critically examined and evaluated for compliance with appropriate professional standards by a licensee in the profession, and by sealing and signing the documents, the professional stenographer accepts responsibility for the stenographic or transcription work, respectively, represented by the documents and that applicable stenographic and professional standards have been met.  This designation exists in other professions, such as engineering, land surveying, public water works, landscape architects, land surveyors, fire preventionists, geologists, architects, and more.  In the case of professional engineers, the engineering association adopted a Responsible Charge position statement that says, “A professional engineer is only considered to be in responsible charge of an engineering work if the professional engineer makes independent professional decisions regarding the engineering work without requiring instruction or approval from another authority and maintains control over those decisions by the professional engineer’s physical presence at the location where the engineering work is performed or by electronic communication with the individual executing the engineering work.” If we were to adopt a Responsible Charge position statement for our industry, we could start with a draft that looks something like this: "A professional court reporter, or stenographer, is only considered to be in responsible charge of court reporting work if the professional court reporter makes independent professional decisions regarding the court reporting work without requiring instruction or approval from another authority and maintains control over those decisions by the professional court reporter’s physical presence at the location where the court reporting work is performed or by electronic communication with the individual executing the court reporting work.” Shared purpose The cornerstone of a strategic narrative is a shared purpose. This shared purpose is the outcome that you and your customer are working toward together. It’s more than a value proposition of what you deliver to them. Or a mission of what you do for the world. It’s the journey that you are on with them. By having a shared purpose, the relationship shifts from consumer to co-creator. In court reporting, our mission is “to bring justice to every litigant in the U.S.”  That purpose is shared by all involved in the litigation process – judges, attorneys, everyone.  Who we are is the Responsible Charge.  How we do that is by Protecting the Record.

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