Q: Now that we have obtained our Seller of Travel licenses from California, Florida, Washington state, Iowa and Hawaii, what should we do with them? How should we display the licenses on our website? Do we have to put the license numbers in email confirmations? Do our independent contractors (ICs) need to use the numbers? Is there an actual paper license that we need to hang up in the office, like a local business license?
A: Each state's requirements are different, but they are all easy to comply with.
California requires that the number be "clearly and conspicuously displayed on all advertising materials offering for sale or soliciting the purchase of any air or sea transportation or travel services, including but not limited to any writings or promotional materials of any kind which are advertised, displayed or disseminated in any manner to any persons in California or from California to any person elsewhere." California also requires that, if you use the words "Seller of Travel" along with the number, you add, "Registration as a Seller of Travel does not constitute approval by the state of California."
You probably want to avoid having to post the sentence about nonapproval by California.
So put the number on your website's homepage and advertising, but don't use the word California before the number. Instead, as many agencies do, display it as "CST No. X."
California also requires that, if you are required to have a surety bond or trust account, your contracts must contain a "clear and conspicuous disclosure" stating: "California law requires certain Sellers of Travel to have a trust account or bond. This business has [a trust account] or [a bond issued by (company) in the amount of $X]."
Fill in the blanks and add it to your website's terms and conditions and email confirmations.
Florida requires that "each advertisement of a Seller of Travel must include the phrase "Fla. Seller of Travel Reg. No. X." In addition, "Each contract of a Seller of Travel must include the phrase "(Name of firm) is registered with the state of Florida as a Seller of Travel. Registration No. X."
So put "Fla. Seller of Travel Reg. No. X" on your homepage and in advertisements. In your website terms and conditions, email confirmations and anything else that could be called an ad or contract, add the last sentence quoted above.
Washington state requires that sellers include the registration number in "all advertisements" but not in "institutional advertising." The latter is defined as advertising that does not include prices or dates. There is no particular wording required.
Hawaii and Iowa do not require any display of the registration number.
Independent contractors who are exempt from registration under the various state laws do not have to display their host's registration number. If an IC does not meet the criteria for exemption, then the IC needs his, her or its own Seller of Travel registrations, in which case the foregoing rules and advice apply.
California and Florida issue paper certificates that you can hang on the wall, but only Florida requires that you do so.