Three weeks. That’s how long it took to process a new guard registration card through Tennessee’s Private Protective Services division before COVID-19 hit. The TDCI office in Nashville would receive the application, run the background check through TBI, and mail the card. Straightforward. Predictable.
Now it’s taking six to eight weeks. Sometimes longer. And for Memphis security companies trying to meet a surge in demand, that timeline is a serious problem.
What’s Happening at TDCI
The Tennessee Department of Commerce and Insurance, which oversees all private security licensing under T.C.A. 62-35, shifted most of its staff to remote work in mid-March. The Davy Crockett Tower in Nashville, where PPS applications are normally processed, cut back in-person services. Walk-in appointments disappeared. Phone lines went to voicemail more often than not.
The backlog started almost immediately.
TDCI still accepts applications by mail and through its online portal, and the agency has been clear that it’s processing them in the order received. Nobody is accusing the department of negligence. The staff is working. The problem is volume and infrastructure. State employees who normally handled physical paperwork in a shared office are now doing it from kitchen tables and spare bedrooms, passing documents through a system that was never designed for full remote operation.
Background checks are part of the bottleneck. The TBI processes criminal history checks for guard applicants, and that agency has its own COVID-related slowdowns. IdentoGO, which handles fingerprinting for the state, reduced its available appointment slots at collection sites across Tennessee. In Shelby County, the wait for a fingerprint appointment stretched past two weeks in June. That’s two weeks before the application even reaches Nashville.
For armed guard registrations, the delays stack up even more. Those applications require proof of firearms qualification from a TDCI-certified trainer, on top of the standard background check. Trainers who are behind on classes create another choke point in the pipeline.
The 48-Hour Training Problem
Every new security guard in Tennessee needs to complete a minimum training program before they can work. The state requires classroom instruction covering legal authority, report writing, emergency procedures, and use of force guidelines. For unarmed guards, the training runs about 16 hours. Armed guards need an additional 12 hours of firearms-specific training, including live-fire qualification.
Before the pandemic, training academies in Memphis ran classes weekly. Groups of 15 to 25 candidates would cycle through the material in a few days. The Memphis area had half a dozen approved training providers running on regular schedules.
COVID changed that math. Social distancing rules from the Shelby County Health Department capped indoor gatherings and forced training providers to cut class sizes. A room that held 20 students now holds eight or ten. Live-fire qualification at local ranges requires shared equipment that needs sanitizing between users. Some trainers paused operations entirely during April and May, and a few haven’t restarted.
The ones still running classes are booked out. I spoke with the owner of one Memphis-area training academy who said his July classes filled within 48 hours of being posted. He’s adding Saturday sessions to handle overflow. He told me he could fill three times as many seats if he had the space and the instructors.
That’s the catch. Demand for new guards is climbing. Training capacity dropped. And even when a candidate finishes the course, they’re still waiting weeks for the state to process their registration.
Why the Timing Is So Bad
Memphis security companies are fielding more requests right now than they have in years. The reasons aren’t hard to find.
Commercial properties that went dark during the shutdown need security. Restaurants and retail stores that reduced hours have empty buildings sitting vulnerable overnight. Construction sites, which kept operating as essential work, need guards while crews aren’t on site. Churches, event venues, office complexes, the usual clients are all adjusting their security needs as they figure out what reopening looks like.
Then there’s the new work. COVID screening stations at building entrances. Temperature check points at warehouses and distribution centers. Compliance monitoring to make sure employees and visitors follow mask requirements. This type of work barely existed six months ago. Now it’s generating contract requests across Shelby County and beyond.
Security firms in Memphis are telling me the same thing: they have contracts they can’t staff. The work is there. The licensed guards aren’t.
One operations manager at a mid-size Memphis firm put it this way: “I have four new accounts I should have started in June. Two of them are still waiting because I can’t get bodies through the licensing process fast enough.”
What Companies Are Doing About It
Some firms are getting creative. A few are pulling guards from lower-priority posts to cover new contracts, which means the clients they’re pulling from are getting thinner coverage. Others are running mandatory overtime for existing staff, which works in the short term and creates burnout in the long term.
Cross-training is another approach. Guards who are already registered and working unarmed posts are being pushed to complete armed qualification so they can fill higher-level assignments. That works if you can get them into a firearms class, which circles back to the training bottleneck.
A handful of larger companies with operations across multiple states are transferring guards from their Nashville or Knoxville offices to cover Memphis contracts temporarily. That’s expensive and unsustainable, and it only works for firms big enough to have that kind of bench depth.
The companies without those options are just waiting. Waiting for TDCI to clear applications. Waiting for training slots to open. Waiting for fingerprint appointments that keep getting pushed back.
The Bigger Worry
Here’s what concerns me. The licensing delays aren’t just an inconvenience for security companies. They’re a public safety issue.
When a property owner needs security coverage and the licensed providers can’t staff the contract, some of those property owners start looking at cheaper, unlicensed alternatives. I’ve heard from three different company owners in the past month who lost potential contracts to outfits operating without proper TDCI registration. One was a “security company” that turned out to be two guys with concealed carry permits and a pickup truck.
Tennessee law is clear on this. T.C.A. 62-35 requires any person performing security guard services to be registered with the state. The company employing them needs a contract security company license. Operating without one is a Class A misdemeanor. TDCI has enforcement authority, and they’ve used it in the past.
The question is whether enforcement resources are keeping up right now. TDCI’s investigative staff is dealing with the same remote-work constraints as everyone else. Complaints about unlicensed operators take time to investigate, and that time is stretching along with everything else.
This isn’t a Nashville problem or a rural Tennessee problem. It’s a Memphis problem. Shelby County has the highest concentration of security companies and registered guards in the state. When the licensing pipeline slows down here, the effects are immediate and visible. Properties go unguarded. Legitimate companies lose revenue. Unlicensed operators fill the gap.
What Needs to Happen
TDCI could help by temporarily expanding online processing capabilities and adding staff to the background check queue. Emergency provisional registrations, allowing new guards to work under supervision while their applications are pending, would take pressure off companies trying to fill contracts. Other states have done this. Georgia implemented a temporary registration extension earlier this year.
The training issue is harder to solve from Nashville. Local providers need help with facility costs so they can rent larger spaces for socially distanced classes. The state could also approve online delivery for the classroom portions of the training curriculum, reserving in-person requirements for firearms qualification and practical exercises.
None of this will happen overnight. In the meantime, Memphis security companies are stuck in a system that was already slow before a pandemic ground it to a halt.
The contracts are stacking up. The applications are sitting in a queue. And the gap between what Memphis needs and what the licensing system can deliver keeps getting wider.