Most states do not require the use of broker-dealers. Some do, and others have criteria to avoid issuers/agents registration.
With Alabama, Arizona, New York, Texas, Nevada, North Dakota, New Jersey, and Nebraska, issuers/agents need to use a broker-dealers.
Florida, and Washington have some criteria. If not met, a broker-dealer would be necessary to avoid Issuer/agent registration.
We see most issuers engage a broker-dealer to assist with compliance in all States as a practical matter.