No, you can already report a change of ownership even though it is not yet reflected in the records of the relevant trademark office. You should however provide us with the template transfer/assignee declaration available on the website of the Clearinghouse in order to evidence the change in ownership and select “assignee” as the status of the trademark holder.
Is it correct that an ownership change should not be deposited until after that change is reflected in the record of the relevant trademark office?
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