The QI File

Qualified Intermediary

Atlas 1031

Atlas 1031 Exchange, LLC · Parent: Independent / unpublished · Firm website

FEA membership
FEA member
CES® holders
Andrew Gustafson, CES®
Fidelity bond
Not published on cited pages
E&O / other cover
$250,000 errors and omissions policy (as stated on the October 23, 2018 Four Questions PDF — request a current certificate)
How funds are held
Segregated
Dual-signature wires
Dual-signature
Reverse / improvement / DST
Reverse Yes · Improvement Unknown · DST Unknown
Last sourced
2026-09-06

Other published coverage

Firm states it uses a qualified escrow agreement rather than maintain a fidelity bond (2018 Four Questions PDF).

Fund handling

Non-commingled proceeds plus a Qualified Escrow Account. The 2018 PDF says Atlas uses qualified escrow accounts requiring dual signatures in non-commingled accounts, with Axos Bank in San Diego named as the bank on that PDF. The qualified-escrow page describes a written exchangor authorization, QI submission to the bank, and a bank callback to the QI before the wire.

Fee structure

Fees described as competitive and based on complexity and type of exchange (2018 PDF). No public fee card.

Who it is for

Individuals, trusts, and businesses doing forward and reverse 1031 exchanges of real property held for business or investment, including foreign and domestic files. Atlas 1031 Exchange, LLC was established in 2007; Andy Gustafson’s published QI work dates to 2003 via a prior Florida entity.

Verdict

A CES-led boutique that publishes the stronger custody story — qualified escrow with dual signatures and non-commingled accounts — instead of a fidelity-bond number. The $250,000 E&O figure and Axos Bank name sit on a 2018 PDF; treat them as dated disclosures and ask for a current certificate and today’s bank. Reverse is published on the About page. Improvement and DST were not marketed as QI products on the pages cited here. Tom Gustafson’s FEA Membership Committee seat is personal, not a second company-membership source.

Notes

This is a QI custody file, not a securities offering. Atlas 1031 Exchange, LLC is the legal name on the About page. Andrew (Andy) Gustafson is president, founder, and managing member, and is named as a Certified Exchange Specialist® (CES®) since 2006. The About page says he co-founded Old South 1031 Exchange Services, LLC in Destin, Florida, in 2003 and established Atlas 1031 Exchange, LLC in 2007. The homepage’s “since 2003” line is that longer QI history, not a 2003 formation date for the Atlas LLC.

The About page is also the reverse-exchange source (“forward and reverse”) and the “over 3,000” exchange count — the firm’s own figure. The 2018 PDF still says “over 1,400”; the later About number is not independently audited here.

The October 23, 2018 Four Questions PDF is the FEA-membership source and the custody-structure source: Atlas is an FEA member, uses a qualified escrow agreement rather than maintain a fidelity bond, uses qualified escrow accounts requiring dual signatures in non-commingled accounts, and then-stated a $250,000 E&O policy. Fidelity is omitted because the firm’s own PDF says it does not maintain a bond. E&O is printed only as that dated disclosure.

Tom Gustafson is listed as a manager and as having joined the FEA Membership Committee. That is not treated as a named CES® holder and is not a substitute for the company FEA line on the PDF.

Who keeps interest on the escrow is not stated on the cited pages. Improvement and DST products are not published there.

Sources

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Corrections and verification

Listings are sourced from public pages. Unknown is omitted, not graded. If a fact is wrong or stale, send the primary URL.

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