Guides
Read the file before you wire funds
These pages exist so you can ask a QI the same questions a careful closer would ask — and so you can tell a marketing claim from a custody fact. They are editorial. They are not tax, legal, or investment advice. Statutes and firm disclosures change; check the primary source and the date on each citation.
Primary explainer
How to choose a QI
No federal license. Titling, segregation, who can wire, disclosed insurance, FEA vs charter, CES, reverse/improvement/DST as questions, and who keeps float interest.
Custody
Who holds the money
QI, bank depository, qualified escrow/trust, and title closing escrow. Constructive receipt is not an owner name.
Roles
QI vs title company
Two jobs at the same table. Disqualified-person rules and the routine title/escrow exception in Treas. Reg. §1.1031(k)-1(k).
Printable
QI due-diligence checklist
Ten HTML boxes: entity, title, segregation, wires, certificates, state statute, FEA vs CES, reverse/EAT, float, independent bank verify.
Interview
Questions to ask a QI
Spoken versions of the same ten asks — sentences to send before you sign, not a ranking.
Process flags
QI red flags
How a firm answers: fuzzy legal entity, brochure insurance, parent-logo custody, FEA-as-license. Unknown is not a flag.
Failure modes
If a QI fails
Constructive receipt is not a bailout. LandAmerica / Millard on QI-controlled “segregated” cash. Bonds are claims.
Treasury definitions
Qualified escrow vs qualified trust
Treas. Reg. §1.1031(k)-1(g)(3) in the regulation’s words. Parallel safe harbors — not a ranking of wrappers.
Deadlines
1031 timeline (45 / 180)
IRC §1031(a)(3): 45-day identification; exchange period is 180 days or the return due date including extensions, whichever is earlier.
Identification
3-property / 200% / 95%
Treas. Reg. §1.1031(k)-1(c): written, signed, sent. Incidental property and revocation.
Recognition
Boot in a 1031
§1031(b)–(d): money and other property, liability relief as money received. Not an invented typical percentage.
Related parties
Related-party rules
§1031(f) two-year disposition, §267(b)/§707(b)(1) related persons, (f)(4) anti-avoidance.
Partnerships
Drop and swap
Partnership interests are not like-kind real property. Bolker and Magneson are fact-specific. Not a playbook.
Exchange types
Forward vs reverse vs improvement
Definitions from IRC §1031, Treas. Reg. §1.1031(k)-1, and Rev. Proc. 2000-37. What QI operational capability actually means, and common failure modes.
State overview
State QI bonding and registration
Verified states only, from primary statute or regulator pages. Table with requirement summary, source link, and as-of date.
State deep-dives
CA, WA, NV, CO, ME + TX, FL, AZ, NY, NJ
Statute states open the primary text. TX/FL/AZ/NY/NJ report what we opened when no standalone chapter was found.
Comparisons
Compare listed QIs
Fifteen high-intent pairs from published custody fields. No crown, no invented fees, unknown stays unknown.
Comparison
IPX1031 vs Asset Preservation
Published custody facts for the two title-family QIs. No crown, no invented fees, DST labeled as securities.
Comparison
QI fees (published cards only)
Dollar amounts only where a firm still prints them. Unknowns stay unknown. Float is a separate price.
Comparison
Reverse-exchange QI
Rev. Proc. 2000-37 and 2004-51, questions to ask, and an alphabetical list of firms that publish reverse or EAT work.
Custody mechanics
Segregated funds vs dual-signature
Segregated vs commingled vs aggregated subledgers, why dual-signature is a different control, and what a parent logo does not prove.
Securities language
QI custody vs DST offerings
A QI listing here is a custody file. A DST interest is typically a securities offering. Those are different products and different documents.
Structure only
DST as replacement property
Rev. Rul. 2004-86 holdings and trustee-power list. No sponsor term sheet. No offering CTA.
Counts
Directory stats
FEA, CES, segregated, reverse, published fee-card counts from this repo’s firm Markdown only. Not a ranking.
Comparison
Deferred vs LikeKind
Two $0-forward fee-model files, published fields only. No crown.
Field key
How to read a custody file
What each directory column means, what we refuse to invent, and how to use FEA, CES, and state bonding without treating them as a government charter.
Attribute indexes (unique ledes, same firm files):FEA members,CES on staff,reverse published,improvement published,segregated funds,independent,institutionally owned.