Printable checklist · not tax or legal advice

QI due-diligence checklist

Ten questions to answer in writing before relinquished-property proceeds move. Check a box only when you have a document, not a slogan. Unpublished directory cells are not demerits — fill those from the live file. This HTML page stays public and printable. The same ten items are also aPDF.

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Directory and checklist notes only — not investment advice, not a securities subscribe, and not an offer of exchange services. We do not sell the list.

The HTML checklist stays public.

Download the PDF or use the browser print dialog. The PDF links back towww.theqifile.com. Navigation hides on the printed page.

1. Legal entity on the exchange agreement

Exact legal name and formation state of the qualified intermediary that will sign. Confirm it matches the account title — not a marketing brand or parent lockup.

2. Account title and TIN

The words that will appear on the bank or trust statement, including taxpayer identification. Request a redacted specimen. If a qualified escrow or trust is used, name the escrow holder or trustee.

3. Segregated vs commingled / aggregated

In writing: identified-to-taxpayer account, qualified escrow/trust, or pooled account with a subledger. Confirm proceeds are not deposited in the QI’s operating account. Aggregation is not the same as a unique account number.

4. Who can initiate a wire (dual-sign)

Authorized-signer list. Whether a single employee can release funds. Whether the deposit bank requires dual written authorization, at what amount, and who the second signer is.

5. Current insurance certificates — not brochure numbers

Fidelity / crime and E&O certificates in force, named insured, deductible. Do not copy a marketing limit into this box. The QI File does not invent coverage.

6. State statute path, if any applies

Which exchange-facilitator or escrow statute the firm says applies, and which alternative it is using (bond, cash/LOC, or qualified escrow/trust with dual authorization). There is no federal QI license.

7. Company FEA membership vs personal CES

Current company membership and a named CES® holder on this file, each verified on 1031.org. Association facts, not a government charter.

8. Reverse / EAT if this deal needs it

If you are parking property, will they document a QEAA under Rev. Proc. 2000-37, and have they applied Rev. Proc. 2004-51 to these facts? If this is only a delayed exchange, mark N/A — do not treat a missing reverse menu as a defect.

9. Who keeps interest

Who is entitled to interest or float, whether any rate is credited to the taxpayer, and whether that sits in the exchange agreement or a separate schedule. Unknown stays unknown until it is written.

10. Written independent bank-verify instructions

How you confirm title, TIN, and signers with the bank or trustee using a number or portal you look up yourself — not a callback from the same email that sent the wire instructions.

After the boxes

Compare what firms already publish in thedirectory. Interview wording lives onquestions to ask a QI. Process warnings — not a naughty list — are onQI red flags.

Sources for the underlying rules

Treas. Reg. §1.1031(k)-1 — law.cornell.edu/cfr/text/26/1.1031(k)-1. Accessed 2026-09-08.
Rev. Proc. 2000-37 — irs.gov/pub/irs-drop/rp-00-37.pdf. Accessed 2026-09-08.
Rev. Proc. 2004-51 — irs.gov/pub/irs-drop/rp-04-51.pdf. Accessed 2026-09-08.
Federation of Exchange Accommodators — 1031.org/about-fea. Accessed 2026-09-08.

Editorial access date: 2026-09-08. Not tax, legal, or investment advice.