The QI File

Texas · no standalone facilitator chapter found · not legal advice

Texas: what we opened, and what we did not find

There is no federal QI license. Some states have enacted exchange-facilitator bonding or licensing chapters. Texas is not on theverified bonding tablebecause we did not open a Texas statute that creates that chapter. Searches ofstatutes.capitol.texas.govfor “exchange facilitator” and “qualified intermediary” returned other uses of “exchange” (stock exchanges, currency exchange, insurance exchanges) — not a 1031-facilitator act. That is a sourcing result, not a slogan that “Texas has no law.” Municipal rules, title-agent rules, and money-transmission facts can still matter. Ask counsel.

What still applies on a Texas property file

IRC §1031 and Treas. Reg. §1.1031(k)-1 still define the delayed-exchange clocks, identification, constructive receipt, and who is a qualified intermediary. A closing in Seguin or Austin does not replace those rules. Seethe timelineandwho holds the money.

Adjacent Texas text we are not treating as a QI license

Texas Finance Code chapter 152 (money transmission / currency exchange) licenses currency-exchange and money-transmission businesses and includes an exemption for an attorney or title company that receives and disburses funds in a real-property transaction. That is not a QI charter and not a finding that a QI is or is not a money transmitter. Do not treat a title-company exemption as a 1031 safe harbor.

What to ask on a Texas file

  • Exact QI legal name on the exchange agreement — not a brand that shares a building with a title agency.
  • Account title, TIN, who can wire, current fidelity/E&O certificates (even though this page found no Texas statutory minimum).
  • Whether any other Texas license (title, escrow, real-estate brokerage) is being treated as if it were a QI license — it is not, on the sources opened.

FAQ

Does Texas license qualified intermediaries?

No standalone Texas “exchange facilitator” or QI license chapter was found on the Texas Constitution and Statutes site when searched for those terms for this page. Federal tax status as a qualified intermediary is Treas. Reg. §1.1031(k)-1(g)(4), not a Texas charter. Adjacent Texas licenses (real-estate brokerage, title, money transmission) are different statutes. This is not a 50-title survey and not a finding that no Texas rule could ever attach on other facts.

Is there a Texas QI fidelity-bond minimum?

This page does not invent one. No Texas facilitator-bond figure was opened on a primary QI chapter. Do not copy California’s $1 million or Maine’s $250,000 onto a Texas file. Ask the QI for current certificates anyway.

Other state deep-dives

Related

Sources

  • Texas Constitution and Statutes — statutes.capitol.texas.gov. Searched for exchange-facilitator / qualified-intermediary chapters. Accessed 2026-09-11.
  • Texas Finance Code ch. 152 (money transmission / currency exchange; title/attorney real-property disbursement exemption on the fetched text) — statutes.capitol.texas.gov … 152.104. Adjacent only. Accessed 2026-09-11.
  • Treas. Reg. §1.1031(k)-1(g)(4) — federal QI definition, not a Texas license. Accessed 2026-09-11.

This is a QI custody explainer, not a securities offering and not legal advice. Statutes change. A later Texas chapter would move this page.