State overview · not legal advice
State QI bonding and registration
There is no federal qualified-intermediary license. A smaller set of states have enacted exchange-facilitator or escrow statutes that require a bond, errors-and-omissions coverage, a cash or letter-of-credit substitute, a qualified escrow or trust, a license, or some combination. This page is an editorial index of states we could verify from a primary statute text or a named regulator guidance document. It is not a 50-state survey, not a conclusion that a given firm is in or out of compliance, and not legal advice. If we could not open a primary page, the state is omitted. Amounts below are the figures on the cited text as of the access date — they are not The QI File’s invention, and they can be amended.
How to use this table
Read the cited section. Confirm the current text — unofficial mirrors and session-law reprints go stale. Ask counsel which statute attaches to this exchange (situs of the property, office location, advertising, and where funds are held can all matter; California’s facilitator definition, for example, is broader than “property in California only”). Then ask the QI which statutory alternative it is using (bond vs deposit vs qualified escrow/trust) and for current certificates. Directory listings remain custody files; they do not recertify state compliance.
States not listed here are unknown to this table, not “no law.” Municipal rules, money-transmitter licenses, escrow licenses that might apply on other facts, and pending bills are out of scope unless cited below.
Verified states (as of access dates)
| State | Requirement summary (from the cited text) | Primary source | As of |
|---|---|---|---|
| California | No state QI license in Division 20.5. A person is an “exchange facilitator” if the person handles a California-property exchange, maintains a CA office, or advertises as a facilitator in the state (see §51000 definitions on the cited chapter). Financial assurance (§51003): $1 million fidelity bond or $1 million cash/letter of credit deposited as specified, or all exchange funds in a qualified escrow or qualified trust with dual written authorization. Errors-and-omissions (§51007): $250,000 E&O or an equivalent deposit. Conduct (§51009): prudent-investor standard; do not commingle exchange funds with operating accounts; do not loan or transfer exchange funds to an affiliate except as needed for an exchange accommodation titleholder. | Cal. Fin. Code Div. 20.5, §§51000–51013 (LegInfo) | |
| Washington | No statement on the cited section that Washington issues a QI license. RCW 19.310.040 requires a $1 million fidelity bond or a qualified escrow/trust structure with authorization independent of the facilitator plus a client bank statement. Exchange funds in a separately identified account using the taxpayer’s taxpayer identification number, taxpayer as a named beneficiary. Required website and contract disclosure that no Washington or federal agency regulates exchange facilitation. | RCW 19.310.040 (Washington State Legislature) | |
| Nevada | License required under NRS 645G (Division of Mortgage Lending). NRS 645G.320: $1 million fidelity bond or a deposit with the Division in lieu of the bond. NRS 645G.330: $250,000 E&O or a deposit in lieu. NRS 645G.350–.360: exchange money in a separate federally insured trust or escrow account; commingling with operating funds prohibited on the cited sections. | NRS Chapter 645G (Nevada Law Library) | |
| Colorado | No QI license on the cited section. Treating exchange facilitation without the statute’s financial assurance is a deceptive-trade-practice hook in §6-1-721. At all times: a $1 million fidelity bond and $250,000 E&O; or cash or letters of credit equal to that combined sum; or all exchange funds in a qualified escrow or qualified trust with dual written authorization. Do not commingle with operating accounts; aggregation of exchange funds with subaccounting that tracks each client is addressed in the section. Dual authorization required for transfers of exchange funds over $250,000. Change-of-control notice within two business days. | C.R.S. §6-1-721 (Colorado Public Law reprint of CRS; official OLLS title PDF also at leg.colorado.gov) | |
| Maine | License required (10 M.R.S. §1396). Financial responsibility in §1397: $250,000 fidelity bond, or a $250,000 deposit, or a qualified escrow/trust with dual authorization; and $100,000 E&O or a $100,000 deposit. Those are the figures on the cited sections — not a national schedule. | 10 M.R.S. §§1396–1397 (Maine Legislature) | |
| Oregon | ORS 673.810 financial responsibility: $1 million fidelity bond, or $1 million deposit, or qualified escrow/trust with dual written authorization, or the person is a named insured on a $1 million fidelity bond; and $250,000 E&O or a $250,000 deposit. This row reports the cited financial-responsibility statute. Whether a separate Oregon license chapter also applies to a given firm is not concluded here — read the surrounding ORS 673 provisions and the regulator if you need a license answer. | ORS 673.810 (Oregon Public Law / ORS) | |
| Virginia | Code of Virginia Title 55.1, Chapter 8 (Exchange Facilitators). No fidelity-bond minimum appears on the fetched chapter text. §55.1-802: separately identified account (the chapter points at Treas. Reg. §1.468B-6) with dual written authorization, or a qualified escrow or qualified trust. §55.1-803: $250,000 E&O or cash/letter of credit. No commingling. Change-of-control notice within ten business days. Do not invent a Virginia fidelity-bond number; the chapter as fetched does not state one. | Va. Code §55.1-800 et seq. (LIS) | |
| Connecticut | CGS §§36a-830–837 (money-transmission / exchange-facilitator provisions in Chapter 669). §36a-832: $1 million fidelity bond, or a separately identified account with dual written authorization, or a qualified escrow/trust with dual authorization. §36a-833: $250,000 E&O or cash, securities, or letter of credit. No registration or QI license requirement was found on the fetched chapter text; this row does not invent one. | Conn. Gen. Stat. §§36a-830–837 (Connecticut General Assembly) | |
| Idaho | Idaho does not appear to have a standalone “QI act” on the sources used for this table. The Idaho Department of Finance guidance 2020-03-SB (July 1, 2020) interprets the Idaho Escrow Act (I.C. §30-901 et seq.) as applying to qualified intermediaries, with an exception described in the guidance when the sole Idaho contact is replacement property located in Idaho. The guidance’s alternate financial-responsibility path under §30-909(7) is stated as a $1 million fidelity bond plus $250,000 E&O and no surety bond. That is the Department’s published interpretation as of the guidance date — not a separately numbered “Idaho QI statute.” Confirm current Department posture before treating the 2020 PDF as the last word. | ID Dept. of Finance Guidance 2020-03-SB (July 1, 2020) + I.C. §30-901 et seq. |
Deliberately not in the table
We did not add rows for states where we only had secondary blogs, FEA slide decks, or “all states that require a bond” marketing lists without a statute URL we opened. Idaho is included only because the Department of Finance published an escrow-act interpretation that names QIs — that is guidance plus the Escrow Act, not a dedicated QI code chapter. Oregon’s row is the financial-responsibility section we opened; we do not invent a separate “Oregon QI license” conclusion. Virginia’s row states that the fetched chapter has no fidelity-bond minimum; do not copy a bond number from another state into Virginia.
Per-state deep pages (full statutory text, legislative history, regulator contacts) are reserved for later. This overview is the citeable index.
Related
Sources
- California: Cal. Fin. Code Div. 20.5, §§51000–51013 (LegInfo). Accessed .
- Washington: RCW 19.310.040 (Washington State Legislature). Accessed .
- Nevada: NRS Chapter 645G (Nevada Law Library). Accessed .
- Colorado: C.R.S. §6-1-721 (Colorado Public Law reprint of CRS; official OLLS title PDF also at leg.colorado.gov). Accessed .
- Maine: 10 M.R.S. §§1396–1397 (Maine Legislature). Accessed .
- Oregon: ORS 673.810 (Oregon Public Law / ORS). Accessed .
- Virginia: Va. Code §55.1-800 et seq. (LIS). Accessed .
- Connecticut: Conn. Gen. Stat. §§36a-830–837 (Connecticut General Assembly). Accessed .
- Idaho: ID Dept. of Finance Guidance 2020-03-SB (July 1, 2020) + I.C. §30-901 et seq.. Accessed .
- Cross-check context only (not a row): Treas. Reg. §1.1031(k)-1(g)(3)–(g)(4) — federal safe-harbor definitions of qualified escrow/trust and qualified intermediary, not a state license. law.cornell.edu/cfr/text/26/1.1031(k)-1. Accessed 2026-09-05.
Colorado’s readable reprint is colorado.public.law/statutes/crs_6-1-721; that page cites the official OLLS title PDF at leg.colorado.gov … crs2024-title-06.pdf. Prefer the current Colorado Revised Statutes official publication if the reprint and the PDF diverge. This page is not legal advice. Statutes change.