Rev. Proc. 2000-37 QEAA safe harbor — EAT parks title while you sell the relinquished property. 8 Vectr workflows. 3 durable deadline clocks. 0 steps that require human intuition. All approval gates are authorization, not judgment — exactly what multi-party Vectr workflows provide. Cross-link: Reverse Automation Surface.
Exchange-Last — 7-Step Hub Sequence (sell relinquished after replacement is parked)
3 Durable Deadline Clocks — All Anchored on EAT Deed Recorded (Day 0)
reverse-qeaa-5day-watcherreverse-qeaa-5day-watcher
must skip Sat/Sun and federal holidays in its countdown predicate.
Day 3 reminder fires; Day 5 escalation blocks further progress until QEAA is signed.
reverse-45day-relinquished-id-watcherbodyVariant: identify-relinquished
or it generates a Replacement Property Identification Notice — the wrong document —
instead of the Relinquished Property Identification Notice.
reverse-180day-parking-watcherreverse-180day-parking-watcher
fires a block notice and alerts QI staff. Day 150 + Day 170 warnings precede it.
The exchange fails irrevocably at Day 180 — there is no grace period.
Implementation Correctness Traps — Reverse-Specific
eat-parking-arrangement-setup webhook from the deed-recording event is the sole correct trigger.
identify-replacement) generates
an IRS-compliant Replacement Property Identification Notice signed by the exchanger.
In a reverse exchange the ID hub must declare bodyVariant: identify-relinquished so it:
(a) labels the identified property as the one to be sold, not purchased,
(b) routes the signed notice to reverse-45day-relinquished-id-watcher,
and (c) generates the Relinquished Property Identification Notice.
Using the wrong variant produces a document that the IRS will reject.
reverse-qeaa-5day-watcher must skip Saturdays, Sundays, and federal holidays.
A deed recorded on a Thursday yields a QEAA deadline on the following Thursday, not Tuesday.
Firing the Day-5 block on a Tuesday would wrongly void an exchange that has until Thursday.
bodyVariant on the ID hub,
(2) the deadlineAnchor field in the exchange config,
and (3) the step-order array. This proves the hub shell renders from the exchange-type config array —
not a hardcoded 6-hub list — and that Reverse is not a special-case build,
it is the same engine with a different config.
| Workflow | Trigger | Approval Gate | Documents |
|---|---|---|---|
| eat-entity-formation | Exchange created (reverse type selected) | None — automated | SPE-LLC articles of organization, EAT escrow account opening docs, EAT operating agreement |
| Workflow | Trigger | Approval Gate | Documents |
|---|---|---|---|
| eat-parking-arrangement-setup | Deed-recorded webhook from EAT acquisition close | None — starts both 45-day and 180-day durable timers automatically | Parking arrangement record; starts durable timer workers for 45-day and 180-day clocks |
exchange.sale_closed at relinquished property transfer).
| Workflow | Trigger | Approval Gate | Documents |
|---|---|---|---|
| eat-agreement-generate | Parking setup complete event | Exchanger + QI each sign via DocuSign | QEAA Agreement (PDF), EAT loan documents |
| reverse-qeaa-5day-watcher | Day 0 timestamp (deed recorded) | QI escalation on Day 5 if unsigned | Day 3 reminder email/push, Day 5 escalation notice |
| Workflow | Trigger | Approval Gate | Documents |
|---|---|---|---|
| reverse-45day-relinquished-id-watcher | Day 0 timestamp | None for reminders; QI alerted Day 44; hard block Day 45 | Day 30 reminder, Day 40 reminder, Day 44 QI escalation; Relinquished Property Identification Notice (exchanger e-sign) |
| Workflow | Trigger | Approval Gate | Documents |
|---|---|---|---|
| esign-orchestration | Sign action in Sales Hub | Exchanger + QI counter-sign | Exchange Agreement, Assignment of Contract (relinquished) |
| escrow-wire-routing | Closing event webhook | QI officer authorizes wire (multi-party) | Wire instruction letter |
| escrow-funds-received | Bank webhook / Plaid event | QI confirms receipt | Escrow receipt confirmation |
Sale proceeds must flow to the QI-held escrow account, never directly to the exchanger. The escrow-wire-routing workflow enforces this at the wire level — no code path allows the exchanger to receive funds before the EAT transfer-out is complete.
| Workflow | Trigger | Approval Gate | Documents |
|---|---|---|---|
| eat-transfer-out | Exchanger requests a transfer the agreement permits; an authorized officer proposes it | Two authorized officers, proposer distinct from approver — never single-person | Deed transfer instruction, EAT loan repayment confirmation, wire authorization |
| reverse-180day-parking-watcher | Day 0 timestamp / ongoing | Day 179: blocks transfer if not initiated; QI alerted | Day 150 warning, Day 170 warning, Day 179 block notice |
| Workflow | Trigger | Approval Gate | Documents |
|---|---|---|---|
| form-8824-generate | EAT transfer-out completion event | Exchanger + CPA review; QI counter-sign | IRS Form 8824 — Like-Kind Exchanges (PDF) with §1031(d) basis calculation |
Exchange-First — EAT Parks the Relinquished (less common; exchanger wants to buy first, sell later)
eat-parking-arrangement-setup webhook still fires, but from the relinquished property close.
| # | Workflow | Trigger | Approval Gate | Documents Generated |
|---|---|---|---|---|
| 1 | eat-entity-formation |
Exchange created (reverse type) | None — automated | SPE-LLC articles of organization, EAT escrow docs, operating agreement |
| 2 | eat-parking-arrangement-setup |
Deed-recorded webhook from EAT acquisition | None — starts 45-day + 180-day durable timers | Parking arrangement record |
| 3 | reverse-qeaa-5day-watcher |
Day 0 timestamp (deed recorded) | QI escalation on Day 5 if QEAA unsigned | Day 3 reminder, Day 5 escalation notice |
| 4 | eat-agreement-generate |
Parking setup complete event | Exchanger + QI each sign via DocuSign | QEAA Agreement (PDF), EAT loan documents |
| 5 | reverse-45day-relinquished-id-watcher |
Day 0 timestamp | QI alerted Day 44; hard block Day 45 | Day 30/40/44 reminders; Relinquished Property Identification Notice |
| 6 | reverse-180day-parking-watcher |
Day 0 timestamp / ongoing | Day 179 blocks transfer if not initiated | Day 150/170 warnings, Day 179 block notice |
| 7 | eat-transfer-out |
Exchanger requests a transfer the agreement permits; an authorized officer proposes it | Two authorized officers, proposer distinct from approver — never single-person | Deed transfer instruction, EAT loan repayment confirmation, wire authorization |
| 8 | form-8824-generate |
EAT transfer-out completion event | Exchanger + CPA review; QI counter-sign | IRS Form 8824 — Like-Kind Exchanges (PDF) |
IRS Compliance Points — What Vectr Automates
reverse-qeaa-5day-watcherreverse-45day-relinquished-id-watcherreverse-180day-parking-watchereat-entity-formationeat-transfer-outform-8824-generate