Your exchange
Matt Belcher · EX-2026-000214 · Reverse exchange (exchange-last) · QI of record: [QI firm legal name]
Mockup control. A real exchanger never sees this — they see one exchange, of one type. A reverse improvement is both at once: its clocks anchor on the EAT acquisition like the left panel, and its money runs on the draw schedule like the right one.
Someone has to hold the deed. For now, it is not you.
You bought your replacement property before you sold the one you already own. The tax rules behind a 1031 exchange do not let you hold both ends at the same moment — so a company holds the new one for you until your sale closes. That company is called an Exchange Accommodation Titleholder, or EAT. Yours is Open1031 EAT LLC, a single-purpose company your QI formed for this exchange and nothing else.
The EAT is on the deed. You are not. Everything else about the property is arranged so it behaves like yours — and the day your sale closes, the deed comes to you. The industry word for this is parking: the property is parked with the EAT.
Who holds the deed to 456 Sunset Blvd, and when. The middle segment is the parking period. It cannot last longer than 180 days.
Is this arrangement normal, or is my exchange unusual?
Your clocks started on July 8 — the day the EAT took title
This is the detail almost everyone gets wrong, so it is worth being blunt about: in a reverse exchange your 45-day and 180-day clocks are not counted from the sale of anything. They are counted from the day the EAT took title to your replacement property.
The one thing to do next
By day 45 you have to put in writing which property you are selling to complete this exchange. Nothing has to be sold by then, and nothing has to be under contract — you are naming it, not closing it. Two steps, both short:
The agreement that had to be signed in 5 business days
This is the written agreement between you and the EAT that says, in effect: the EAT is holding this property for a 1031 exchange, on these terms. Rev. Proc. 2000-37 requires it to be signed within 5 business days of the EAT taking title — business days, so weekends and federal holidays do not count.
What is parked, and what it is waiting for
Where your money is, and who is allowed to move it
When your sale closes, the proceeds are wired straight into your QI's qualified escrow account. Not to you, and not to your bank. This is the part of a 1031 that people find strangest, so here is the plain reason: if you could get your hands on the money — or even hold up its release — the IRS treats you as having received it, and the deferral is gone.
Your documents
You are buying a building and improving it with exchange money
Your replacement property is worth less than the one you sold — until the work is done. An improvement exchange (also called build-to-suit) lets the money from your sale pay for construction, and lets the finished value count toward your exchange. It has one condition that surprises people, and it is worth reading twice.
The improvements have to be physically standing on the property by day 180. Not contracted. Not paid for. Standing. Work finished on day 181 does not count toward your exchange, no matter when you signed the contract or when the money left the account.
And while the work happens, the same Exchange Accommodation Titleholder (EAT) arrangement applies: Open1031 EAT LLC holds the deed to 1420 Harbor Point Rd while it is being improved, and the deed comes to you when the work is in place. You cannot own it and build on it with exchange money at the same time.
Who holds the deed to 1420 Harbor Point Rd, and when. The parking period ends on the earlier of two dates: 180 days after the EAT took title (Feb 1, 2027), or your exchange deadline (Jan 20, 2027). We hold you to the earlier one — Jan 20, 2027.
Your clocks started on July 24 — the day your sale closed
This is a forward improvement exchange, so the anchor is the closing of the property you sold, not the EAT. If yours were a reverse improvement, the anchor would move to the day the EAT took title, exactly as in the reverse panel — the construction rules below would be unchanged.
Value in place — the number that actually counts
Your draw schedule
| Draw | Amount | Where it stands | Whose move | Action |
|---|---|---|---|---|
|
Draw 1 — foundation & site work
Requested by you Aug 6 · inspected Aug 10
|
$95,000.00 |
Approved
By Sandra Osman, QI officer, Aug 11 — she did not request it
|
Nothing outstanding | |
|
Draw 2 — framing & envelope
Drafted Aug 18 · contractor invoice attached
|
$91,500.00 |
Draft — not sent
Sending it is a request. It is not an approval and releases nothing.
|
You | |
|
Draw 3 — mechanical, electrical, plumbing
Scheduled for late October
|
$118,000.00 | Not requested yet | Your contractor | |
|
Draw 4 — finishes & occupancy
Scheduled for December · must be in place by Jan 20
|
$115,500.00 | Not requested yet | Your contractor |
status = 'funded'
is defined in the schema and written by nothing. In a live exchange that release runs through the
two-officer disbursement path, and this row would show both names and both timestamps.
Ask me anything on this page in plain language — "what happens if my buyer walks", "why can't I just hold the deed", "what does day 180 actually mean for me". I will explain, draft documents and remind you before a date, and I will always show you where an answer came from. I do not give tax or legal advice, and I cannot move, hold or release your money — that takes two authorized officers, and neither of them is me.
The same cards in every other state
Each of these is a state the shipped code can actually produce. They are drawn here because the state a surface handles badly is the state that frightens someone.
EXCHANGE_VARIANTS[...].deadlineAnchor === 'eat_acquisition'). Never render a countdown on this
family without naming the anchor date beside it. The QI console already carries this correction
(ReverseFamilyNotice.tsx); the exchanger has never been told.2 · Every clock is server-side, and the page says so. The 5-business-day QEAA window (
qeaaDeadlineGuard.ts, federal holidays from businessDays.ts) and the 45/180-day
dates (parkingDeadlineCascade.ts) are computed and watched in Vectr. A browser left open cannot move
a statutory date, and the surface must reassure the reader of that rather than silently rely on it.3 · An overdue statutory deadline never resolves to met, satisfied or green. A QEAA signed past its window renders in the danger role with the overrun stated and the recorded written acknowledgement (
qeaaLateAcknowledgment + reason) linked. There is no state in which it turns into a tick.4 · Status is derived from evidence, never from one boolean. "Signed" is a signature record — signer, timestamp, affirmed intent, and the deadline the platform computed. "Parked" is a recorded deed plus an acquisition date plus a park status. "Value in place" is inspected work, and it is deliberately never added to, or confused with, the money released in draws — the two are separate computations in
ConstructionHub.tsx because only one of them counts on day 180.5 · The exchanger is never in a fund-movement path, and the page explains why rather than hiding it. Releasing money takes two authorized officers with an approver who is not the proposer, enforced in the workflow and in the database (
construction_draws_approver_ne_requester,
disbursement_proposals_approver_ne_proposer). Where the exchanger genuinely participates it is an
acknowledgement or a request — recorded, non-authorizing, non-gating — and it must render visibly distinct from
an approval slot (.ack-slot, never .auth-slot alone). A submission is never counted as
a sign-off. An exchanger with a hold over qualified-escrow funds is constructive receipt under Treas. Reg.
§1.1031(k)-1(g)(6), which is a statutory failure, not a permissions preference.6 · KYC is the first gate and can never be satisfied by proxy; a signature always belongs to the signer.
useHubAccess('parking') blocks the hub until identity clears, and the coordinator path
(useCoordinatorHubBanner) can prepare and send a document but has no affordance to sign one — the
eSign Act and UETA require the signer's own intent. Say this out loud on the surface; a reader who does not know
it will ask their coordinator to "just sign it".7 · Exactly one next step, per variant, and it is the one with the shortest fuse. The reverse panel emphasises the 45-day identification (3 days out); the improvement panel emphasises the draft draw. Only one panel is on screen at a time, so only one
.is-next is ever visible. Zero emphasis is as wrong
as two.8 · Whose move is it, on every row that two parties can touch. Waiting-on attribution exists on neither the exchanger nor the QI interface today. It is the cheapest anxiety reduction available: a row that says "waiting on your QI" stops a 2 a.m. phone call.
9 · Plain English, expanded on first use, and never advice. "Exchange Accommodation Titleholder" is spelled out and then explained in one sentence about deeds. Rev. Proc. 2000-37 appears as reassurance — a published IRS safe harbour this structure is built to sit inside — never as a citation dropped on the reader. The surface states what Open1031 did, on which date, with which document, and stops there: it never tells the reader how their return will be treated.
10 · Accent roles are aliased, not hardcoded. Each panel sets
--acc* once:
reverse reads --hub-reverse, improvement reads --hub-disbursement because it is the
only orange role in the sheet and matches ConstructionHub's shipped color="orange".
When this becomes code, add a real --hub-improvement role rather than borrowing the disbursement
leg's hue — an improvement exchange is not a disbursement. The filled improvement button takes
--hub-disbursement-ink, not the base hue: white on the base orange is 3.6:1 and fails AA.11 · Provenance is stated, not implied. This consolidated page is a proposal; the hubs, clocks, parking model, attestations and draw workflow under it are shipped. Draw funding is neither —
status = 'funded' is in the schema with no writer — so it carries a dashed
Not wired yet pill instead of a plausible-looking timestamp.
reverse_exchange_first is supported: false in exchangeVariant.ts and is
concierge-assisted; it is not depicted here as self-serve.Light and dark are both designed. Every colour resolves through
tokens.css; there is no raw hex in
this file. All names, addresses, amounts, dates and references are synthetic demo data.