1031 Accommodator Fees: Base Cost, Add-Ons, and Tax Basis

For a straightforward forward exchange with one property sold and one purchased, 1031 accommodator fees typically run between $600 and $1,500 as a flat charge. That fee covers the exchange agreement, custody of your sale proceeds, tracking of the 45-day and 180-day deadlines, and closing coordination on both sides of the transaction. Reverse exchanges and construction exchanges cost substantially more because the Qualified Intermediary (QI) takes on additional legal and financial risk.

What the Base Fee Actually Covers

The accommodator fee buys a defined bundle of work. Most QIs include all of the following in a standard forward-exchange price:

  • Drafting and executing the written exchange agreement that assigns your rights in the sale and purchase to the intermediary. This document is what creates the Section 1031 safe harbor.
  • Holding your sale proceeds in a segregated trust or escrow account, so you have no ability to receive, pledge, borrow, or otherwise access the funds until the exchange closes.1eCFR. 26 CFR 1.1031(k)-1 – Treatment of Deferred Exchanges
  • Monitoring the 45-day identification deadline and the 180-day exchange deadline, sending written reminders, and documenting your compliance.2Office of the Law Revision Counsel. 26 USC 1031 – Exchange of Real Property Held for Productive Use or Investment
  • Preparing assignment agreements, buyer and seller notices, and closing instructions for the title or escrow agent on each leg of the exchange.
  • Providing the forms and collecting your written identification of replacement properties before the 45-day window closes.

Some accommodators also include preparation of IRS Form 8824 in the base price. Others charge a small add-on for it. Ask before you sign.3Internal Revenue Service. Instructions for Form 8824 (2025)

Flat Fee vs. Tiered Pricing

Accommodators generally price two ways.

The flat-fee model is the most common. You pay a single fixed price for one relinquished property and one replacement property, regardless of the transaction size. That gives you a predictable cost and removes any incentive for the QI to steer you toward higher-priced properties. Flat fees for a standard forward exchange typically run $600 to $1,500.

The tiered model starts with a base fee and adds charges for complexity. A QI might charge $800 for the first property leg plus an additional amount for each subsequent property. This structure shows up most often when the exchange involves multiple relinquished or replacement properties, because each additional closing requires its own assignment agreement, closing instructions, and fund transfers.

Add-Ons That Sit Outside the Quote

Whatever the pricing model, watch for line items that fall outside the headline fee. Common extras include wire transfer fees of $25 to $50 per wire, overnight courier charges, and fees for amending identification letters after the initial submission. If you sell property in a state that imposes nonresident withholding, the QI may charge a supplemental fee for handling the withholding exemption paperwork tied to the 1031 exchange. Ask for a complete fee schedule before you sign the exchange agreement so you can compare accommodators on the same terms.

What Pushes Fees Well Above the Base

The base fee applies to the simplest structure: sell one property, buy one replacement, move forward in time. Anything beyond that increases the accommodator’s workload and risk, and the pricing follows.

Reverse Exchanges

In a reverse exchange, you buy the replacement property before selling the relinquished property. Because you cannot own both properties at once and still qualify for deferral, the QI (or an affiliated entity) must take title to one of the properties through a special-purpose entity called an Exchange Accommodation Titleholder. The IRS recognizes this arrangement under a safe harbor from Revenue Procedure 2000-37, which requires the parked property to be transferred within 180 days.4Internal Revenue Service. Rev. Proc. 2000-37 – Safe Harbor for Reverse Exchanges Reverse exchange fees commonly start around $5,000 and can reach $10,000 or more, because the QI is holding title, arranging financing, and carrying legal exposure across the entire parking period.

Improvement or Construction Exchanges

If you want to use exchange funds to build on or improve the replacement property before you take title, the QI has to manage construction draws, track capital expenditures, and verify that all improvements are completed inside the 180-day window. Fees for improvement exchanges run several thousand dollars above the standard rate.

Multiple Properties

Exchanging into or out of several properties at once multiplies the paperwork. Each closing is a separate legal event with its own assignment agreement, fund transfer, and coordination with a different title or escrow agent. Accommodators typically charge a per-property add-on for each additional property beyond the first on either side of the exchange.

Other Transaction Costs the Fee Does Not Cover

The accommodator fee is one line item among several. Other costs go to separate parties and come out of your own pocket or the exchange proceeds if they qualify as allowable expenses:

  • Appraisal fees for a third-party valuation of the replacement property, typically several hundred dollars per property.
  • Title insurance and escrow fees paid to the title company, which vary by property value and local market.
  • County recording fees for the deed and mortgage instruments.
  • Independent legal counsel, if you hire an attorney to review the exchange agreement.
  • Environmental assessments, property inspections, and surveys ordered as buyer due diligence.

Together these can add several thousand dollars to the total cost of completing an exchange. Budget for them alongside the accommodator fee.

How Accommodator Fees Affect Your Tax Basis

QI fees are classified as exchange expenses. That means they reduce your recognized gain rather than sitting on the sidelines as a personal cost with no tax benefit. The Form 8824 instructions direct you to include exchange expenses in the adjusted basis calculation on Line 18, which effectively adds those costs to your basis in the replacement property.3Internal Revenue Service. Instructions for Form 8824 (2025)

Accommodator fees are also among the transaction costs the IRS permits you to pay directly from exchange proceeds without creating taxable boot. Other allowable expenses include real estate commissions, title insurance premiums, escrow fees, transfer taxes, and attorney fees tied directly to the exchange. Costs that are not directly related to the sale or acquisition, such as loan origination fees, property insurance premiums, and prorated property taxes, generally cannot be paid from exchange funds without risking boot treatment. Paying a disallowed expense from your exchange account has the same tax consequence as pulling out cash.

Why the Cheapest Quote Is Not Always the Best Deal

There is no federal licensing requirement for 1031 qualified intermediaries. Anyone can hold themselves out as a QI and offer to hold your exchange funds. The IRS regulations define what a QI does and how the safe harbor works, but they impose no capital requirements, bonding, or insurance minimums on the entity holding your money.5GovInfo. 26 CFR 1.1031(k)-1 – Treatment of Deferred Exchanges

Roughly nine or ten states have stepped in with their own rules, typically requiring accommodators to carry fidelity bonds of at least $1 million and errors-and-omissions insurance of $250,000 or more. In a state without those requirements, your QI may have no legal obligation to carry any coverage at all.

This is not theoretical. In November 2008, LandAmerica 1031 Exchange Services filed for bankruptcy, freezing hundreds of millions of dollars in customer exchange funds. Deadlines kept running while the money sat locked in bankruptcy proceedings, and many exchanges failed. The affected customers owed capital gains tax on the original sale in that tax year, even though the funds to pay it were inaccessible. Some recovered only a fraction of what they had deposited.

When you compare accommodators, treat the fee as one data point rather than the deciding one. Ask whether the QI carries a fidelity bond and how much it covers. Ask whether exchange funds sit in a segregated, FDIC-insured account or are commingled with the company’s operating funds. Ask how many people hold signatory authority over the account. A QI charging $900 with strong bonding and segregated accounts is a better deal than one charging $600 with no insurance and vague answers about where your money is held.

One Detail Worth Asking About: Interest

While your sale proceeds sit in the accommodator’s account, they typically earn interest. Most exchange agreements provide that the interest belongs to you, but interest income does not qualify for tax deferral under Section 1031. It is taxable as ordinary income in the year earned, at your regular rate rather than the capital gains rate. If the interest pushes the total in the account above what you reinvest into the replacement property, the excess can be treated as taxable boot. Ask your QI upfront how interest is handled and whether it will be distributed separately or folded into the exchange proceeds.