Several states are adopting some form of the Federation of Exchange Accomodator's (FEA) model law ( CA, CO, ME, NH, NV, VA, WA). The State of Washington, with the recent enactment of Substitute Senate Bill 6295, has perhaps the most stringent requirements. These laws pertain only to relinquished property sold in Washington as of June 7, 2012: The rules include a requirement to use a Qualified Trust or Qualified Escrow to hold the funds. It also must have an attorney or a Certified Exchange Specialist CES® (certification given by FEA) supervising the business. You get both of these with us at Keys Capital, Inc.