The 1031 portion that indefinitely defers the tax on gain and depreciation recapture is paperwork performed by the qualified intermediary who is the extra required presence by the IRS to facilitate your exchange.  

@Daryl DearmanFrom your last statement, it sounds like you may be confusing Checkbook LLC facilitators with custodians. 

If you have ANY expense that relates to one of the investments held by your SDIRA, you'll only want to cover those expenses using your IRA funds and you'll have to direct your custodian to facilitate the payment from your IRA.

My understanding is that I need to disclose to both the wholesaler and to my buyer what my commission will be, have already determined agency or facilitator status with my buyer, and then add my commission to the price a give to my buyer before writing an offer for my buyer (and disclose that I am receiving $5,000 commission in the necessary forms).

There were certain things you had to do to earn the origination fee like collect required documents, facilitate in pulling credit, and submit the file to underwriting.However, then there was a change in regulations that required loan officers to be educated/certified in some way. 

I’m looking to implement CRM software into my wholesaling business in order to keep track of client information, and to facilitate communication and follow up.I understand there are many good systems out there, but I’m wondering if anyone has advice for implementing CRM software into a wholesaling business, and if there are any recommendations on any specific systems.

If you have no intention or ability to close, you’re locking up someone’s property and brokering without a license to try to resell it.Plus think about the showings and how your agent will need to facilitate showings to bring in new buyers.

I can send over some referrals if needed, but overall I'd call a few title companies to have their attorneys facilitate the transaction.

The agent is not the decision maker here, just the facilitator.

And THEN, once you sold all your homes, can you use the accumulated trust to facilitate a 1031 exchange into one large commercial property?