# SeniorCRE — REIT & Institutional-Owner Diligence Checklist
_Prepared for Janus Living / Healthpeak Properties · Refreshed September 2026_

Use this checklist to evaluate any operating record proposed as the **operator-controlled operating record** for REIT-qualification monitoring, covenant evidence, and multi-operator rollups across a Sunbelt senior housing & care portfolio (~546 units, AL / MC / IL; Yardi® + PointClickCare® stacks).

**Context for Janus Living / Healthpeak.** Institutional capital in senior housing does not fail the day the §856 income test tips below 75%. It fails the day the asset-management team cannot reconstruct which source row of which system produced the number. This checklist is scoped so Patrick (Asset Management) and Omkar (Innovation / AI) can run the same evaluation from opposite ends of the stack — and land on one Operator-Controlled Operating Record.

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## 1. REIT qualification tests (IRC §856)
- [ ] 75% asset test coverage across every entity in the Janus / Healthpeak structure, refreshed each quarter close
- [ ] 95% and 75% gross income tests with RIDEA / SHOP carve-outs and TRS isolation for AL / MC / IL revenue mix
- [ ] TRS securities measured against the 25% total REIT asset-value limit under §856(c)(4)(B)(ii) for tax years beginning after December 31, 2025, with alerts to Tax and Finance
- [ ] 90% distribution requirement tracker by tax year with rollforward evidence
- [ ] Section 856(d) rents-from-real-property classification at the lease-clause level, not the lease level

## 2. Portfolio operating controls (Patrick — Asset Management)
- [ ] Tenant / entity isolation enforced at the database row level (RLS), not app-layer
- [ ] Covenant tracking (LCR, DSCR) per property with alert thresholds — visible from the REIT roll-up
- [ ] Multi-operator rollups with property-level drill-down from portfolio KPIs (occupancy, RevPOR, agency %, denials)
- [ ] Occupancy math visible to Asset Management: 1 pt of occupancy across the Janus footprint ≈ ~$382K annualized net revenue (illustrative, worked example on stated RevPOR / unit mix)
- [ ] 1031 like-kind exchange workflow with identification and 45 / 180-day timers
- [ ] Immutable, append-only audit log designed to support operator assurance evidence; no SeniorCRE SOC 2 report claimed — REIT views follow operator-approved authority and lineage

## 3. AI & data governance (Omkar — Innovation / AI)
- [ ] Operator-controlled authority record — designed so REIT views follow operator-approved definitions, source authority, reconciliation, and lineage
- [ ] AI agents grounded on the Operator-Controlled Operating Record (not a vector copy) with source-row citation on every answer
- [ ] Role-based access at the row level enforced for AI outputs, not just the UI
- [ ] Named data-processing agreements, HIPAA BAAs, and PHI storage boundaries for resident-level data
- [ ] Documented integration paths for Yardi®, PointClickCare®, MatrixCare®, MRI®, RealPage® — read-only diagnostic is a design target, not a guaranteed timeline, subject to access, data-use agreements, and scoping
- [ ] Published methodology and dated footnotes for every competitive claim (nominative fair use, dated citations)

## 4. Buyer fit — Janus / Healthpeak specific
- [ ] Read-only diagnostic scope against one Sunbelt community (Yardi® GL + PointClickCare® clinical) with no rip-and-replace — gate-based written scope, subject to access, data-use agreements, and operator acceptance
- [ ] Single operator-controlled operating record across retained systems and any domains the operator elects to run on SeniorCRE
- [ ] Named review and sign-off owners for every quarter-close attestation
- [ ] Evidence chain from OM number → source row in ≤1 hop, screen-recordable in the demo
- [ ] Contract facts, retention posture, and audit-log export terms defined before pilot expansion

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**How to run the evaluation (30 minutes, one community).**
1. Score the platform yes / no against the 24-point checklist — product evidence, not marketing.
2. Trace one §856 income number from the OM to the source row. One hop, not four.
3. Verify tenant isolation at the database row level — ask for the RLS policy set and the automated tests.
4. Force hedged, dated comparative wording on Yardi®, PointClickCare®, MatrixCare®, MRI®, RealPage®.
5. Confirm the operator owns the Operator-Controlled Operating Record. REIT reads it. Operator writes it. Same record. Same second.

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_Hedged comparative wording. Yardi®, PointClickCare®, MatrixCare®, MRI®, and RealPage® are trademarks of their respective owners and are referenced under nominative fair use based on publicly available product materials as of September 2026. Prepared as a diligence leave-behind for Janus Living / Healthpeak Properties; not an offer of securities. As of September 17, 2026: no completed operator pilot, no operator production deployment, no independently verified operating outcome._

## October 15, 2026 statutory reconciliation — professional review pending

The limit is the value of TRS securities as a share of total REIT asset value, measured at statutory quarter-end, not a TRS gross-income cap. Public Law 119-21 §70439 changes 20% to 25% for taxable years beginning after December 31, 2025. Annual 95%/75% income tests are separate. Earlier periods require the applicable historical rule. Tax counsel must confirm entity-specific application, valuation and relief.

Capability evidence remains October 9, 2026: §856 qualification is under evaluation, not confirmed or built; governance is designed, not implemented in any community; named-vendor connectors are roadmap, not live in operator production. Named qualified tax-counsel and product-owner review dates remain pending.

Evergreen sixteen criteria and JSON/CSV/Markdown: https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria
Q3 post-close archive: https://seniorcre.com/reit-monitoring-features-checklist-q2
Q4 preparation (not completed close): https://seniorcre.com/reit-monitoring-year-end-review-2026
Statute: https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm