# SeniorCRE — REIT & Institutional-Owner Diligence Checklist
_Senior housing investment management software · 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 senior housing & care portfolio.

## 1. REIT qualification tests (IRC §856)
- [ ] 75% asset test coverage across every entity, refreshed each quarter close
- [ ] 95% and 75% gross income tests with RIDEA/SHOP carve-outs and TRS isolation
- [ ] 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
- [ ] 90% distribution requirement tracker by tax year with rollforward evidence
- [ ] Section 856(d) rents-from-real-property classification at the lease clause level

## 2. Portfolio operating controls
- [ ] Tenant / entity isolation enforced at the database row level (not app-layer)
- [ ] Covenant tracking with lease-coverage and debt-service thresholds by property
- [ ] Multi-operator rollups with property-level drill-down from portfolio KPIs
- [ ] 1031 like-kind exchange workflow with identification and 45/180-day timers
- [ ] Immutable, append-only audit log designed to support SOX 404 / SOC 2 evidence requirements

## 3. Data governance & buyer fit
- [ ] Operator-controlled authority record — REIT views follow operator-approved definitions, source authority, reconciliation, and lineage
- [ ] Named data-processing agreements, HIPAA BAAs, and PHI storage boundaries
- [ ] Documented integration paths for Yardi®, MRI®, RealPage®, PointClickCare®, MatrixCare® — nominative fair use for system identification; no live third-party connector is claimed
- [ ] Named review and sign-off owners for every quarter-close attestation
- [ ] Published methodology and dated footnotes for every competitive claim

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_Hedged comparative wording. All named products are trademarks of their respective owners and referenced under nominative fair use based on publicly available product materials as of September 2026. As of September 8, 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