# SeniorCRE — Q2 REIT Portfolio Compliance Checklist
_Senior housing REIT compliance software · reviewed September 2026 for Q2 close_

Use this checklist during Q2 quarter-close reporting 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) — Q2 close
- [ ] 75% asset test coverage across every entity, refreshed at the Q2 close cut-off
- [ ] 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 rollforward for the current tax year
- [ ] §856(d) rents-from-real-property classification at the lease-clause level
- [ ] Pre-close drift alerts routed to Tax, Finance, and Asset Management

## 2. Portfolio operating controls
- [ ] Tenant / entity isolation enforced at the database row level (not app layer)
- [ ] LCR and DSCR covenant tracking per property with alert thresholds
- [ ] Multi-operator rollups with property-level drill-down from portfolio KPIs
- [ ] Operator-data evidence boundary — REIT views follow operator-approved definitions, source authority, reconciliation, and lineage
- [ ] Portfolio NOI variance vs. budget with one-hop trace to source row
- [ ] Occupancy-quality view: payer mix, level-of-care, LOS, move-out velocity

## 3. §1031 exchange readiness
- [ ] 45-day identification window tracked per exchange with reminders
- [ ] 180-day exchange completion window tracked per exchange with reminders
- [ ] Qualified intermediary evidence attached to the disposition record
- [ ] Boot / basis calculation visible to Tax and Finance in-platform

## 4. Data governance & buyer fit
- [ ] Immutable, append-only audit log designed to support SOX 404 / SOC 2 evidence requirements
- [ ] 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
- [ ] Operator-controlled canonical record — designed to avoid a warehouse hop between write and read
- [ ] Named review and sign-off owners for the Q2 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