# REIT Q3 post-close review — September 30, 2026 Evidence cut-off: 2026-09-30 · Dated archive · Q3 post-close review · evidence cut-off September 30, 2026 · prepared October 9, 2026 Prepared / updated: 2026-10-15 SeniorCRE® is operator-controlled operating infrastructure for senior housing & care. The Operator-Controlled Operating Record is designed and not yet implemented in any community. IRC §856 qualification support is under evaluation for the roadmap — not confirmed, not built. No production result, live third-party connector, independently validated isolation control or tax-counsel approval is claimed. No more than 25% of the value of total REIT assets may consist of securities of one or more TRSs under IRC §856(c)(4)(B)(ii) for taxable years beginning after December 31, 2025 (Public Law 119-21 §70439). The amendment replaces 20% with 25%; earlier tax years require the applicable historical rule. This is a quarter-end securities asset-value limit, not a TRS gross-income cap. The annual 95% and 75% gross-income tests are separate; §856(l) defines TRS status and election. Tax counsel must confirm entity-specific application, valuation and relief. Named product-owner review: pending. Named tax-counsel review: pending. No expert approval is claimed. ## Preserve the September 30 snapshot - [ ] Keep the signed quarter-end asset values, source dates, definition versions and entity scope. Monitoring between closes does not change the statutory quarter-end asset-test measurement. ## Separate close facts from later changes - [ ] Log late feeds, reclassifications and valuation corrections against the signed package. Reproduce the original report before presenting a restatement; retain the approval and impact trail. ## Ask counsel to disposition exceptions - [ ] Review asset and TRS exceptions as of the quarter-end cut-off. Income and distribution tests require tax-year analysis; a Q3 year-to-date view is provisional, not annual qualification. Do not assume a missed threshold is incurable or that a cure applies. ## Carry open matters into year-end preparation - [ ] Assign an owner and due date to unresolved classifications, taxable-income estimates, distribution assumptions, covenant exceptions and exchange deadlines. A September 30 close does not mean the remaining tax year is closed. ## Sixteen evaluation criteria — preserve evidence, do not assume features - [ ] [1. IRC §856 75% asset test: quarter-end evidence and between-close warnings](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#asset-test) — A recomputation for one entity and one prior period you select, with the source rows behind both sides of the ratio. - [ ] [2. 95% and 75% gross income tests with RIDEA/SHOP treatment](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#income-tests) — The classification rule set, the line-level mapping for one RIDEA entity, and the change history on both. - [ ] [3. §856(c)(4)(B)(ii) 25% TRS securities asset limit for applicable 2026 tax years](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#trs-cap) — Quarter-end TRS securities values and total REIT asset values, the taxpayer’s tax-year start and applicable rule version, plus provisional alert thresholds, recipients and fired-alert history. - [ ] [4. 90% distribution requirement rollforward for the current tax year](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#distribution) — A rollforward view with the estimate basis, the version history, and the approver. - [ ] [5. §856(d) rents-from-real-property classification at clause level](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#rents) — A clause-level classification for one service-bundled lease, and the reviewer who approved it. - [ ] [6. Coverage and covenant evidence computed per property](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#covenants) — A one-hop trace from one covenant figure to the operator rows that produced it, with the definition version attached. - [ ] [7. NOI variance with lineage to the operating event](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#noi-variance) — One variance walk from portfolio NOI to a named operating driver at a named community. - [ ] [8. Occupancy quality, not just occupancy percentage](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#occupancy-quality) — The metric definitions, who owns each definition, and the last time each was changed. - [ ] [9. Entity and operator isolation enforced below the application layer](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#isolation) — The written control description, the test that proves it, and the contract clause on derived-data ownership. - [ ] [10. Named definition authority for every published metric](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#definition-authority) — The definition register with owner, version, effective date, and the approval record for one recent change. - [ ] [11. Reconciliation performed once, under governed rules](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#reconciliation) — One contested figure, the reconciliation rule applied, the approver, and the downstream reports that inherited it. - [ ] [12. Per-source freshness and stale-feed behavior stated in writing](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#freshness) — A latency table by source, plus a screenshot of the view while a feed is deliberately stale. - [ ] [13. Documented integration paths, scored honestly](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#integration-paths) — A source-by-source matrix with method, direction, owner, latency, and a named reference environment for each claim. - [ ] [14. Append-only history, period locking, and reproducible prior reports](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#audit-log) — A reproduction of one prior period report, its approval identities, its override history, and the retention and export terms in the contract. - [ ] [15. §1031 identification and earlier-of completion deadline monitoring](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#exchange-timers) — One disposition with both timers, the alert schedule, and the evidence attached to the entity record. - [ ] [16. Production references and honest maturity disclosure](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#production-references) — A dated capability register naming what is built, what is demonstrated, what is roadmap, and what is production-proven. ## Tax rules and review boundaries No more than 25% of the value of total REIT assets may consist of securities of one or more TRSs under IRC §856(c)(4)(B)(ii) for taxable years beginning after December 31, 2025 (Public Law 119-21 §70439). The amendment replaces 20% with 25%; earlier tax years require the applicable historical rule. This is a quarter-end securities asset-value limit, not a TRS gross-income cap. The annual 95% and 75% gross-income tests are separate; §856(l) defines TRS status and election. Tax counsel must confirm entity-specific application, valuation and relief. Asset tests are measured at statutory quarter-end; income and distribution requirements are tax-year tests. Entity structure, elections, relief and cure provisions require counsel. Sources: https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm ; https://www.law.cornell.edu/uscode/text/26/856 ; https://www.law.cornell.edu/uscode/text/26/857 ; https://www.law.cornell.edu/uscode/text/26/1031 Not tax, legal or investment advice. This is an evidence-review checklist, not a tax opinion, attestation or deployed SeniorCRE capability.