Canonical page: https://sequoia-research.com/writing/delaware-statutory-trust-1031-reviews-2026-when-old-rent-rolls-and-appraisals-need-a-closer-look
Author: Sequoia Research
Published: 2026-10-17T23:43:21.973Z
Updated: 2026-10-17T23:43:21.973Z

# Delaware Statutory Trust 1031 Reviews (2026): When Old Rent Rolls and Appraisals Need a Closer Look

## What Is This Article About?

This article explains when older property records need an update before a Delaware statutory trust (DST) purchase. A review of two 2026 offering documents shows how a value date, report date, and rent-roll date can differ. Original examples then trace later lease changes, unpaid rent, costs, and repairs into the assumptions a reviewer may be using. The goal is to identify the update that answers the open question, rather than assume every older report is wrong.

## Table of Contents

- [Start With the Claim You Need to Use Today](#start-with-the-claim-you-need-to-use-today)
- [What the Selected 2026 Documents Actually Disclose](#what-the-selected-2026-documents-actually-disclose)
- [Build a Record of Changes Since the Evidence Date](#build-a-record-of-changes-since-the-evidence-date)
- [Test What an Unchanged Occupancy Rate Can Hide](#test-what-an-unchanged-occupancy-rate-can-hide)
- [Match Rent-Roll Changes to Signed Lease Evidence](#match-rent-roll-changes-to-signed-lease-evidence)
- [Bridge Charged Rent to Collected Cash](#bridge-charged-rent-to-collected-cash)
- [Refresh Costs Alongside the Rent Assumptions](#refresh-costs-alongside-the-rent-assumptions)
- [Ask Whether the Appraisal Still Answers Your Question](#ask-whether-the-appraisal-still-answers-your-question)
- [Use a Sensitivity Model Without Rewriting the Appraisal](#use-a-sensitivity-model-without-rewriting-the-appraisal)
- [Check Later Damage and Repair Commitments](#check-later-damage-and-repair-commitments)
- [Choose the Right Kind of Follow-Up](#choose-the-right-kind-of-follow-up)
- [Write a Decision Note With Open Conditions](#write-a-decision-note-with-open-conditions)
- [Keep the Update Current Through the Decision Date](#keep-the-update-current-through-the-decision-date)
- [FAQ](#faq)
- [About Sequoia Research](#about-sequoia-research)
- [Sources](#sources)

## Start With the Claim You Need to Use Today

An older rent roll may still be the right record for a historical question. It can show which units were leased at acquisition or what rent the original forecast used. A current investment decision asks a different question: what has changed since that record, and does the change affect the plan being presented?

Begin with a specific claim. Perhaps a review says the property can support a stated rent budget. Perhaps it describes a reserve as enough to complete repairs. Or it cites an appraisal to support the property's value. Each claim needs a different update. A new occupancy summary cannot resolve an unpaid repair bill, and a recent property photo cannot verify rent collection.

Review each claim with the evidence that supports it. Record the claim, the source date, the later event, and the part of the conclusion that may change. This gives the reviewer a path from an older file to a current question.

Age alone does not decide the answer. A three-week-old rent roll could miss a major tenant departure yesterday. A much older site plan might still describe the same building layout. Refresh evidence when it matters to the decision or later events may have changed it.

That does not mean age can be ignored. The longer the gap, the more opportunity there is for unrecorded changes. It means the reviewer should explain why the older record remains useful, what later checks were made, and what remains unknown.

Private-placement disclosure can be limited. A public memorandum may mention records that were not obtained for the review. Missing public evidence does not prove that the sponsor lacks the record. It does limit what a reader can verify from that review. [SEC private-placement bulletin, updated September 21, 2026](https://www.investor.gov/introduction-investing/general-resources/news-alerts/alerts-bulletins/investor-bulletins/private-placements-under-regulation-d-updated-investor-bulletin)

This article's public-source cutoff is October 17, 2026. It checks selected disclosed dates, not current property operations. The worked cases are separate original illustrations. No later event described in those cases is an allegation about either named offering.

## What the Selected 2026 Documents Actually Disclose

The sample consists of two accessible offering memoranda. They were chosen because they identify dated property evidence. This is not a random market sample. These facts do not support a sponsor ranking.

**Passco Allure DST.** The May 1, 2026 PPM's cover note 19 identifies an April 8 appraisal report and a March 17 as-is value date. Note 20 attributes 98.57% occupancy to an April 27 rent roll. Printed page 65 separately identifies a March 23 rent roll for the subject property in a rent-comparison table. Those dates concern different parts of the packet. The later occupancy date does not refresh the appraisal or every comparison input. The underlying appraisal, both rent rolls, leases, and October operating records were not obtained here. [Passco Allure PPM, cover page v and printed page 65](https://qbkrvktefrncdppfqwyg.supabase.co/storage/v1/object/public/investment-documents/rec2aJXhMpuVPqp2L/146296582c94da53/Passco%20-%20Allure%20DST%20-%20PPM.pdf)

**NewStar 17 Sweetwater Springs, DST.** Its February 9, 2026 PPM identifies a December 29, 2025 appraisal report addressed to the lender and an as-is property value. The selected paragraph does not establish the valuation's separate effective date. The underlying appraisal and any October update were not obtained. The report date should therefore not be relabeled as a confirmed effective date. [NewStar PPM, printed page 14](https://pcsalts.com/wp-content/uploads/2026/03/NewStar-NewStar-17-Sweetwater-DST-Private-Placement-Memorandum-PPM.pdf)

These observations establish the dates disclosed in the selected passages. They do not establish that values fell, occupancy changed, or a required update was withheld. Nor do they show whether the offerings remain available. An investor considering a later purchase would need to obtain and assess the relevant later evidence.

For the first packet, the appraisal report and value dates are explicitly different. For the second, the selected summary leaves a key date unresolved. A responsible review preserves that difference. It should not fill an empty field merely to make two rows look comparable.

## Build a Record of Changes Since the Evidence Date

Start the update with a fixed baseline. Save the specific rent roll or report on which the prior conclusion relied. Record its title, property, relevant date, page, and version. If the baseline cannot be identified, the reviewer cannot reliably describe what changed.

Next, create a list of later events that could affect the claim. For rental income, that might include move-outs, new leases, rent credits, unpaid balances, or units removed from service. For value, it might include those operating changes plus major costs, damage, or new market evidence. For reserves, it might include payments and unpaid commitments.

Use one line per event. Separate the event date from the date the reviewer learned about it. A manager's October email might describe a move-out in August. The later email is the source; August is the event period. This distinction matters when testing a prior forecast or a current cash need.

A helpful record can be quite small:

| Question | Earlier support | Later event | Evidence needed |
|---|---|---|---|
| Which units produce rent? | Dated rent roll | Tenants changed | New roll and signed leases |
| Was billed rent collected? | Charge schedule | Unpaid balances grew | Cash application and aging records |
| What will insurance cost? | Prior policy budget | Renewal terms arrived | Bound policy or supported quote |
| What work remains? | Inspection and budget | Damage or completed work | Updated scope, bills, and payment record |
| What does the value opinion cover? | Appraisal and assumptions | Inputs changed | Qualified review of the affected assumptions |

Do not turn this list into a vote. Five unchanged minor facts cannot cancel one major unresolved issue. The effect depends on the particular claim, amount, timing, and rights involved.

FINRA's guidance for covered firms calls attention to new material developments during an offering and careful review of third-party work. It also warns against relying only on issuer statements. That supports following a change through to its evidence; this article's worksheet is not a substitute for a firm's duties. [FINRA Regulatory Notice 23-08, May 9, 2023](https://www.finra.org/rules-guidance/notices/23-08)

## Test What an Unchanged Occupancy Rate Can Hide

Consider fictional Cedar Mews, a 120-unit property. All property details, documents, amounts, and later events in this case are invented. They are not modeled results for either offering in the public sample.

The March 31 rent roll lists 114 occupied units and six vacant units. The September 30 roll also lists 114 occupied units and six vacant units. Both show 95% physical occupancy. That stable percentage does not tell us whether the same tenants remained or whether the rent terms stayed the same.

In this example, 12 of the original occupied units changed tenants during the interval. The other 102 remained occupied by their original tenants. The original six vacant units stayed vacant. The 12 replacement tenants were all in place by September 30, so the ending count still reconciles to 114 occupied units.

The March scheduled monthly rent was $1,800 for each occupied unit, or $205,200. By September, the 102 continuing tenants each have scheduled rent of $1,810. The 12 replacement tenants each have scheduled rent of $1,750. The ending monthly schedule is therefore $184,620 plus $21,000, or $205,620.

| Measure | March baseline | September update |
|---|---:|---:|
| Occupied units | 114 | 114 |
| Physical occupancy | 95% | 95% |
| Scheduled monthly rent | $205,200 | $205,620 |
| Known change in tenants | Baseline | 12 occupied units changed tenants |

Scheduled rent has risen by only $420 a month. Yet the tenant group and rent mix changed. A review that checks only the occupancy percentage would miss that shift.

Now add a stated future concession. Six of the replacement tenants have agreed October rent credits of $1,750 each. Those credits total $10,500. If all other October scheduled rent is paid on time, the expected October cash is $195,120. This is a budget assumption, not a claim that October collections have already occurred.

For a separate 12-month budget starting October 1, hold scheduled rent fixed, assume all amounts are paid, and allow only those October credits. Scheduled rent totals $2,467,440. After the credits, budgeted rent cash is $2,456,940. That is $5,460 below 12 months of the old $205,200 monthly schedule, despite the slightly higher new face rent.

The example does not predict a year of unchanged leases. It shows why a current review needs the changed terms as well as the occupied-unit count. A temporary credit should not be mistaken for a permanent monthly reduction or silently ignored.

## Match Rent-Roll Changes to Signed Lease Evidence

A newer rent roll is a useful starting point. It still needs support for material changes. Ask which signed lease, amendment, termination, or other record supports each changed row. A spreadsheet label is not the same thing as the underlying agreement.

For Cedar Mews, suppose the reviewer receives ten of the 12 replacement lease files. The ten received files support the dates and amounts shown for those units. The other two remain missing. The correct finding is limited: ten files were checked, and two new lease rows remain unverified.

At $1,750 each, the two unverified rows account for $3,500 of the $205,620 scheduled monthly rent. The other rows total $202,120 under the case's supplied records. Unknown support for $3,500 does not prove that amount is zero, uncollectible, or fraudulent. It means the conclusion about the full schedule is incomplete.

Keep a documented-only view separate from a conditional full-schedule view. The first can show the amounts supported by the records reviewed. The second can show what the model would use if the missing terms are confirmed. Neither is a prediction of actual collections.

The reviewer should also inspect the details most likely to change the claim. For the October credits, confirm the covered month, amount, conditions, and whether the credit is already reflected in a net-rent column. Subtracting it again from a net number would create an error in the other direction.

Match units with stable identifiers. A tenant spelling change does not necessarily mean a new lease. A unit renumbering does not necessarily mean new space. Preserve the connection to the earlier row and explain any mapping that requires judgment.

If a manager says the missing files are unchanged from an earlier package, request the exact files and identify the relevant versions. Repeated copies of one unsigned draft do not become separate confirmations. The purpose is to resolve the terms, not to increase the document count.

## Bridge Charged Rent to Collected Cash

A rent roll can describe contractual charges while cash records show a different amount collected. A current rent review should connect those two records instead of treating a scheduled dollar as a dollar already in the account.

Use a separate September ledger illustration. It does not add another loss to the October-credit case. Assume Cedar Mews starts September with $18,000 of rent owed. September charges are $205,620. Cash applied to those balances is $198,000, and supported credits or adjustments total $3,620. No other entries occur.

Ending amounts owed are $18,000 plus $205,620, less $198,000 and $3,620, or $22,000. The balance owed grew by $4,000. The charge schedule and the cash record can both be correct while describing different things.

The $198,000 includes whatever current and older balances the case's cash ledger assigns to those receipts. Do not assume it all pays September charges. Ask how cash was applied, which balances remain unpaid, and whether deposits or unrelated receipts were kept outside the rent ledger.

Aging information adds another question: how long have those balances been unpaid? Two properties with the same $22,000 total may have very different collection problems. One balance could be newly due. Another could be concentrated in older accounts with unresolved disputes. The total alone cannot establish the chance of collection.

For a later decision, request a cutoff date and subsequent receipts through a stated date. A collection after the cutoff can help assess a balance, but should not be backdated into the earlier cash total. The later evidence answers a later question.

This also limits what occupancy can tell the reviewer. A unit can be occupied while its rent is unpaid. A property can have a strong physical occupancy rate and still face a cash gap. The review needs both the right measure and the evidence behind it.

## Refresh Costs Alongside the Rent Assumptions

Refreshing rent while leaving every cost at its original level can create a misleading improvement. Review the costs affected by later events, especially where the original plan used an estimate that has since been replaced by a bill, contract, or renewal.

Return to Cedar Mews's recurring rent schedule, leaving the separate October credits and September collection ledger aside. The $420 monthly increase equals $5,040 over 12 months. Suppose a supported insurance renewal raises the modeled annual cost from $120,000 to $156,000. That $36,000 increase exceeds the rent increase by $30,960.

If all other recurring income and costs remain fixed, annual net operating income would fall by $30,960. Net operating income, or NOI, is income after the operating costs defined in the model. Here it excludes debt payments, capital work, and investor-level charges. The calculation says nothing about those other cash needs.

The update should show both changed inputs. Reporting only the higher rent schedule would omit the larger expense change. Reporting only the expense increase would miss the small offset. Neither selective view describes the stated model.

Some costs will remain uncertain. A pending tax assessment is not zero simply because the new bill has not arrived. A quote subject to underwriting is not the same as a bound insurance policy. Keep each amount's status next to the number and use separate cases where a range matters.

Check when each cost takes effect. A renewal on October 1 affects a different period from a renewal halfway through the next year. A full-year run rate helps compare recurring levels; it does not automatically equal cash due during the next 12 months.

The SEC cautions that performance methods, costs, and assumptions affect what a result means. The same care applies when a property update feeds a forecast. A revised budget remains hypothetical even when some of its inputs now have better support. [SEC performance bulletin, September 15, 2022](https://www.investor.gov/introduction-investing/general-resources/news-alerts/alerts-bulletins/investor-bulletins-47)

## Ask Whether the Appraisal Still Answers Your Question

An appraisal is a value opinion for a defined assignment. Read what property interest it covers, the value basis, effective date, intended use, and key assumptions. A date on the delivery email cannot answer those questions.

An as-is opinion and a future stabilized opinion need not describe the same condition. Stabilized value may depend on leasing, construction, or other steps that have not occurred. If a reviewer uses that figure to describe today's property, the unfinished steps and their costs need to remain visible.

The December 2010 interagency appraisal guidelines distinguish the report date from the effective date. They also discuss whether existing valuation work still reflects the property and market, considering later changes. This is banking guidance, used here for its review framework. It does not create a universal expiration date for every DST appraisal. [Interagency Appraisal and Evaluation Guidelines, section XIV and glossary](https://www.occ.gov/news-issuances/federal-register/2010/75fr77450.pdf)

For a later purchase decision, ask what changed in the assumptions supporting the opinion. Did a key lease end? Did costs rise? Was planned work delayed? Did a later event affect the building? Has new market evidence changed the context? A documented review should connect the event to the affected assumption.

Also ask whether the person reviewing the value has the full report. A PPM paragraph may identify a figure and date without reproducing the analysis, limiting conditions, or exhibits. Reading that summary is not the same as reviewing the appraisal itself.

A lender's use of a report does not answer every investor question. The investor may be paying an offering price that includes fees, reserves, and other amounts. A property-value opinion is not automatically an opinion of the investor's interest, cash proceeds on resale, or expected return.

Where a new opinion is needed, the proper response is qualified valuation work with a clear scope. A reader should not alter the original report's value, paste in a new date, or describe a personal sensitivity calculation as an appraiser's revised conclusion.

## Use a Sensitivity Model Without Rewriting the Appraisal

A sensitivity model can show why an update matters while leaving the formal value opinion untouched. The model should identify its inputs and exclusions, and should not imply that its output is a new appraisal.

Use an original property model with $3 million of annual income and $1.2 million of operating costs. The income includes rent and other property income. NOI is $1.8 million. At a chosen 6% capitalization rate, dividing NOI by the rate gives $30 million. The rate is an invented valuation input, not a current market quote or forecast.

Apply only the recurring rent and insurance changes from the prior example. NOI falls by $30,960 to $1,769,040. At the same 6% rate, the model gives $29,484,000. The income change reduces this calculated value by $516,000.

Next, test a separate chosen rate of 6.5% with that same updated NOI. The result is $27,216,000. Moving the rate after updating NOI reduces the model by another $2,268,000. Together, the two changed inputs produce a $2,784,000 decline from the starting calculation.

| Sensitivity step | NOI | Chosen cap rate | Calculated property value |
|---|---:|---:|---:|
| Starting assumptions | $1,800,000 | 6.00% | $30,000,000 |
| Updated recurring income and costs | $1,769,040 | 6.00% | $29,484,000 |
| Same updated NOI, alternate rate | $1,769,040 | 6.50% | $27,216,000 |

This sequence isolates the effects in a stated order. It does not prove which factor caused a real market price to change. It also omits debt, selling costs, trust cash, taxes, and investor fees. The final column is therefore neither owner equity nor sale cash.

The temporary October credits, September unpaid-rent case, and later roof example are outside this recurring-income model. Adding them would require a new, coherent set of assumptions. The model does not quietly combine every adverse event in the article.

The practical result is a question for the review: does the current conclusion depend on an income or rate assumption that later evidence may no longer support? That question can justify further work without claiming a new valuation has already been completed.

## Check Later Damage and Repair Commitments

A clean earlier inspection cannot establish that no damage occurred later. When a new event is reported, identify its date, affected areas, current status, and the evidence needed to assess it. The review should be proportionate to the issue and use qualified inspection where needed.

Consider a separate invented roof case. An earlier budget contained an $80,000 roof allowance. After later damage, a new supported scope replaces that work with a $210,000 total project. The new total includes the old scope. It is not an additional $210,000 on top of the old allowance.

The increase from the old budget is $130,000. Suppose $50,000 of the new project's cost has already been paid. The remaining amount to pay is $160,000. If the relevant reserve had $220,000 before that payment, it now holds $170,000 and would have $10,000 left after paying the remainder.

Subtracting the full $210,000 from the already reduced $170,000 would count the $50,000 payment twice. Adding $80,000 to the replacement scope would also overstate the stated project. A current review needs the scope, invoices, paid amounts, and unpaid balance together.

Those numbers do not prove that the reserve may legally fund the work or that the price cannot change. They describe a cash reconciliation under supplied assumptions. Restrictions, approval needs, contract limits, and other committed uses require separate evidence.

Do not net an expected insurance claim against the bill unless its amount and timing are supported for the case being modeled. A claim under review is not money in the account. Keep a confirmed-funds case and a clearly conditional recovery case separate.

Photos and a manager's summary can help locate an issue. They do not necessarily establish the cause, full repair scope, structural condition, or completion. Request evidence suited to the question rather than treating every new document as equally useful.

## Choose the Right Kind of Follow-Up

The update request should name the gap it is meant to close. “Send a newer report” can produce a recent file that repeats old facts. “Show the changes to these lease rows and the signed support” is more likely to resolve the rent question.

A narrow factual correction may need a corrected schedule and an explanation. A missing lease term may need the signed agreement. A disputed expense may need the bill and payment terms. A changed physical condition may need a focused inspection. A value question may need a qualified appraisal review or a new assignment.

Keep the response's scope in view. A letter confirming that no known leases were amended does not establish that every tenant paid on time. A contractor's completion notice does not prove the invoice was paid. A new valuation summary may not include the full report needed to assess its assumptions.

Ask who supplied the response and what they checked. Direct operating records can be useful without being an independent audit. An outside expert's report can be useful without covering every issue. The title or letterhead does not expand the work actually performed.

Avoid letting an exchange deadline decide whether missing evidence exists. The calendar may constrain the available choices, but it cannot turn a missing record into a verified fact. Tell the responsible professionals which conclusion depends on the unresolved point and when the decision is expected.

The review should leave a clear trail: question sent, record received, part reviewed, conclusion changed or unchanged, and remaining conditions. This is how the next reader can understand why a file was marked useful without assuming that the whole investment received a passing grade.

## Write a Decision Note With Open Conditions

A useful decision note states the answer at the level supported by the evidence. For Cedar Mews, it might say that occupied-unit counts reconcile while two replacement lease files remain unverified. It can also state that the supplied new insurance cost exceeds the scheduled rent increase under the stated recurring model.

That note should not become “the property is safe” or “the property has failed.” It describes what was checked, the financial effect under chosen assumptions, and what evidence is still needed. Broader judgments require more than this property update.

Separate facts from decisions. A lease file may confirm the lower rent. Whether the investor can accept the resulting cash plan is a different question. A supported repair estimate may settle the cost question. It can also leave a smaller reserve than the investor expected.

Record which open issues are essential to a particular conclusion. If the expected payment depends on a pending receipt, the conclusion should remain conditional on that receipt. If a value statement depends on unreviewed assumptions, identify them rather than burying the limitation in a general footnote.

A later answer may narrow the gap without eliminating it. Receiving the two missing leases can settle the rent terms, but it does not settle tenant credit, collection, or future renewal. Closing one question should not automatically close every question linked to the same property.

## Keep the Update Current Through the Decision Date

A review is completed at a point in time. Preserve that cutoff and identify later events that would reopen a material question. An update process helps the reader respond to change without rebuilding every section from scratch.

Use specific triggers tied to the analysis: a major lease change, a new cost, damage, a missed receipt, or a revised value assumption. These are examples, not a universal monitoring schedule. The scope depends on the property, documents, and decision being made.

When new evidence arrives, save it as a new version. Record whether it changes an amount, a date, a condition, or only the support for an unchanged input. Recalculate affected tables and check the article's summary and FAQs for stale conclusions.

Keep the historical record intact. An accurate March statement does not become false merely because September changed. A later review should explain the change rather than erase the earlier source. This preserves the distinction between a bad earlier assumption and a later event that could not be known then.

The final result is a review a reader can follow: the starting evidence, the changes, the affected assumptions, and the unresolved work. A newer date on its cover matters only if that work has actually been done.

## FAQ

### How Old Can a DST Rent Roll Be Before It Is Unusable?

There is no universal age limit established by this article. Start with the decision and the changes that could affect it. A recent major lease event may require an update quickly, while an older roll can remain useful as a historical baseline. State the date and obtain the support needed for the current claim.

### Does a New PPM Date Mean the Appraisal Was Updated?

No. A memorandum can include an earlier appraisal and several other evidence dates. Check the appraisal's report date, effective date, and scope separately. The selected 2026 documents illustrate why the cover date should not replace those fields.

### Why Review Lease Changes if Occupancy Is the Same?

The same occupied-unit count can contain different tenants, rents, credits, and collection risks. The Cedar Mews illustration keeps occupancy at 95% while tenant turnover and rent terms change. Compare the underlying rows and support the changes with the relevant records.

### Can I Treat Rent Shown on a Roll as Cash Received?

No. Scheduled charges, amounts owed, and applied cash are different measures. Reconcile the charge schedule with cash records and supported credits. Preserve the cutoff and distinguish later collection from money received during the period being reviewed.

### Can a Simple NOI Model Replace an Appraisal?

No. A sensitivity model shows how selected assumptions affect a calculation. It does not perform a full valuation assignment or revise the appraiser's opinion. Label the model, its chosen rates, exclusions, and limits; seek qualified work where the value question requires it.

### What if the Sponsor Says Nothing Material Has Changed?

Record the statement, its date, who made it, and what it covers. Then seek support suited to the claim you need to use. A statement about lease terms does not automatically verify collections, repair costs, or market value. The scope of the answer matters as much as its recency.

### Does This Article Find That Either Named Offering Has Stale or False Data?

No. The public check identifies selected dates and missing underlying evidence within this review's scope. It does not verify October operations or establish that a required update was withheld. All later events, costs, cash schedules, and value sensitivities are separate invented examples.

## About Sequoia Research

Sequoia Research, LLC provides independent research on DSTs and other real estate investment offerings. This educational article explains how dated property evidence can be assessed for a later decision. Its limited public-document observations and original examples do not provide an individual investment, appraisal, legal, or tax conclusion.

## Sources

1. [Passco Allure DST PPM](https://qbkrvktefrncdppfqwyg.supabase.co/storage/v1/object/public/investment-documents/rec2aJXhMpuVPqp2L/146296582c94da53/Passco%20-%20Allure%20DST%20-%20PPM.pdf), May 1, 2026; cover page v and printed page 65. Public copy downloaded and selected pages inspected October 17, 2026.
2. [NewStar 17 Sweetwater Springs DST PPM](https://pcsalts.com/wp-content/uploads/2026/03/NewStar-NewStar-17-Sweetwater-DST-Private-Placement-Memorandum-PPM.pdf), February 9, 2026; printed page 14. Primary text and retained same-source page image inspected October 17, 2026.
3. [Interagency Appraisal and Evaluation Guidelines](https://www.occ.gov/news-issuances/federal-register/2010/75fr77450.pdf), December 10, 2010; section XIV and glossary. Banking scope, used for dated-value and changed-assumption concepts. Inspected October 17, 2026.
4. [FINRA Regulatory Notice 23-08](https://www.finra.org/rules-guidance/notices/23-08), May 9, 2023; covered firms' investigation and third-party review. Inspected October 17, 2026.
5. [SEC Private Placements Under Regulation D](https://www.investor.gov/introduction-investing/general-resources/news-alerts/alerts-bulletins/investor-bulletins/private-placements-under-regulation-d-updated-investor-bulletin), August 17, 2022; updated September 21, 2026. Inspected October 17, 2026.
6. [SEC Performance Claims](https://www.investor.gov/introduction-investing/general-resources/news-alerts/alerts-bulletins/investor-bulletins-47), September 15, 2022; methods, costs and hypothetical results. Inspected October 17, 2026.


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