Canonical page: https://sequoia-research.com/writing/delaware-statutory-trust-fees-2026-what-to-compare-across-competing-offerings
Author: Sequoia Research
Published: 2026-10-17T04:18:44.914Z
Updated: 2026-10-17T04:18:44.914Z

# Delaware Statutory Trust Fees (2026): What to Compare Across Competing Offerings

## What Is This Article About?

This article compares selected upfront costs in two DST offering documents dated in 2026. It puts those costs on the same basis and explains which charges the comparison leaves out. Separate, invented examples show how debt, annual fees, sales terms, and fee credits can change a broader comparison. The aim is to help you ask better cost questions before choosing between offerings.

## Table of Contents

- [Start With a Defined Fee Comparison](#start-with-a-defined-fee-comparison)
- [A Two-Offering Sample of 2026 DST Fee Disclosures](#a-two-offering-sample-of-2026-dst-fee-disclosures)
- [Put DST Fees on the Same Denominator](#put-dst-fees-on-the-same-denominator)
- [Keep the Cost Categories Consistent](#keep-the-cost-categories-consistent)
- [Compare Broker Compensation and Fee Credits](#compare-broker-compensation-and-fee-credits)
- [Find Acquisition Charges Embedded in the Price](#find-acquisition-charges-embedded-in-the-price)
- [Separate Financing Costs From Cash Reserves](#separate-financing-costs-from-cash-reserves)
- [Model Annual Management Fees Over the Same Period](#model-annual-management-fees-over-the-same-period)
- [Test Exit Fees Under Several Sale Outcomes](#test-exit-fees-under-several-sale-outcomes)
- [Include the Account and Advice Costs](#include-the-account-and-advice-costs)
- [Write a Comparison That Another Reader Can Check](#write-a-comparison-that-another-reader-can-check)
- [Frequently Asked Questions](#frequently-asked-questions)

## Start With a Defined Fee Comparison

The first question is not which DST has the lowest fee. It is which costs are inside the figure you are comparing. A small percentage can cover one charge. A larger percentage can cover several. Unless you match their scope, the difference may say more about the labels than the economics.

For a useful comparison, choose the offerings, document dates, purchase route, and cost categories first. Then calculate each result. Keep costs at purchase, costs during ownership, and costs at sale in separate groups. You can later combine them under stated assumptions, but each group should remain visible.

The SEC's July 2025 fee bulletin points investors to both product and account disclosures. It identifies offering documents, fee schedules, and account records as places to check. A product comparison can therefore be accurate within its scope and still miss charges from the investor's account. [SEC: How Fees and Expenses Affect Your Investment Portfolio](https://www.investor.gov/introduction-investing/general-resources/news-alerts/alerts-bulletins/investor-bulletins/updated)

This article starts with a narrow, real comparison: selected upfront costs in two public copies of 2026 private placement memorandums, or PPMs. It does not measure the whole DST market. It does not rank sponsors, confirm that interests remain available, or tell a reader which investment to buy.

The source check was completed on October 16, 2026. The dates on the documents are earlier. Those dates serve different purposes. The check date records when this review occurred. It does not make an old budget a current invoice or prove that no later supplement exists.

After the named sample, all numerical cases are original teaching examples. They are not forecasts for the two named offerings. This separation matters: a clear model can explain a fee formula without having enough evidence to predict an actual investor's result.

## A Two-Offering Sample of 2026 DST Fee Disclosures

The sample contains NewStar 17 Sweetwater Springs, DST, and Passco Allure DST. They were selected because public PPM copies dated in 2026 provided usable fee details. This is a document-access sample of two offerings, not a random sample or a list of leading sponsors.

The following figures use the full offering budgets before any investor-specific reduction. Dollar figures are as printed. “Sales network” combines the listed commissions, dealer charges, and related sales allowances; it is a comparison category used here.

| Item | NewStar 17 Sweetwater Springs | Passco Allure |
|---|---:|---:|
| PPM date | February 9, 2026 | May 1, 2026 |
| Maximum equity offering | $21,808,522 | $58,575,000 |
| Loan proceeds | $17,600,000 | $48,350,000 |
| Sales network costs | $1,962,767 | $4,480,988 |
| Organization and offering costs | $271,766 | $286,000 |
| Selected combined costs | $2,234,533 | $4,766,988 |
| Selected costs divided by equity | 10.25% | 8.14% |

NewStar's sales rows use 6% and 3%; Allure's use 5%, 0.5%, 1.15%, and 1%. The table combines those rows, then adds each document's organization costs. Both documents allow certain commission reductions. Consult the full terms for eligibility and treatment. [NewStar PPM, printed pages 2 and 43–46](https://pcsalts.com/wp-content/uploads/2026/03/NewStar-NewStar-17-Sweetwater-DST-Private-Placement-Memorandum-PPM.pdf), [Passco Allure PPM, cover notes and printed pages 48–49](https://qbkrvktefrncdppfqwyg.supabase.co/storage/v1/object/public/investment-documents/rec2aJXhMpuVPqp2L/146296582c94da53/Passco%20-%20Allure%20DST%20-%20PPM.pdf)

One further difference shows why these selected totals cannot rank overall costs. NewStar lists a separate $578,638 sponsor acquisition fee. Allure describes a $2,295,000 affiliate advisory fee built into a $94,095,000 purchase price, grossed up from $91,800,000. That embedded amount should not be added to the gross price again. [NewStar PPM, printed page 46](https://pcsalts.com/wp-content/uploads/2026/03/NewStar-NewStar-17-Sweetwater-DST-Private-Placement-Memorandum-PPM.pdf), [Passco Allure PPM, cover and printed page 48](https://qbkrvktefrncdppfqwyg.supabase.co/storage/v1/object/public/investment-documents/rec2aJXhMpuVPqp2L/146296582c94da53/Passco%20-%20Allure%20DST%20-%20PPM.pdf)

For this selected cost group, the two observed results span about 8.14% to 10.25% of equity. That range describes these two budgets only. It excludes acquisition-related compensation, financing and carrying costs, ongoing expenses, exit costs, and account charges. It is neither a typical DST fee range nor a finding about lifetime value.

No full lifetime cost ranking is made. We did not obtain every later amendment, each reader's subscription terms, or their account agreement. A current decision requires those records as well as a review of the property, debt, and other risks.

## Put DST Fees on the Same Denominator

A denominator is the amount below the line in a fraction. In a fee comparison, it answers “a percentage of what?” The same dollar charge can look small or large when you change that amount.

For the named sample, the formula is selected costs divided by maximum equity. We use the printed dollar amounts rather than adding already rounded percentages. Results are rounded only after division. This keeps rounding from becoming an unexplained difference between the worksheet and the source table.

Now consider two entirely fictional offerings, Linden and Birch. Each has a $12 million equity budget. Linden also has an $8 million loan; Birch has a $16 million loan. Both budget a $960,000 sales charge.

On an equity basis, each charge is 8%: $960,000 divided by $12 million. On an equity-plus-debt basis, Linden shows 4.8% and Birch shows about 3.43%. The second number is smaller because its denominator includes more debt. The charge did not fall.

That change does not establish that either debt level is wise. It only shows why a cost table should identify the funding base. Debt adds its own obligations and risks. Counting loan proceeds below a fraction cannot make the sales expense disappear.

Use the equity basis to describe the selected charge relative to investor capital. Keep the total funding basis when it helps reconcile the project's sources and uses. Each can be useful, provided it is named and applied the same way to both offerings.

For a separate hypothetical $250,000 proportional interest, an 8% allocation equals $20,000. That is a scaling example under uniform ownership and fee assumptions. It is not a claim that every investor receives a separate bill or that every subscription uses the same price.

Also keep appraised value separate from purchase price and total funding. Those numbers answer different questions. A comparison can show each one, but it should not replace a missing appraisal with a purchase price and retain the appraisal label.

## Keep the Cost Categories Consistent

Choose a category because the costs perform a similar function, not because the headings look alike. A sales group may include commissions, marketing allowances, placement charges, and dealer compensation. Another document may put some of those items in a larger group with legal or organization expenses.

Build a short mapping beside the comparison. Keep the source's name for each charge, then add your chosen category. This lets a later reviewer move from the clean table back to the original language. It also leaves room for a cost that does not fit neatly.

In a fictional comparison, Pine shows a 6% selling commission and a 2% dealer fee. Elm shows a 5% commission, a 1% placement charge, and a 2% marketing allowance. Each totals 8% under the stated terms. Calling Elm cheaper because its commission is lower would ignore the other sales charges.

Suppose Pine then lists 1% in organization costs while Elm lists 0.4%. The selected sales-plus-organization totals are 9% and 8.4%. On the same $10 million equity base, those amounts are $900,000 and $840,000. The $60,000 difference is real within this selected group.

The next step is to check exclusions. If Elm has a separate $200,000 acquisition charge that Pine does not have in this invented case, that broader comparison changes. Adding only that charge makes Elm's selected expanded amount $1,040,000. It does not make either figure a complete cost total unless all relevant costs have been mapped.

A missing field should say “not established.” A confirmed zero requires evidence that the charge does not apply within the defined scope. A charge included elsewhere should point to its existing row. These states prevent a blank cell from quietly giving one offering an advantage.

Do not add both a subtotal and its components. If the worksheet includes the commission, placement charge, and marketing allowance, the sales subtotal is a check. It is not a fourth payment. Give each actual economic charge one place in the sum, even if several source pages describe it.

## Compare Broker Compensation and Fee Credits

The quoted rate, the maximum permitted rate, and the amount actually charged can differ. A useful comparison shows which one it uses. A budgeted full-rate example should not appear beside a negotiated quote without a clear note.

Start with the same route for both offerings where possible. For example, compare two stated full-rate budgets, then compare two written quotes available to the same investor. If only one quote has arrived, preserve that mismatch. Do not assume the second firm will match a proposed reduction.

Use an original case to see the issue. A fictional interest has a $100,000 stated price and a $6,000 commission built into that price. A written offer reduces the price by $2,000 while preserving the same ownership interest. Under those assumed terms, the investor pays $98,000 for that interest.

The reduced price is 2% below the stated $100,000 price. But $2,000 divided by the $98,000 actually paid is about 2.04%. Neither percentage describes an annual return. Each merely measures a one-time difference against a different base.

If a forecast shows $5,000 in annual cash for that unchanged interest, the stated cash rate is 5% on $100,000. It is about 5.10% on $98,000. The payment has not increased. Only the cash denominator changed. This example does not predict that the forecast payment will occur.

Real terms may work differently. A reduction could affect the price, interest size, dealer payment, or another line. Ask for a written explanation of the exact treatment. Do not assume a waiver creates a cash refund or that it leaves all ownership rights unchanged.

For broker recommendations to retail customers, FINRA describes obligations to understand risks, rewards, and costs. It also discusses written disclosure of material fees and relevant conflicts. A cost comparison helps frame those questions, but a completed worksheet is not proof that a recommendation meets every duty. [FINRA Regulatory Notice 23-08](https://www.finra.org/rules-guidance/notices/23-08)

## Find Acquisition Charges Embedded in the Price

A purchase-related charge may sit in its own fee row, within a larger acquisition amount, or in a payment made by another party at closing. Trace the dollars before deciding whether the item belongs in your total.

Here is a separate fictional case. A seller expects $20 million net. The agreement adds a $500,000 advisory charge to the stated purchase price, making that price $20.5 million. At closing, the seller pays the advisory charge from those proceeds.

The total price already includes the $500,000. Adding it again produces $21 million and overstates the assumed payment by $500,000. The comparison should show $20.5 million as the gross price, with $500,000 identified inside that amount.

At the same time, a separate compensation analysis may count that $500,000 as a payment to the adviser. That is not double counting if the table clearly answers who receives compensation and does not add the amount a second time to total uses. The purpose of the table controls the sum.

For this case, the charge is 2.5% of the $20 million net price. It is about 2.44% of the $20.5 million gross price. With $10 million of equity, it is 5% of equity. All three calculations describe the same $500,000 payment.

Keep the base in the column heading. “Acquisition fee: 2.5%” by itself is too thin to compare. It leaves the reader guessing whether the rate applies to net price, gross price, total funding, or another amount.

An embedded charge also does not prove that the property was fairly or unfairly priced. That is a separate valuation question. Review the price, property facts, appraisal scope, and comparable evidence on their own terms. A fee map can reveal the cash path without answering every question about value.

## Separate Financing Costs From Cash Reserves

Loan fees and cash reserves can both reduce money available for other uses at closing. They are not the same type of item. A fee pays for something; a reserve may remain an asset that will later fund expenses or be released under stated terms.

Compare financing charges on their contractual base first. In an invented pair, Cedar pays a 1% financing fee on a $10 million loan. Maple pays 0.75% on a $16 million loan. The dollar charges are $100,000 and $120,000. The lower rate produces the larger amount because the loan is larger.

If both raise $12 million of equity, those fees equal about 0.83% and 1% of equity. Show both views: the loan-based rate explains the contract, while the equity-based amount helps compare the burden relative to investor capital. This does not compare all benefits or risks of the loans.

Keep interest-rate buydowns, legal charges, lender fees, and reserve deposits identifiable. A combined line may hide different cash paths. Ask what is spent at closing, what remains in an account, who controls that account, and what must happen before cash can be used.

Suppose one fictional offering sets aside $600,000 for repairs and another sets aside $200,000. Calling the first offering $400,000 more expensive misses the nature of those funds. The real questions include the repair needs, timing, access, and who bears a shortfall.

Neither should the entire reserve be counted as freely available cash. Some funds may have a restricted use. An unfunded promise to contribute is also different from money already on deposit. Preserve those differences in the comparison instead of combining every reserve-related line under “cash.”

For a simple reconciliation, a $20 million funding budget might cover a $17.8 million property payment, $1.2 million in spent charges, and $1 million retained in reserves. The uses total $20 million. Describing all $2.2 million outside the property payment as fees would erase the retained reserve.

## Model Annual Management Fees Over the Same Period

Ongoing fees need a time model. A first-year amount can look low because of a waiver or a rising schedule. A lifetime comparison needs the full formula, a holding period, and the base to which the fee applies.

Begin with this fictional pair, separate from all prior cases. Oak charges $80,000 each full year. Willow charges $40,000 in year one and $90,000 in each later full year. Assume no inflation, deferral, other charges, or partial years.

| Holding period | Oak's cumulative fee | Willow's cumulative fee |
|---|---:|---:|
| Three years | $240,000 | $220,000 |
| Five years | $400,000 | $400,000 |
| Seven years | $560,000 | $580,000 |

Willow is lower over three years, equal over five, and higher over seven. The first-year comparison cannot answer which costs less over an unknown holding period. These are nominal cash totals: they do not adjust for when the payments occur or for returns on retained money.

For a 1% proportional interest under these assumed terms, the five-year allocation is $4,000 in either case. That figure is not a claim that the investor receives a separate annual bill. It translates the entity-level fee into an assumed economic share.

A revenue-based fee needs another input. Suppose a separate contract charges 2% of annual collected revenue. At $3 million of revenue, the fee is $60,000. At $2.4 million, it is $48,000. A fixed $60,000 contract would not fall with revenue under the same assumptions.

That difference can matter during a weak year. It does not tell you which manager provides better service, or whether either arrangement is fair. Compare the required work, payment terms, and conflicts as well as the arithmetic.

Read waivers closely. A permanent waiver cancels a specified amount under its terms. A deferral moves payment to a later date. In a fictional three-year plan, deferring a $20,000 first-year fee until sale does not reduce the total $60,000 obligation if the other two annual fees remain $20,000 each. It changes timing.

Keep projected annual fees separate from realized expenses. A budget is an estimate based on stated assumptions. Later statements may show what was actually charged. Mixing a realized three-year record for one offering with a five-year forecast for another produces no clean cost comparison.

## Test Exit Fees Under Several Sale Outcomes

Exit costs depend on the sale terms, the loan balance, and the fee rules in force. A comparison should state whether a charge uses gross property price, net proceeds, profit, or a threshold. It should also identify charges that apply only after a specific condition is met.

Consider two invented contracts on otherwise identical simplified sales. Contract A charges 1.5% of gross price, with no threshold. Contract B charges 2%, but only if the gross price exceeds $20 million. Assume a $10 million loan payoff and other sale costs equal to 3% of gross price.

At an $18 million sale, A's fee is $270,000. After that fee, $540,000 in other costs, and the loan payoff, $7.19 million remains. B's fee is zero under its stated condition, leaving $7.46 million.

At a $24 million sale, A's fee is $360,000 and B's is $480,000. Other sale costs are $720,000 in each case. The remaining cash is $12.92 million for A and $12.8 million for B. Which contract leaves more cash changes with the outcome.

These amounts omit taxes and any other liabilities. They also omit prior distributions. They are residual sale cash under an invented model, not investor profit or total return. To calculate profit, you would need the investor's contributions, ownership share, and all relevant receipts and costs.

Check the threshold's exact language. “Exceeds $20 million” is different from “at least $20 million.” A trigger based on net price is different from one based on gross price. If the source does not define the term clearly, do not repair it by guessing.

Also ask whether one fee offsets another. A sponsor disposition fee may be separate from a third-party sales commission, or a contract may provide a specific credit. Only the governing terms can establish the treatment. A similar phrase in another offering does not supply the answer.

For an actual comparison, preserve unresolved contract conflicts beside the result. You can model alternate readings to show why the issue matters. Label each reading as an assumption, and leave the final contractual conclusion open until the appropriate source resolves it.

## Include the Account and Advice Costs

Investors can reach an offering through different account arrangements. A product fee schedule does not by itself show the whole cost of that relationship. Ask which account fees apply to this asset, how they are calculated, and whether a stated credit lasts for the full holding period.

The SEC fee bulletin encourages investors to ask about account and product costs, payment methods, and available reductions. Those questions belong alongside the PPM review. They do not establish that any particular reduction is available to a reader. [SEC fee questions for investors](https://www.investor.gov/introduction-investing/general-resources/news-alerts/alerts-bulletins/investor-bulletins/updated)

Use a fictional $200,000 account solely to compare two stated fee paths. Route A charges $8,000 at purchase and $250 at each year-end. Route B charges $2,000 at purchase and 0.75% each year on an assumed constant $200,000 billed value. All other charges and services are equal in this model.

Over four years, A costs $9,000 and B costs $8,000. Over eight years, A costs $10,000 and B costs $14,000. The results change because B's assumed annual charge is $1,500. Neither total includes investment gains, losses, taxes, or the time value of money.

The constant billed value is an assumption, not a prediction. A real advisory agreement may use a different value, billing date, asset exclusion, or minimum fee. If the amount varies, calculate it period by period. Do not present a fixed-value example as a quote for an actual account.

Service scope matters too. One route may include work the other does not. List the promised services separately, then ask how their value relates to the investor's needs. A cost comparison should not award points for an unverified claim of better access or advice.

Watch for overlapping payments. If the product budget already includes a charge that is later credited against an account fee, trace the credit once. An unsigned proposal is not an applied credit. Retain the agreed terms and compare them with the eventual statement when available.

## Write a Comparison That Another Reader Can Check

A strong final comparison contains a finding, its scope, and the evidence needed to repeat it. It should be possible for another person to follow the source rows, redo the sums, and understand which conclusion the data supports.

For each offering, record the legal issuer name, class, document date, page, and fee route. Keep original dollar amounts and formulas. Add the chosen category and common denominator in separate columns. That preserves the difference between a source fact and your analysis.

State the exclusions near the result. A selected entry-cost comparison should say that annual and sale costs are outside its scope. A projected seven-year model should name the holding period and uncertain inputs. A statement of actual fees should identify the period and account covered.

When evidence is missing, write a specific follow-up. “Need more information” is hard to act on. “Need the signed terms showing whether the dealer credit reduces the price or changes the interest size” points to a document and a decision.

Keep uncertainty separate from risk. An unknown charge is an evidence gap. A known fee tied to future revenue is a defined formula with an uncertain amount. Both need attention, but the next step differs. The first needs a source; the second needs a scenario.

The SEC warns that private placements can involve limited disclosure and illiquidity. A well-organized fee file does not remove those risks. Cost review belongs within the wider investment review, including the property, financing, legal terms, and the investor's own situation. [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)

Before signing, update the comparison for new supplements and the actual subscription route. Preserve the earlier version so each change has a clear cause. The useful output is a set of supported cost findings and remaining questions, rather than a single number stripped of its assumptions.

## Frequently Asked Questions

### What is the best basis for comparing upfront DST fees?

Start with the same cost categories divided by the same base. Equity is useful when asking how large a charge is relative to investor capital. Total funding is useful for tracing sources and uses. Show the contractual base too, especially for loan or property-price charges. One basis should not silently replace another.

### Does this two-offering sample establish typical DST fees?

No. It was selected from accessible documents, not drawn from the whole market. Its results cover only the stated upfront categories. A market estimate would require a defined population, a broader sampling method, consistent cost mapping, and evidence about excluded offerings. Two observations cannot establish an industry standard.

### Should I choose the offering with the lower entry-cost figure?

That figure answers only a cost question within its stated scope. It does not establish property quality, likely return, liquidity, or personal fit. Check annual and exit costs, then review the broader terms and risks. A lower selected cost is useful information, but it is not a complete investment conclusion.

### How do I compare a fee charged on property price with one charged on equity?

Calculate each dollar charge from its own contract first. Then divide those dollars by a common base for the comparison. Retain both the original formula and the converted percentage. This avoids rewriting the contract and lets another reader see how debt or purchase price affects the result.

### Are reserves part of the fee total?

Keep reserve deposits separate from spent charges. A reserve may remain an asset, though its use can be restricted and its funds can later be consumed. Check ownership, control, funding, and release terms. Do not assume that a reserve label means either free cash for investors or a payment earned by a service provider.

### Can a lower commission make the projected cash rate look higher?

Yes, under terms that reduce the amount paid while preserving the same interest and projected cash. The rate rises because its denominator falls. That does not raise the projected dollar payment or guarantee receipt. Verify the actual reduction mechanics before using that calculation for a real subscription.

### What should I do when two documents disagree about a fee?

Save both passages, identify their dates and scope, and ask for clarification from the relevant party. If the difference affects a model, show separate assumed cases while keeping the final interpretation unresolved. Do not select the more favorable wording just to complete a comparison table.

## About Sequoia Research

Sequoia Research, LLC provides independent research on DSTs and other real estate investment offerings. This educational library explains source documents, investment terms, and research methods through cited evidence and original examples.

## Sources

- [NewStar 17 Sweetwater Springs, DST: Private Placement Memorandum](https://pcsalts.com/wp-content/uploads/2026/03/NewStar-NewStar-17-Sweetwater-DST-Private-Placement-Memorandum-PPM.pdf). February 9, 2026. Selected cost review: printed pages 2 and 43–46. Accessed October 16, 2026.
- [Passco Allure DST: Private Placement Memorandum](https://qbkrvktefrncdppfqwyg.supabase.co/storage/v1/object/public/investment-documents/rec2aJXhMpuVPqp2L/146296582c94da53/Passco%20-%20Allure%20DST%20-%20PPM.pdf). May 1, 2026. Cover, cover notes, and printed pages 48–49; PDF viewer pages 9–10 and 56–57. Accessed October 16, 2026.
- [SEC: How Fees and Expenses Affect Your Investment Portfolio](https://www.investor.gov/introduction-investing/general-resources/news-alerts/alerts-bulletins/investor-bulletins/updated). July 23, 2025. Accessed October 16, 2026.
- [FINRA Regulatory Notice 23-08](https://www.finra.org/rules-guidance/notices/23-08). May 9, 2023. Accessed October 16, 2026.
- [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). Originally August 17, 2022; updated September 21, 2026. Accessed October 16, 2026.


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