Canonical page: https://sequoia-research.com/writing/delaware-statutory-trust-fees-how-to-review-expense-reimbursements
Author: Sequoia Research
Published: 2026-10-17T07:54:02.962Z
Updated: 2026-10-17T07:54:02.962Z

# Delaware Statutory Trust Fees: How to Review Expense Reimbursements

## What Is This Article About?

This article explains how to review costs that a DST or another party repays after someone incurs them. It uses selected public offering language to show why a management fee may not describe every expense. Original examples trace bills through eligibility, shared-cost allocation, approval, caps, credits, and payment. The goal is to distinguish a supported reimbursement from an estimate or an unresolved charge without assuming that every extra cost is improper.

## Table of Contents

- [What an Expense Reimbursement Means](#what-an-expense-reimbursement-means)
- [Read the Cost Boundary in the Offering Documents](#read-the-cost-boundary-in-the-offering-documents)
- [Identify Who Incurred the Cost and Who Owes It](#identify-who-incurred-the-cost-and-who-owes-it)
- [Build a Reimbursement Record From the Original Bill](#build-a-reimbursement-record-from-the-original-bill)
- [Test Whether the Cost Is Already Inside a Fee](#test-whether-the-cost-is-already-inside-a-fee)
- [Check the Allocation of Shared Expenses](#check-the-allocation-of-shared-expenses)
- [Apply Expense Caps to the Right Category and Period](#apply-expense-caps-to-the-right-category-and-period)
- [Separate Spending Authority From Invoice Approval](#separate-spending-authority-from-invoice-approval)
- [Reconcile Advances, Refunds, and Vendor Credits](#reconcile-advances-refunds-and-vendor-credits)
- [Follow Reimbursements Through the Cash Records](#follow-reimbursements-through-the-cash-records)
- [Explain Changes With Activity and Unit Costs](#explain-changes-with-activity-and-unit-costs)
- [Review a Complete Reimbursement Packet](#review-a-complete-reimbursement-packet)
- [Report Findings Without Jumping to a Verdict](#report-findings-without-jumping-to-a-verdict)
- [Frequently Asked Questions](#frequently-asked-questions)

## What an Expense Reimbursement Means

A reimbursement repays a cost that another party has incurred or paid under the relevant agreement. The right to payment comes from the terms and facts. The label alone does not prove the charge is allowed. It also does not show that the cost was split correctly or paid.

A fixed management fee follows its stated schedule. An expense repayment may rise or fall with activity. A property with more repairs, legal matters, or reporting work could incur different costs from one year to the next. The review should identify the work behind the change rather than treating any increase as proof of a higher fee rate.

There are several questions inside one reimbursement request. Was the service performed? Did it benefit the named property or entity? Does the agreement assign that cost to the requested payer? Is the amount supported? Were any limits or approval rules met? Has the cost already been paid through another route?

A bill can answer some questions while leaving others open. An invoice may prove that a vendor charged $4,000 for work. It does not necessarily show that the DST must bear all $4,000. Part of the work could serve a second property, or the service might already fall within a fixed fee.

The SEC advises investors to read both account and product disclosures and ask how fees are charged. It includes private placement memoranda among documents that can explain investment costs. A cost that does not appear as a separate charge on an investor's statement can still affect the investment. [SEC fee bulletin, July 23, 2025](https://www.investor.gov/introduction-investing/general-resources/news-alerts/alerts-bulletins/investor-bulletins/updated).

For a useful review, separate the contractual right, the work, the amount, and the cash payment. These are connected facts, but they are not the same fact. A process that checks all four is more useful than a list of unexplained totals.

## Read the Cost Boundary in the Offering Documents

Start with the private placement memorandum, or PPM, then follow its references to the governing agreements. A summary may state that certain expenses are reimbursable without listing every category, limit, or required record. The referenced agreement is the next source to request.

Two selected 2026 public documents show why this matters. These are brief examples of wording, not a comparison of actual bills or findings about either firm. We inspected the cited pages on October 17, 2026; signed current service agreements and reimbursement ledgers were not obtained.

The NewStar 17 Sweetwater Springs PPM, dated February 9, 2026, states on printed page 48 that the property manager is entitled to reimbursement of certain expenses incurred while performing its duties. That page also describes management compensation and places fees under the property management agreement with the master tenant. The underlying agreement is described as available in the investor data room. The summary alone does not identify a complete reimbursable-expense schedule or prove a particular bill is payable. [NewStar PPM, printed page 48](https://pcsalts.com/wp-content/uploads/2026/03/NewStar-NewStar-17-Sweetwater-DST-Private-Placement-Memorandum-PPM.pdf).

The Passco Allure PPM, dated May 1, 2026, says on printed page 125 that a $25,000 annual administration fee includes internal legal, accounting, and other related out-of-pocket costs. This is selected wording about that fee's scope. It does not establish that every outside cost is included or that any particular extra invoice is improper. Review the actual service and complete governing terms before drawing either conclusion. [Allure PPM, printed page 125](https://qbkrvktefrncdppfqwyg.supabase.co/storage/v1/object/public/investment-documents/rec2aJXhMpuVPqp2L/146296582c94da53/Passco%20-%20Allure%20DST%20-%20PPM.pdf).

The practical question is the boundary around each charge. One provision may permit a repayment. Another may include a category within a fee. A third may assign it to a different entity. A reimbursement review must connect those provisions before adding amounts to a cost estimate.

Do not turn silence in a short summary into a zero. If the category or cap is not stated in the page you have, record that limit of the evidence. Ask for the missing schedule or provision. An unknown term should remain unknown until a source resolves it.

## Identify Who Incurred the Cost and Who Owes It

A DST structure may involve the trust, a master tenant, an asset manager, a property manager, and outside vendors. The party paying the first bill is not always the party that bears the final cost. Build a simple map of the obligation and the payment route.

A master tenant leases the property from the trust and may sublease space to occupants. Its duties can differ from the trust's duties. If it pays a vendor, the next question is whether its agreement allows recovery from the trust, from occupants, or from no other party. The word “property” on the invoice does not decide that issue.

Consider a fictional $10,000 repair. Assume the contract makes the master tenant fully responsible, with no right to recover this repair from the trust. The manager pays the vendor first. A $10,000 repayment from the master tenant to the manager settles that advance. Charging the trust another $10,000 would require separate support that this example does not provide.

Now change the assumption. Suppose the trust is responsible and the manager paid on its behalf. A supported repayment from the trust would follow that obligation. The vendor service is the same, but the contractual cost bearer is different. This is why the payer map belongs before the arithmetic.

Record the legal entity name, not just a familiar brand. An invoice addressed to an affiliate may still relate to the property, but the file should explain the route. A sponsor-wide invoice can include several properties or central services. It should not be treated as property-specific solely because the sponsor owns the manager.

Also distinguish a party's duty to pay from its ability to pay. A reimbursement claim can be valid while collection is delayed. If the forecast relies on a repayment from another entity, retain the supporting agreement and the cash evidence separately. A receivable is an amount claimed or owed; it is not cash already received.

## Build a Reimbursement Record From the Original Bill

The record should begin with the underlying service, not the final transfer between affiliates. Capture the vendor, invoice number, service dates, description, gross amount, credits, and proof of payment where available. Then add the contract clause and allocation that support the requested repayment.

The IRS's business recordkeeping guidance identifies invoices, receipts, account statements, and payment records as supporting documents. It notes that several records may be needed to show the payee, amount, date, and business purpose. That is useful recordkeeping context; it does not grant a DST investor an automatic right to every internal record or decide a contract dispute. [IRS guidance on supporting business records](https://www.irs.gov/businesses/small-businesses-self-employed/what-kind-of-records-should-i-keep).

Use one line for each cost item that needs a separate decision. A single invoice can contain routine accounting, a special filing, and unrelated consulting. Grouping them into one “professional fees” line may hide which portions are allowed under different terms.

Give the original invoice a stable reference. If the same bill appears in a manager's expense report and the trust's closing ledger, both records should point back to that reference. This makes a duplicate easier to spot. Similar dollar amounts alone are weak evidence of duplication, because separate services can cost the same amount.

Preserve the service period even if payment occurs later. A December service invoiced in January should not automatically be treated as January activity. The contract may measure its annual cap by when costs are incurred, paid, submitted, or approved. Those are different dates, and the selected rule needs support.

A review file should also retain exceptions. If a receipt is missing, say what evidence is available and what remains unverified. A bank debit can show money left an account while failing to show the service's purpose. A vendor statement can show an unpaid balance while failing to prove a cash payment. Use each record for the fact it actually establishes.

## Test Whether the Cost Is Already Inside a Fee

A fixed fee and a reimbursement can coexist without being duplicates. The issue is whether they cover the same service. Read included costs, exclusions, and any separate service schedule before deciding.

Use a fictional administration agreement that charges $24,000 each year. Assume the contract expressly includes routine bookkeeping and annual investor statements. It allows separate reimbursement of a required outside filing charge, at cost, with no markup. These terms are invented and are not assigned to the named offerings.

The administrator submits three items: $3,000 for routine bookkeeping, $1,200 for an outside filing charge, and $800 for a special legal matter. Under the stated terms, routine bookkeeping is already included. The supported filing charge is eligible. The legal matter remains unresolved because the example has not supplied a rule covering it.

The request totals $5,000. The review currently supports $1,200, identifies $3,000 as included in the fixed fee, and leaves $800 open. Reporting only “$3,800 denied” would lose the distinction between an excluded item and an unanswered question. Reporting the whole $5,000 as approved would do the opposite.

Now suppose a later written amendment specifically allows the $800 legal matter. Record its effective date and application. Do not silently change the earlier result as though the original record had always supported that charge. The total supported separate reimbursement would then become $2,000 for the assumed scope.

A common problem is reading a service label too broadly. “Accounting” could refer to monthly bookkeeping, a special tax consultation, or an outside audit. Their costs may follow different terms. Ask what the provider did, which period it served, and why the separate charge falls outside the base service.

A fee increase can create another overlap. A new fixed fee might include a service that used to be billed separately. Check the separate bills from the date that change took effect. A ledger may mix old and new terms. Split it by date before applying the rates.

## Check the Allocation of Shared Expenses

A cost shared across properties needs both a total and a method for dividing it. Reproducing the arithmetic is only part of the review. The method must also match the contract and the work performed.

Suppose a fictional vendor charges $30,000 for a project serving three properties. Detailed work records show 50 hours for Cedar, 30 for Birch, and 20 for Maple. If the agreed method allocates by documented hours, the shares are $15,000, $9,000, and $6,000. The amounts add back to the full invoice.

Equal thirds would instead assign $10,000 to each property. That produces the same overall total but changes Cedar's charge by $5,000. Neither method becomes correct just because it adds up. The agreement and reasonable support for the work should explain the selected method.

Some invoices contain a common part and a property-specific part. Assume a separate $30,000 bill contains a $6,000 common setup charge plus $24,000 of work billed by hours. If the contract divides setup equally and work by the same 50:30:20 hours, Cedar bears $14,000. Birch bears $9,200, and Maple bears $6,800. Applying the hour split to the whole bill would produce a different result.

Check the population included in the split. If a fourth property benefited but was omitted, the listed properties could bear too much. If one listed property received no service, its allocation might lack support. A complete beneficiary list matters as much as the percentages.

Changes in the allocation base can also explain a cost increase. A property's share can rise even if the vendor's total bill stays flat. That could follow more documented work for that property, fewer properties sharing a common cost, or a changed policy. Record which change occurred instead of describing every increase as vendor inflation.

Related-party services deserve the same detail. Identify the affiliate, service, cost basis, any permitted markup, and approval path. FINRA's guidance for covered firms calls for review of issuer-affiliate transactions, conflicts, and material claims. It does not declare every affiliate reimbursement improper. [FINRA Regulatory Notice 23-08](https://www.finra.org/rules-guidance/notices/23-08).

## Apply Expense Caps to the Right Category and Period

A cap limits a defined set of costs under stated terms. It may apply by year, project, service, or request. Some categories may sit outside it. The word “cap” is not enough to calculate the investor's maximum total expense.

Consider an invented annual cap of $12,000 for routine administrative reimbursements. A separate clause excludes emergency repairs from that cap. At the start of the final quarter, $8,500 of eligible routine costs has used the cap. New routine requests total $5,000, while an emergency repair costs $4,000.

Remaining routine capacity is $3,500. The new routine request exceeds it by $1,500. If the emergency repair meets its separate clause and approval conditions, the newly payable amount could be $7,500: $3,500 routine plus $4,000 emergency. The routine cap does not limit every cost to $12,000.

That model assumes the terms make the $1,500 excess nonpayable for the year. A different agreement might permit approval above the cap or carry costs into another period. Check the actual rule before treating the excess as canceled. A deferred balance could still affect later cash.

Cap measurement dates also matter. Suppose $2,000 of approved work occurs in December but is paid in January. If the cap follows service dates, the work belongs to the earlier year's limit. If it follows payment dates, the next year may be relevant. This article does not select a rule without the contract.

Separate a budget from a cap. A $12,000 estimate may be a forecast rather than a binding spending limit. A reserve of $12,000 may be cash set aside rather than a promise that costs cannot exceed that amount. Put the document's actual label next to the figure.

If a cap is stated as a percentage, preserve its base. Two percent of $2 million in receipts is $40,000. Two percent of a $5 million property budget is $100,000. Using the same rate with the wrong base creates a $60,000 error in this example. Confirm the base, period, exclusions, and any minimum before applying the rate.

## Separate Spending Authority From Invoice Approval

Permission to order work can differ from permission to pay a bill. A budget approval may authorize a project while requiring further approval for an overrun. A manager may approve small costs but need another party's consent above a threshold. The actual agreements decide those powers.

Use a fictional policy that permits a property manager to order one project up to $5,000. Larger projects need advance written consent from the asset manager. A $4,500 initial order is within that authority. A $1,000 change would bring the project to $5,500, so the assumed policy requires the additional approval before that change.

Breaking the same project into two bills does not change its $5,500 total under this policy. But two unrelated projects could follow separate limits. The review needs the work orders and change records to tell which situation exists. Invoice count is not a reliable substitute for project scope.

An emergency exception needs its own terms. It might permit immediate work to prevent damage while requiring notice afterward. A bill marked “emergency” does not establish that the exception applies. Record the event, action, cost, notice, and review required by the actual clause.

Do not assume passive investors vote on each expense. Instead, identify the contractual decision maker and the reporting process. An investor can ask who approved a charge without claiming an approval power the governing agreement does not grant.

Approval also does not prove the invoice is accurate. The approver may authorize a roof repair budget, while a later invoice contains a duplicate line or a credit not applied. Both authorization and arithmetic still need review. A proper spending decision can coexist with a correctable billing error.

When approval is missing from the provided packet, describe the evidence limit precisely. “No approval record was supplied” differs from “No approval occurred.” The first can be established from the reviewed file. The second would require more evidence. This distinction keeps a request for documentation from becoming an unsupported accusation.

## Reconcile Advances, Refunds, and Vendor Credits

An advance supplies cash before the final eligible cost is known. It should be reconciled against actual charges under the agreement. Treating the advance and the later invoice as two expenses can double the cost.

Suppose a fictional manager receives a $10,000 advance for approved work. Final supported bills total $8,200. Under an assumed dollar-for-dollar reconciliation rule, $1,800 must be returned or properly credited. The total net funding is $8,200 once the reconciliation is complete.

If the manager sends $1,800 back, connect the bank receipt to the original advance. If the manager applies it to the next request, connect that credit to the next bill. A note promising a credit is different from proof that the credit reduced a payment.

A vendor rebate needs similar treatment. Consider a separate $12,000 invoice allocated 50%, 30%, and 20% among three properties. A later $2,000 credit reduces the net bill to $10,000. Under the same allocation rule, the net shares are $5,000, $3,000, and $2,000.

The credits to the original allocations are $1,000, $600, and $400. If the full credit is posted to only one property, the overall total might still reconcile while each property's result is wrong. Match credits to the original beneficiaries and method unless an agreement supports a different treatment.

Check outside recoveries without assuming collection. A repair may be subject to an insurance claim, tenant repayment, or vendor warranty. A claimed $20,000 recovery is not the same as $20,000 received. Preserve the gross cost, claim status, expected amount, and paid amount separately.

A later recovery should not be counted twice. If it already reduces the net expense in the report, adding the same amount again as extra income in a custom cash model could overstate the result. Follow how the source report presents it, then reconcile any adjustment rather than layering it on blindly.

## Follow Reimbursements Through the Cash Records

An allowed reimbursement may be approved in one period and paid in another. The distinction affects cash available for other uses. A review should connect opening balances, new eligible costs, credits, payments, and ending balances.

The SEC's financial statement guide explains that income and cash flow are related but different. A balance sheet shows a position at a date, while income and cash-flow reports cover a period. Use that distinction when comparing expense reports and bank activity; also read the stated accounting basis. [SEC Beginners' Guide to Financial Statements](https://www.sec.gov/about/reports-publications/beginners-guide-financial-statements).

Consider a fictional reimbursement account with $6,000 owed at the start of a quarter. New eligible costs are $18,000. A $2,000 credit applies, and the payer sends $15,000 during the quarter. The ending unpaid balance is $7,000: opening $6,000 plus $18,000, less $2,000, less $15,000.

The new net eligible cost is $16,000. Cash paid is $15,000. The unpaid balance rises by $1,000. All three facts can be correct at once. Using the cash payment alone as the measure of new activity would miss the balance change.

This is a simple claim-and-payment ledger, not a rule for how every DST must prepare its accounts. Actual reports may use a cash basis or another stated basis. The reviewer should reconcile the provided records and avoid silently switching methods when comparing periods.

In a separate cash illustration, assume $250,000 is available after all other modeled uses and before new reimbursements. Paying $16,000 leaves $234,000. If an approved $10,000 cost is added, the amount falls to $224,000. The additional cost is 4% of the original $250,000 pool.

That percentage does not mean investor payments must fall 4%. The entity could retain other cash, use an allowed reserve, or adjust another use. Those decisions need evidence. The model isolates one cash effect instead of claiming an automatic change in distributions or total return.

## Explain Changes With Activity and Unit Costs

A reimbursement total can rise because more work occurred, the unit price changed, or the allocation changed. Split those effects before judging the result. This is especially useful for costs tied to repeated tasks.

Suppose a fictional service costs $300 for each of 20 tasks in one year, for $6,000. The next year has 30 tasks at $330 each, for $9,900. The increase is $3,900, or 65%. The price per task rose 10%, while task volume rose 50%.

One exact way to explain the increase is to price the ten extra tasks at the old $300 rate, producing $3,000. Then apply the $30 rate increase to all 30 current tasks, producing $900. The two pieces add to $3,900. The allocation of the interaction between price and volume depends on the method, so state the method used.

A high percentage increase from a small base can still be a small dollar item. A modest percentage increase on a large base can matter more to cash. Show both. Also check whether the work was a one-time event or likely to recur. One unusual legal matter should not automatically become a permanent annual assumption.

Forecast future activity with stated inputs. If the plan assumes 25 tasks at the new $330 rate, the cost is $8,250. If it assumes 35, the cost is $11,550. Those are two scenarios, not a confidence range or a claim about typical property needs.

An apparent saving also needs explanation. Fewer reimbursed costs could reflect less work, a new fixed-fee arrangement, delayed submission, unpaid bills, or reduced service. A lower cash payment is not enough to identify which reason applies. Look at the work records and balances before calling it an efficiency gain.

## Review a Complete Reimbursement Packet

The fictional Willow Park packet combines several checks. It is separate from all named offerings and assumes the stated contract rules have been verified. The packet requests $25,000 across five items. Its purpose is to show how a reviewer can reach a precise result without collapsing every issue into approved or rejected.

| Requested item | Requested amount | Assumed evidence and rule | Current result |
|---|---:|---|---:|
| Routine bookkeeping | $3,000 | Included in fixed fee | $0 separately payable |
| Outside filing | $1,200 | Supported and allowed at cost | $1,200 supported |
| Shared vendor project | $12,000 | Correct allocation supports $9,000 | $9,000 supported |
| Emergency repair | $8,000 | Service supported; required approval record missing | $8,000 unresolved |
| Duplicate invoice entry | $800 | Same paid invoice already included elsewhere | $0 additionally payable |

The requested total is $25,000. The supported amount is $10,200. The unresolved amount is $8,000. The remaining $6,800 consists of the included bookkeeping, the $3,000 allocation difference, and the duplicate $800 entry. These categories add back to the request.

Under the supplied assumptions, the review should not pay $18,200 merely because the emergency work occurred. Its approval condition remains open. Nor should it assert that the $8,000 is permanently invalid. A valid approval record or another applicable contract provision could change the result.

Suppose a later record resolves the emergency item in favor of payment. Supported costs would then be $18,200. If $10,000 had already been paid as a valid advance against this same packet, the remaining amount would be $8,200. The advance is a funding credit, not another expense.

Preserve both versions of the review. The first shows the evidence available at that date. The second shows what changed and why. That history helps a later reader understand that the new result came from an approval record rather than from changing the arithmetic or ignoring the earlier question.

The packet does not prove that all other property costs are correct. It supports a conclusion about five listed requests under stated terms. State that scope in the result so a detailed small review does not get mistaken for a full audit.

## Report Findings Without Jumping to a Verdict

A strong reimbursement finding names the cost, the rule, the evidence, and the unresolved point. “Professional costs are high” is hard to act on. “This request includes $3,000 for a service listed within the fixed fee” gives the provider a clear issue to address.

Separate a billing error from a disagreement about the contract. A duplicated invoice may be easy to correct once both entries are found. The meaning of a broad expense clause may need counsel or other professional review. An allocation can be mathematically correct yet disputed because the work records do not support its base.

Ask for a response that resolves the specific point. For a missing invoice, request the invoice. For a shared-cost question, request the beneficiary list and method. For a cap, ask which category and period the provider applied. A general assurance that expenses are reasonable does not answer those narrower questions.

Record the response date and any remaining conditions. If a provider promises to correct a future statement, check the correction when that statement arrives. A proposed credit and a posted credit are different stages. Close the item only to the extent the available evidence supports closure.

The result should let a reader trace every reviewed dollar from its source to its final treatment. It should also show what the review could not establish. That combination makes a fee comparison more useful without claiming that a spreadsheet can decide legal rights, detect misconduct, or certify an investment.

## Frequently Asked Questions

### Are Expense Reimbursements the Same as Management Fees?

They can be separate charges under an agreement. A management fee may pay for a defined service, while a reimbursement repays an eligible cost. Some agreements include particular expenses within the fixed fee. Review the service boundary before deciding whether both amounts are payable for the work in question.

### Does a Receipt Prove the DST Owes the Cost?

No. It can support that a purchase or payment occurred, but the agreement must assign the cost to the requested payer. You may also need an allocation, proof of business purpose, or approval. The original receipt is useful evidence; it does not answer every contractual question.

### Can a Manager Reimburse Itself for Affiliate Costs?

The answer depends on the governing terms, service, allocation, and required approvals. Identify the affiliate and any markup rather than assuming an at-cost pass-through. A related-party charge is not automatically improper, but it needs enough detail to assess the actual arrangement and any conflict.

### Does an Annual Expense Cap Limit Every Property Cost?

Only if the actual terms define it that broadly. A cap may cover one category and exclude others. It may also measure costs by service date or payment date. Read the scope and exceptions before using the cap as a maximum total expense in a forecast.

### Should a Missing Approval Be Treated as a Rejected Charge?

Keep it unresolved unless the evidence supports a stronger conclusion. Missing paperwork in the reviewed packet does not prove no approval occurred. At the same time, do not label a request fully supported when an essential condition remains unverified. State what record is needed to resolve the issue.

### How Do Refunds and Credits Change the Review?

Connect them to the original cost and the original allocation. A credit should reduce the relevant balance or payment under its terms. Verify that it was posted or received. Do not count a promised credit as paid cash or apply one property’s credit to another without support.

### Do Higher Reimbursements Always Mean Worse Investment Results?

No. The amount may reflect more work, needed repairs, a changed service model, or higher prices. It still uses resources, so review its effect on cash and the benefit or obligation behind it. A cost total alone does not measure service quality, property performance, or the investor's total return.

## About Sequoia Research

Sequoia Research, LLC provides independent research on DSTs and other real estate investment offerings. This educational library helps readers connect offering terms with financial evidence, compare costs clearly, and identify questions that need further review.

## Sources

- [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. Inspected October 17, 2026.
- [NewStar 17 Sweetwater Springs PPM](https://pcsalts.com/wp-content/uploads/2026/03/NewStar-NewStar-17-Sweetwater-DST-Private-Placement-Memorandum-PPM.pdf), February 9, 2026; printed page 48. Inspected October 17, 2026.
- [Passco Allure PPM](https://qbkrvktefrncdppfqwyg.supabase.co/storage/v1/object/public/investment-documents/rec2aJXhMpuVPqp2L/146296582c94da53/Passco%20-%20Allure%20DST%20-%20PPM.pdf), May 1, 2026; printed page 125. Inspected October 17, 2026.
- [IRS What Kind of Records Should I Keep?](https://www.irs.gov/businesses/small-businesses-self-employed/what-kind-of-records-should-i-keep), undated current page as retrieved. Inspected October 17, 2026.
- [SEC Beginners' Guide to Financial Statements](https://www.sec.gov/about/reports-publications/beginners-guide-financial-statements), January 12, 2014; page footer last reviewed or updated February 6, 2017. Inspected October 17, 2026.
- [FINRA Regulatory Notice 23-08](https://www.finra.org/rules-guidance/notices/23-08), May 9, 2023. Inspected October 17, 2026.


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