Canonical page: https://sequoia-research.com/writing/delaware-statutory-trust-returns-2026-what-evidence-to-request-before-relying-on-a-track-record
Author: Sequoia Research
Published: 2026-10-17T22:16:04.071Z
Updated: 2026-10-17T22:16:04.071Z

# Delaware Statutory Trust Returns (2026): What Evidence to Request Before Relying on a Track Record

## What Is This Article About?

A DST track record is useful when you can connect its claims to the investments, cash records and methods behind them. This article sets out the evidence to request before relying on a sponsor's performance presentation in 2026. It starts with one current public example, then follows a fictional research file through the needed checks. You will learn how to write requests that produce checkable answers and how to describe what remains unverified.

## Table of Contents

- [Define the Track-Record Claim Before Requesting Files](#define-the-track-record-claim-before-requesting-files)
- [A 2026 Public Example of Different Performance Scopes](#a-2026-public-example-of-different-performance-scopes)
- [Request the Complete DST Program Register](#request-the-complete-dst-program-register)
- [Measure the Coverage of the Evidence You Receive](#measure-the-coverage-of-the-evidence-you-receive)
- [Trace Program Cash to the Investor Ledger](#trace-program-cash-to-the-investor-ledger)
- [Verify Fees at the Right Level](#verify-fees-at-the-right-level)
- [Compare Actual Results With Original Assumptions](#compare-actual-results-with-original-assumptions)
- [Reproduce the Return Method and Exit Treatment](#reproduce-the-return-method-and-exit-treatment)
- [Read the Scope of Independent Review](#read-the-scope-of-independent-review)
- [Close Evidence Requests Without Hiding Gaps](#close-evidence-requests-without-hiding-gaps)
- [FAQ](#faq)

## Define the Track-Record Claim Before Requesting Files

Start by saving the exact claim, its date and the page on which it appears. “Average return,” “no losses” and “met projections” require different tests. Asking for “the backup” without naming the claim can produce a large folder that still does not answer your question.

Write down the investments covered. Does the figure concern one DST, completed DSTs, every private program or a broader sponsor platform? A sponsor can manage several products with different fees, legal rights and exit paths. A result from one group does not automatically describe another.

Next, record the measure. A distribution rate describes payments against a stated base. A cash multiple compares total receipts with contributions. An annualized return also depends on time and method. A number without that label is an incomplete claim, even if the calculation behind it was careful.

Ask what date the claim measures. The date a web page was updated can differ from the cutoff of its results. A report received in October might contain figures through June. A later sale may appear in a news release before it enters the performance table.

The SEC's performance bulletin asks readers to examine the math and costs behind a claim. It explains how selected results can give a limited view and separates projections from actual performance. Those are useful starting questions for a DST research request. The bulletin is dated September 15, 2022; it is not a survey of 2026 DST returns. [SEC: Performance Claims](https://www.investor.gov/introduction-investing/general-resources/news-alerts/alerts-bulletins/investor-bulletins-47).

A clear request might read: “Please provide the program list and method supporting the completed-DST cash-return figure through September 30, including programs excluded and the reason for each exclusion.” That gives the recipient a defined task. It also gives you a way to decide whether the answer is complete.

Set the intended use too. Checking a historical sponsor statement is different from estimating a new offering's return. Even a fully supported historical result leaves the new property's price, debt, leases and costs to be reviewed. Keep those jobs connected without treating one as a substitute for the other.

## A 2026 Public Example of Different Performance Scopes

ExchangeRight's track-record page, read October 17, 2026, labels its general statistics as of September 30. It presents an 8.60% average full-cycle annual return across 34 strategic exits. A separate heading concerns 22 full-cycle net-leased DST offerings. The table spans several product groups, including financed DSTs, multifamily DSTs, funds and notes.

The page also shows a separate REIT Class D return through June 30, 2026. Its footnote calls that class history illustrative, based on results that would have occurred had the class existed during the period. That is a different claim from an actual investor cash ledger. [ExchangeRight: Track Record](https://www.exchangeright.com/track-record/).

This is a bounded reading of a sponsor's public presentation, not independent verification of its results. We did not obtain the underlying investor ledgers, original forecasts or an assurance report for these claims. The page supports requests about population, formula, costs, exit form and actual versus illustrative history; it does not answer all of them.

The remaining examples are original and fictional. Alder Bay, its programs, the investor Rowan and every amount below are invented. They do not reconstruct ExchangeRight's offerings or imply that the named sponsor has the fictional file gaps.

## Request the Complete DST Program Register

Ask for a program register that matches the claim's scope. A register is a list of the investments included in the research, with enough detail to tell one from another. Give each program a stable ID. List its exact legal name, type, opening date, capital raised and current status.

Names alone can be weak identifiers. A program may be renamed, merged or followed by a successor investment. Similar property names can also belong to separate offerings. Preserve both the original identity and later changes so that one economic history is not counted twice.

Define the starting population before selecting successful exits. Suppose the fictional Alder Bay presentation concerns 18 original private real estate programs. They raised $200 million in total. Each original program appears once in this list. The groups do not overlap.

| Status at the chosen cutoff | Original programs | Original investor capital |
|---|---:|---:|
| Ended with final cash settlement | 8 | $100 million |
| Still active in the original structure | 6 | $65 million |
| Investors continued into successor interests | 3 | $25 million |
| Current status not resolved in the supplied file | 1 | $10 million |
| Total original population | 18 | $200 million |

The table does not describe returns. It describes the population that needs records. The $200 million is original contributed capital, not current market value. An active program is not a failed investment, and an unresolved status is not proof of a loss.

The successor category needs a link to the new interest. Keep the original program in the register and describe what investors received. Do not erase its history because its name changed. Do not add the successor as a nineteenth original program unless the study deliberately uses a different population and explains that choice.

Ask for exclusion rules in writing. A register limited to a certain strategy may properly omit other products. The reader needs to know what those omitted products are and why they sit outside the claim. Check whether the claim and its group match. Every sponsor product need not appear in every table.

### Request the uncomfortable statuses explicitly

Ask about delayed exits and cuts in payments. Also ask about changes in structure, transfers and programs with missing records. It does not assume those events occurred. It prevents a broad request for “completed results” from leaving those categories unaddressed.

If the sponsor reports no programs in a category, record that as its statement. Ask what population and cutoff the answer covers. A checked zero and an unanswered question are different evidence states.

## Measure the Coverage of the Evidence You Receive

Track both the program list and the files actually reviewed. A list of 18 names does not mean you have substantiated 18 returns. A full cash history for six programs does not mean you have a complete picture of the sponsor.

Continue the fictional Alder Bay file. Six of the eight cash-settled programs have complete records for the particular return test you plan to run. They account for $80 million of the $100 million originally invested in that cash-settled group. The other two programs lack fee records needed for a net-cost result. They account for $20 million.

You reviewed 75% of the cash-settled programs by count. Those programs account for 80% of that group's original capital. Against the full original list, you reviewed six of 18 programs, or about 33.33%. Their $80 million is 40% of the full $200 million in capital. All four figures are correct. Each answers a different coverage question.

None is a quality rating. Reviewing 80% of capital does not establish that the missing 20% behaved similarly. Nor does six complete records tell you whether the other 12 programs have good, bad or unfinished results.

Create a missing-record log tied to exact claims. “Two programs incomplete” is a start. “The fee schedules and paid-fee records are missing, so the net investor result has not been reproduced” explains the limit. You may still have evidence for a narrower gross cash statement.

Do not silently drop the two programs from a table titled “all completed programs.” Show the full group and mark the unverified results. If you calculate a six-program subset, put that subset in the label and state why the others are absent.

### Distinguish unavailable from inapplicable

A cash-settled program should have a final cash record. An active program may have no final sale to document yet. Calling both files “missing final proceeds” treats an unfinished investment like a missing completed record.

Use separate labels for not yet occurred, unavailable, unresolved and outside scope. Each leads to a different next step. You may need to wait for an event, request a record, resolve conflicting accounts or explain why the record does not belong in this test.

A privacy limit is another separate issue. Ask whether a redacted investor ledger or controlled review can support the claim. You do not need names, account numbers or tax identifiers in a public research table. You do need enough preserved detail to check amounts, dates, class and fees.

Keep a small map of the records you receive. Name the file, its date, the program it covers and the claim it helps test. If two files disagree, retain both until the issue is resolved. A newer file can correct an old figure, but its date alone does not tell you why the figure changed.

For example, one ledger might show a payment sent on June 30 while a bank record shows receipt on July 2. That is not proof of an error. Ask what each date means and which event the return method uses. Keep both dates in the source record. Do not move one merely to make two totals or periods line up.

A changed amount needs the same care. Was a payment reversed, a fee posted late or a prior entry corrected? Obtain the link from the old entry to the new one. An extra row with the same amount may be a duplicate or a second payment. Its ID, date and bank reference help you tell which.

## Trace Program Cash to the Investor Ledger

To verify an investor result, connect the program's money to the investor's ownership and receipts. A property sale announcement does not complete that path. Neither does a sponsor's total distribution figure by itself.

Use fictional Alder Bay Program Six as a worked file. It raised $20 million from one investor class. Rowan contributed $200,000 and held a 1% economic interest throughout. Assume equal rights per dollar, no later contributions, no ownership changes and no special sharing formula.

The program's actual operating distributions over five years were $1.10 million, $1.05 million, $900,000, $1 million and $1.10 million. They total $5.15 million. Rowan's share is $51,500. These are supplied net distributions after the modeled operating costs; they are not a forecast or a tax-character statement.

At sale, the program receives $33 million. Its final loan principal is $12 million. All sale costs, including sale fees, total $1.2 million. Other final bills are $600,000. It retains $400,000 for unresolved costs. Assume no other assets, liabilities or cash balances at this point.

| Sale-cash step | Amount |
|---|---:|
| Sale proceeds received | $33,000,000 |
| Loan payoff | −$12,000,000 |
| All sale costs and fees | −$1,200,000 |
| Other final bills | −$600,000 |
| Cash held for unresolved costs | −$400,000 |
| First exit distribution | $18,800,000 |

Rowan receives $188,000 from that first exit payment. Together with the earlier $51,500, receipts stand at $239,500. The $400,000 holdback is not yet part of investor cash received.

Later, $100,000 of the holdback pays the last bills and $300,000 is distributed. Rowan receives another $3,000. Final lifetime receipts are $242,500, a $42,500 nominal gain on $200,000, or 21.25%. The cash multiple is 1.2125 times. These are full-period cash measures before Rowan's personal taxes and separate account charges; they are not annual returns.

### Match each step to a record

Request the ownership ledger and contribution records to support Rowan's 1%. Match each program distribution to the class allocation and investor notice, then to a receipt record where available. Keep reversals or returned payments visible instead of treating every notice as money received.

For the exit, request the sale statement, loan payoff and final cost list. Then reconcile them to the program cash ledger and investor allocations. The holdback needs its own later statement showing both the $100,000 use and $300,000 release.

If a statement says the program has ended, ask whether all cash and claims are settled. A property's sale date and the date of its last investor payment may differ. A return calculation should use the date required by its stated method, supported by the relevant record.

## Verify Fees at the Right Level

Ask which costs are already reflected in the result and which are outside it. “Net” needs a list of what was deducted. A property-level result, a class-level result and a particular account result may have different cost boundaries.

The SEC's July 23, 2025 fee bulletin points readers to both product and account disclosures, including private placement memorandums, fee schedules and statements. It distinguishes transaction costs from ongoing costs. That supports requesting the actual terms and charges, rather than assuming a headline percentage includes everything. [SEC: How Fees and Expenses Affect Your Investment Portfolio](https://www.investor.gov/introduction-investing/general-resources/news-alerts/alerts-bulletins/investor-bulletins/updated).

In Program Six, assume $1 million of the original $20 million contribution paid entry costs. Those costs are inside the investor contribution. Rowan's $200,000 includes a $10,000 share of them. The cash calculation already starts with the full $200,000 paid.

Subtracting another $10,000 from Rowan's final gain would count the same entry cost twice. Starting with only $190,000 would create a different error: it would treat the money paid for costs as though Rowan never spent it. The contribution record, sources-and-uses statement and fee schedule should make the boundary clear.

Now add a separate account-cost example. Assume Rowan paid a $2,500 outside planning charge at the start and $500 from separate cash at each of five year-ends. None of those charges was in the program's distributions or entry costs. These invented charges are not typical fees or current quotes.

Rowan's broader initial cash use becomes $202,500. Deducting the five $500 charges from the $242,500 receipts leaves $240,000 of net later cash. The broader nominal gain is $37,500, about 18.52% of the initial $202,500. This is a separate cash boundary, with no tax or timing adjustment.

Keep both results and label them. The 21.25% program-interest cash gain and 18.52% broader account-cost gain do not conflict. They answer different questions. An investor with a different fee agreement would need that investor's actual records.

### Ask about waivers and deferred costs

A fee can be charged, waived, paid later or paid by someone else. Request the record that establishes which occurred. A disclosed maximum does not prove that the maximum was paid. A current waiver does not establish a permanent reduction.

For a fee paid later, follow the cash beyond the first exit report. For a waiver, preserve the agreement and whether conditions apply. Do not remove a fee from the model merely because it is absent from one statement.

## Compare Actual Results With Original Assumptions

Ask for the forecast investors had when they committed their money. Keep its date, key inputs and any changes issued with it. A current spreadsheet may show a revised plan. It cannot establish what the original plan promised or projected unless the versions are preserved.

For Program Six, assume the original forecast showed $1.2 million of distributions in each of five years and $21 million of final exit cash. The original expected total was $27 million: $6 million of operating payments plus $21 million at exit. All figures use the same class, costs and cash boundary as the actual record.

Actual lifetime receipts were $24.25 million. The $2.75 million shortfall has two parts: $850,000 less operating cash and $1.9 million less final exit cash. Rowan's 1% share of the difference is $27,500.

That bridge does not identify a cause. To explain the operating gap, request the rent, vacancy, expense, debt-service and reserve records that connect the original assumptions to actual cash. To explain the exit gap, request the sale price, loan payoff, fees and final balances assumed then and recorded later.

A useful gap analysis separates changes in price, amounts, timing and labels. For example, a delayed payment is different from a permanently lower payment. An expense moved between headings can change one line without changing total cash. The explanation should reconcile all affected lines.

### Keep revised targets beside the original target

Assume a new forecast was issued after year two. It uses the actual first-two-year distributions of $2.15 million. It then forecasts $1 million, $1 million and $1.1 million for the final three years, plus $19 million at exit.

That revised future total is $22.1 million. Actual remaining operating payments are $3 million and final exit cash is $19.1 million, also totaling $22.1 million. The $100,000 operating shortfall and $100,000 exit improvement offset each other in this nominal total.

The actual result matches the revised total while missing the original total by $2.75 million. Both statements can be true. A claim that the program “met the plan” needs to name which plan and what measure. It also needs to preserve any difference in payment dates; equal totals alone do not establish equal annualized results.

This is an invented version-control example, not evidence that a sponsor revised targets improperly. Updating a forecast can be useful. The research problem arises when the reader cannot tell which version supports the claim.

If the original forecast is unavailable, say so. You may compare actual cash with a later dated target, but you have not tested original forecast attainment. Do not fill that gap with an estimate reconstructed from a current distribution rate.

## Reproduce the Return Method and Exit Treatment

Request the formula, input cash flows, dates, weights and treatment of remaining assets. A spreadsheet should expose enough of the method for another reviewer to reproduce it. A displayed percentage without its inputs leaves the calculation untested.

For a cash multiple, identify all contributions and receipts in the denominator and numerator. For a dated annual return, identify the actual dates and the chosen day-count method. Keep fees consistent with the label. Explain any estimate or adjustment rather than hiding it in a single final number.

The SEC's performance bulletin warns that presentation choices can change the meaning of reported results. An average may combine programs differently from a pooled cash calculation. The word “average” should therefore lead to a request for the weighting method, not an assumption that every investor earned that figure. [SEC: Performance Claims](https://www.investor.gov/introduction-investing/general-resources/news-alerts/alerts-bulletins/investor-bulletins-47).

Consider a separate two-program example. One program received $10 million and returned $13 million, a 1.3-times cash multiple. Another received $30 million and returned $27 million, a 0.9-times multiple. There are no other flows or remaining assets in this example.

The simple average of the two multiples is 1.1 times. The combined cash result is $40 million received on $40 million contributed, or 1.0 times. Weight each multiple by its share of the total capital and the average is also 1.0. That equality follows from this cash-multiple formula. It does not mean an average of the programs' annualized rates equals the rate from all their cash flows pooled together.

### Separate cash from continuing ownership

Some investors may have received units in a new entity. Ask for the exchange records, number of units and the date and method used to value them. Identify any cash paid alongside the units. A quoted value for continuing units is not cash received from a sale of those units.

Do not force a continuing interest into a final-cash category merely to fill a return table. Show the cash to date, the separately identified remaining value and the limits on that value. If the study stops at the exchange, say what event ends its measurement period.

For a mix of exit paths, request separate results where available. Investors who took cash and investors who continued ownership may have different dates, fees and later exposure. A blended result can be reported under a defined method, but it should not be presented as every investor's actual experience.

## Read the Scope of Independent Review

Ask for the actual report behind words such as audited, verified or independently reviewed. Identify its author, date, subject, period, method and conclusion. The cover label alone does not show which performance claim the work supports.

A report on annual financial statements may answer different questions from a check of a marketing return schedule. A calculation review may confirm arithmetic without checking whether every program was included. A tax-structure opinion may have no bearing on the investor cash record. Read what the reviewer actually did.

FINRA's May 9, 2023 notice calls for care when firms use third-party work. It asks firms to consider the reviewer's skills, incentives and independence. That guidance concerns covered firms and activities. It is a reason to ask precise questions about reliance, not a claim that this article's checklist establishes regulatory compliance. [FINRA Regulatory Notice 23-08](https://www.finra.org/rules-guidance/notices/23-08).

For the fictional Alder Bay file, suppose a report tests a schedule for the six documented cash-settled programs. The report can be relevant to that schedule. It would not, solely by existing, establish results for the two incomplete programs, the six active programs, the three continuing interests or the unresolved program.

Match the report's schedule version to the presentation you are using. If new programs or revised results were added after the report date, identify the later work separately. Do not carry an earlier review label over new figures without evidence that the review covers them.

Ask about limitations without turning them into accusations. A defined scope is normal in professional work. The reader's task is to understand what it supports. A narrow report can be useful when the resulting claim stays equally narrow.

## Close Evidence Requests Without Hiding Gaps

Keep one request log that connects each question to a claim, record and conclusion. Assign an owner and a next step. The log should make it possible for a second reader to see why a claim is supported, limited or still open.

| Claim to test | Evidence requested | What would close the stated question |
|---|---|---|
| All original programs are represented | Dated register, identifiers and exclusion rules | The stated population reconciles without unexplained duplicates or omissions |
| A completed result includes all cash | Contributions, distributions, sale and final settlement records | Inputs reconcile through the chosen closing cutoff |
| A result is net of specified costs | Fee terms, charged amounts and cost boundary | Each relevant charge is included once or its exclusion is disclosed |
| Actual results met the original forecast | Original dated forecast and actual cash bridge | The same measure, period and assumptions can be compared |
| Third-party work supports the headline | Actual report and covered schedule version | Its subject and limits match the claim being made |

These are research acceptance tests for the stated questions. They are not an audit standard or a promise that every investor can obtain every underlying record. A firm may offer access through an adviser or provide redacted material. Record the access and scope actually available.

Avoid treating a document's arrival as completion. Check its identity, period, definitions and internal totals. A file can be authentic yet concern the wrong class or date. A response can be accurate yet answer only half the request.

When a record remains unavailable, narrow the conclusion. For Alder Bay, you might write: “Six cash-settled program results were reproduced under the stated cost method. Two completed results remain unverified because fee records were not supplied. Active and continuing investments were recorded separately.” That tells the reader what was done.

The SEC's updated bulletin explains that private offerings may provide less information. It also says regulators generally do not review their offering documents. Those limits make disciplined requests useful, but a full-looking folder is not government approval or a prediction of future returns. [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).

Finish by separating historical findings from the new decision. Record which sponsor practices the evidence reveals, what remains uncertain and which current-offering facts still need work. A documented track record can inform that work. It cannot supply the new investment's missing facts.

## FAQ

### What should I request first to verify DST returns?

Request the exact performance claim, its method and the program register that defines its population. Then request the records needed for that specific test. A broad return average, a payment-history claim and an original-forecast claim require different evidence. Naming the claim first makes the request easier to answer and review.

### Is a sponsor's full-cycle table enough to verify my return?

It can be a useful starting record. Your own result also depends on your class, contribution, dates, receipts and costs. The program may have continuing assets, a holdback or several exit paths. Match the table's definition to your actual records before treating its figure as your return.

### Why ask for active and restructured programs if the headline covers completed programs?

The full register shows what sits outside the completed group. It helps you understand coverage and avoid treating selected exits as the entire sponsor history. Keep unfinished and continuing investments separate. Their existence does not prove a loss, and their missing final result should not be filled with zero.

### Does net performance include all investor fees?

Only the costs identified in its method are established as included. Ask which product, class and account charges were deducted. Check actual amounts and timing. A fee already paid inside the contribution or net distributions should not be deducted again, while a separately paid charge may require a broader account calculation.

### What if original projections are no longer available?

State that the original-forecast test is incomplete. You can compare actual results with a later dated forecast if you name that version. Do not call that original forecast attainment. Preserve the current evidence and the missing request so that a later source can complete the test.

### Does an audit prove a sponsor's entire track record?

Read the actual report and the schedule it covers. Check what it covers, for which period, and what it found. Work on one set of statements or six programs does not automatically cover every marketing claim, later update or investor account. Ask about any gap between the report and the current presentation.

### Can a fully verified track record establish a new DST's expected return?

No. Historical evidence does not settle a new property's purchase price, leases, debt, costs or exit value. It can help you assess relevant past work and ask better questions. The current offering and your circumstances still need their own review, including the risk of loss and a longer-than-planned hold.

## About Sequoia Research

Sequoia Research, LLC provides independent research on DSTs and other real estate investment offerings. This educational library helps readers trace financial claims to records, understand their limits and prepare focused questions for qualified advisers.

## Sources

- [ExchangeRight: Track Record](https://www.exchangeright.com/track-record/), statistics generally as of September 30, 2026, with the separate REIT measure through June 30; public page read October 17, 2026. Sponsor-reported presentation, not independently verified investor results.
- [SEC: Performance Claims](https://www.investor.gov/introduction-investing/general-resources/news-alerts/alerts-bulletins/investor-bulletins-47), September 15, 2022.
- [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.
- [FINRA Regulatory Notice 23-08](https://www.finra.org/rules-guidance/notices/23-08), May 9, 2023; covered private-placement investigation and third-party reliance.
- [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.

Sources accessed October 17, 2026. The public sample is limited to the stated page; all Alder Bay, Rowan and other numerical teaching examples are original and fictional.


## Related Reading and Tools

- [Delaware Statutory Trust Returns: Dated Cash-Flow Return Calculator](https://sequoia-research.com/writing/delaware-statutory-trust-returns-dated-cash-flow-return-calculator)
- [Delaware Statutory Trust Returns: Exit Assumption Sensitivity Grid](https://sequoia-research.com/writing/delaware-statutory-trust-returns-exit-assumption-sensitivity-grid)
- [Delaware Statutory Trust Fees: A Guide to Upfront, Ongoing, and Exit Costs](https://sequoia-research.com/writing/delaware-statutory-trust-fees-a-guide-to-upfront-ongoing-and-exit-costs)