Canonical page: https://sequoia-research.com/writing/delaware-statutory-trust-reviews-2026-which-performance-claims-deserve-a-closer-look
Author: Sequoia Research
Published: 2026-10-17T00:57:42.918Z
Updated: 2026-10-17T00:57:42.918Z

# Delaware Statutory Trust Reviews (2026): Which Performance Claims Deserve a Closer Look

## What Is This Article About?

This article shows how to read performance claims in Delaware statutory trust reviews without mixing up different measures. It examines three public sponsor documents available in October 2026, then uses separate invented examples to explain distributions, total cash, annual returns, fees, and sample selection. The review checks what the public documents say and where their evidence stops. It does not rank sponsors or verify the full cash history of individual investors.

## Table of Contents

- [Read the Metric Before Comparing the Percentage](#read-the-metric-before-comparing-the-percentage)
- [Three Public Performance-Claim Examples Available in 2026](#three-public-performance-claim-examples-available-in-2026)
- [A Distribution Rate Is a Cash-Flow Measure](#a-distribution-rate-is-a-cash-flow-measure)
- [Separate Capital Returned From Investment Gain](#separate-capital-returned-from-investment-gain)
- [Understand Annual Returns, IRR, and Equity Multiples](#understand-annual-returns-irr-and-equity-multiples)
- [Check Whether the Result Is Cash or a Valuation](#check-whether-the-result-is-cash-or-a-valuation)
- [Find the Fees Inside and Outside the Number](#find-the-fees-inside-and-outside-the-number)
- [Look Behind the Average and the Program Count](#look-behind-the-average-and-the-program-count)
- [Keep Open Programs and Partial Sales in View](#keep-open-programs-and-partial-sales-in-view)
- [Test Projected Returns Without Calling Them Results](#test-projected-returns-without-calling-them-results)
- [Match Performance Dates and Holding Periods](#match-performance-dates-and-holding-periods)
- [Build a Fair Comparison From the Available Evidence](#build-a-fair-comparison-from-the-available-evidence)
- [Frequently Asked Questions](#frequently-asked-questions)
- [About Sequoia Research](#about-sequoia-research)
- [Sources](#sources)

## Read the Metric Before Comparing the Percentage

Two return figures can look alike while answering different questions. One may describe this month's payment as an annual rate. Another may measure a completed investment's cash gain. A third may include an estimated value for an interest the investor still holds. The word “return” alone does not tell you which one you have.

Start with the label and formula. Identify the money counted above the line, the investment amount below it, and the period covered. Then ask whether the number is projected, paid, valued, or calculated from a completed cash history. Keep these facts with the percentage when you quote it.

Next, identify the subject. A sponsor may report a result for one offering or all completed programs. It may focus on one property type or a broader platform. A result from a real estate investment trust, or REIT, is not automatically a result from its related DSTs. A property sale price is not an investor's return.

This matters because private offerings can have limited public disclosure. The SEC warns that investors may have less information than they would receive in a registered offering. A review should say when cash records are missing. It should also identify agreements it could not obtain. It should not fill that gap by treating an attractive number as confirmed. [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).

A useful first note has six parts: metric, amount invested, cash or value counted, dates, costs, and population. If one part is missing, write a question beside it. You can still learn from the material, but the missing part limits which comparisons you can make.

The aim is not to find a single winning measure. Cash paid helps with spending plans. A total cash multiple helps with capital outcomes. A dated return calculation helps with timing. Each becomes more useful when it stays tied to the question it can answer.

## Three Public Performance-Claim Examples Available in 2026

For this article, we examined three public documents on October 16, 2026. Two came from ExchangeRight and one from Inland Investments. We chose them to show different kinds of claims. This is a small sample of the DST market. Sponsor statements below are attributed statements; we did not inspect individual investor cash ledgers or private offering files.

| Public source | What the source reports or defines | Why the definition matters |
| --- | --- | --- |
| ExchangeRight announcement dated March 13, 2026 | Net-Leased All-Cash 16 DST had a then-current annualized distribution rate of 5.08%; the offering was closed | A payment rate at the announcement date is not a completed total return or a verified October payment rate |
| ExchangeRight's undated Full Cycle Returns PDF, available on the review date | Its net-leased portfolio measure averages a cash-out/1031 route with a 721 route valued using the acquiring REIT's net asset value per share | The stated measure combines different exit forms; it should not be described as cash received by every investor |
| Inland's Portfolio Overview, printed April 15, 2026, with data through December 31, 2025 | The overview shows 334 sponsored programs, 159 completed dispositions, a 6.91% weighted average IRR and a 1.4x weighted average equity multiple | The overall population and full-cycle results have different scopes; the measures also use different formulas |

Sources for the rows: [ExchangeRight announcement](https://www.exchangeright.com/news/exchangerights-net-leased-all-cash-16-dst-fully-subscribed-providing-1031-exchange-investors-historically-recession-resilient-retail/), [ExchangeRight Full Cycle Returns, pages 1–2](https://www.exchangeright.com/resources/full-cycle-returns.pdf), and [Inland Portfolio Overview, pages 1–2](https://assets.inland-investments.com/files/pdf/Inland-Portfolio-Overview-Private-Placements.pdf).

The Inland overview covers IPC and IVP programs, rather than a DST-only sample. Its definitions exclude certain foreclosure-related investment continuations from full-cycle results. It describes capital-weighted program IRRs and calls the measures gross while taking estimated offering costs into account; actual investor fees can differ. Those details prevent treating the headline as each investor's net result. The ExchangeRight PDF's exit-method footnote likewise needs to remain with its figures. Neither document supplied the full investor records needed here to reproduce the reported performance.

These are limits on what this article verified. They are not findings that a sponsor's figures are wrong. Nor are the numbers directly comparable with one another. The rest of the article uses original, hypothetical examples to explain the checks. Those examples do not estimate either sponsor's results.

## A Distribution Rate Is a Cash-Flow Measure

A distribution rate usually compares a payment amount with a stated investment base over a stated period. Read the exact formula. Multiplying a current monthly payment by twelve gives an annualized pace. It does not prove that twelve equal payments have already occurred.

Suppose a fictional investor paid $200,000 and now receives $900 a month. Multiplying $900 by twelve gives $10,800. Dividing that by $200,000 gives a 5.4% annualized payment rate. The calculation says what the current monthly amount would equal over a full year if it remained level.

Now suppose the investor actually received $900 for four months, then $700 for eight months. Cash paid during that year was $9,200: $3,600 plus $5,600. That is 4.6% of the original $200,000. The current rate and the actual full-year rate can therefore differ without either calculation being wrong.

The cash source is a separate question. Ask whether payments came from operations, reserves, sale proceeds, financing, or another permitted source. A payment record proves that cash arrived. It does not by itself show that rent collected during the period covered every cost and the payment.

Also ask whether the base is original equity, current estimated value, or another amount. The same $10,800 annual cash figure is 5.4% of $200,000 and 6% of $180,000. A higher percentage caused by a lower value is not the same event as a higher payment.

Finally, keep capital value in view. A payment rate can stay level while the eventual sale proceeds rise or fall. You need the complete cash history and final value or proceeds to assess the broader result. For someone paying bills, the distribution is still important. It simply answers a narrower question than total investment performance.

## Separate Capital Returned From Investment Gain

A large cash receipt can include money you invested at the start. Before calling it profit, subtract the relevant contributions and costs. Terms such as total proceeds, total distributions, and total return can be defined differently in different materials, so locate the formula rather than guessing from the label.

Consider a fictional $100,000 investment. It pays $6,000 a year for five years, then returns $110,000 at sale. Total receipts are $140,000: $30,000 during the hold plus $110,000 at exit. The gain over the original capital is $40,000 before any omitted costs or personal taxes.

Under a cash-multiple formula, $140,000 divided by $100,000 is 1.4x. Expressing all receipts as a share of capital gives 140%. Expressing the gain as a share of capital gives 40%. Those three figures describe related calculations. Calling the gain 140% would count the original capital as though it were new profit.

Now change the sale proceeds to $70,000 while keeping the same $30,000 of prior payments. Total receipts become $100,000. The investor has received the amount originally contributed, with a 1.0x cash multiple and no nominal gain before other costs or taxes. The positive annual payments did not create a positive overall nominal gain in this case.

Additional contributions need the same care. If an investor contributed $100,000 at purchase and another $10,000 later, a multiple based only on the first amount would omit part of the capital supplied. Use all required contributions when the chosen definition calls for them. Keep each date as well if you will calculate a dated return.

Distinguish economic capital recovery from tax labels. The tax character of a distribution requires the relevant records and tax analysis. A cash ledger alone does not establish that character. Here, subtracting contributed capital is a way to understand the economic result, not a tax calculation.

## Understand Annual Returns, IRR, and Equity Multiples

An equity multiple measures how much cash or stated value comes back relative to the capital counted. It does not show how long the process took. An annual return measure brings time into the calculation, but several methods use similar names.

A simple annualized gain divides total percentage gain by years. For an invented investment with $100,000 at the start, $140,000 at the end, and no interim cash, the gain is 40%. Over five years, a simple division produces 8% per year. That is an arithmetic average of gain over time.

The equivalent compound rate for that same no-interim-cash example is about 6.96% per year. It is the rate that would turn $100,000 into $140,000 through five equal years of compounding. The simple and compound figures differ because they answer different mathematical questions.

An internal rate of return, or IRR, uses the timing of the modeled cash flows. In the no-interim-cash example, the annual IRR matches the compound rate. Add payments during the hold, and the pattern of those payments matters. A review should identify the full schedule used rather than present IRR as another name for the simple annual gain.

Do not average return measures casually. Two program IRRs cannot be combined into a pooled investor return merely by taking their midpoint. A sponsor may use a defined weighted average for its summary, which can be useful on its own terms. A pooled cash-flow IRR is a different calculation that requires the combined dated contributions and receipts.

The same caution applies to a statement such as “average hold of six years.” Dividing a portfolio's average gain by its average hold does not necessarily reproduce the provider's reported average annual return. Programs can have different sizes, dates, payments, and weights. Ask for the method before attempting to reconcile the headline.

Choose the measure that helps answer your question. If you need to know total capital recovery, inspect cash multiples and dollar proceeds. If you need to compare timing, keep dated cash flows. If you need monthly spending money, inspect actual payments. A single percentage cannot do all three jobs.

## Check Whether the Result Is Cash or a Valuation

A performance record can include both realized cash and an estimated value for a continuing interest. Keep those pieces separate. A value assigned to a new interest is not the same as selling that interest for cash that you can spend.

In a fictional exchange, an investor receives $15,000 in cash and an interest valued at $105,000. The stated total value received is $120,000. Only $15,000 is cash in this example. The other $105,000 remains exposed to the rights, risks, costs, and valuation process of the new interest.

Ask what supports the value. Is it a transaction price, an appraisal, a calculated net asset value, or an estimate supplied by a party to the deal? What date does it cover? Which costs and debt are reflected? A label such as “value” cannot answer those questions on its own.

Then ask whether the interest can actually be sold or redeemed at that value. A stated net asset value may have a clear calculation while the investor still faces limits on access to cash. Do not infer a redemption right or a reliable sale price from the valuation alone.

A continuing interest can be a deliberate choice. The point is not that cash is always preferable. It is that cash, exchanged ownership, and estimated value should not be blended without explanation. Otherwise a reader can mistake a completed transaction for the end of all investment risk.

For a fair record, show cash received to date, the remaining interest, its stated value and date, and the relevant access limits. If you calculate a total using the value, label it as value-inclusive. Keep a cash-only result beside it when cash recovery is the question. Do not present the two results as though they were competing estimates of the same thing.

## Find the Fees Inside and Outside the Number

“Net” needs an object. Net of property expenses is not necessarily net of financing, trust fees, sales costs, advice charges, or personal taxes. Ask which deductions are already reflected and which remain outside the number.

The SEC fee bulletin distinguishes product costs from fees for professional services. It points investors toward the relevant offering and account disclosures. That distinction matters when a sponsor result is later used in a personal proposal: the investor may pay a separate charge that is not part of the sponsor's stated calculation. [SEC fee bulletin, July 23, 2025](https://www.investor.gov/introduction-investing/general-resources/news-alerts/alerts-bulletins/investor-bulletins/updated).

Use a fee bridge rather than a general claim that all costs are included. Start with the cash figure in the source. List additional charges, their bases, payment dates, and any credits or overlaps. Count each charge once. If a fee has already reduced the reported cash, subtracting it again makes the comparison too low.

For example, take the fictional $100,000 investment that produced $140,000 of total cash receipts. Assume a separate $500 service fee was paid at the end of each of five years and was not already included. Those fees total $2,500. Cash after that added cost is $137,500, leaving a $37,500 gain over the original capital, before personal tax.

That subtraction adjusts the dollar total. It does not give you the new IRR. For that calculation, deduct each $500 on its actual date in the cash schedule. The timing of a cost can affect a dated return even when the total cost is unchanged.

If a source uses estimated offering costs, do not silently relabel them as every investor's actual costs. Different agreements, entry dates, or interest classes can change the result. Record which cost record you have and which one you still need. A clear fee scope is more useful than choosing the highest or lowest figure from conflicting summaries.

## Look Behind the Average and the Program Count

An average depends on the items included and how much weight each receives. Before using a sponsor average, identify the population: all sponsored offerings, completed programs only, one asset type, or a particular exit route. Then identify the weight, such as equal program weights or invested capital.

Consider two fictional programs that begin and end at the same time after one year, with no interim cash. One receives $1 million and returns $1.2 million, a 20% gain. The other receives $9 million and returns $9 million, a 0% gain. The simple average of the two percentage gains is 10%.

Across both programs, however, $10 million went in and $10.2 million came back. The combined gain is $200,000, or 2%. A capital-weighted average also gives 2% in this deliberately simple, same-period example. The 10% and 2% results answer different questions because one gives both programs equal weight and the other gives each invested dollar equal weight.

Do not extend that shortcut to unlike periods and cash schedules. When investments begin at different times or make interim payments, calculating a pooled return requires those dates. The example shows why weights matter, not a universal formula for combining sponsor records.

Counts also need labels. A sponsor may own several properties within one program. It may have sold several properties but not completed the program. It may have repeated offerings under one broader strategy. Counting properties, programs, exits, and investors as though they were the same unit can produce a false impression of the sample.

Ask how the provider handles missing records. Are programs without enough data omitted? Are changes in strategy or management separated? Does the record include periods of weak markets? You may not receive every underlying file, but the selection rule should be clear enough to understand what the reported result represents.

A large count does not erase concentration. Several programs may share a tenant, market, financing approach, or sale period. A review can recognize broad experience while still examining those common exposures. More observations are useful only when you know what was observed.

## Keep Open Programs and Partial Sales in View

A completed-program record cannot tell you the final outcome of programs that remain open. That is a limit of the category, not automatically a flaw in the arithmetic. A fair review reads completed results alongside the still-active population.

Ask for the definition of completion. Does it require selling every asset? Distributing all remaining cash? Exchanging into another interest? Releasing every reserve? Different endpoints can leave different amounts of economic risk outside the reported period.

A partial sale is especially easy to misread. Suppose a fictional program sold one of four properties and distributed $20,000 to an investor who originally put in $100,000. Three properties remain. The $20,000 is actual cash received, but it does not establish the final gain or capital recovery for the whole program.

A value assigned to the remaining properties can support an interim estimate if its basis and limits are clear. It still should not become a completed cash return. Keep the unsold assets, remaining debt, expected costs, and valuation date visible.

Also check how changes in ownership or program structure affect the record. If an investor's interest continues through another entity, ask what happens to the original cash history in the summary. Is it linked to the continuing investment, treated as a completed event, or excluded from the completed set? Record the provider's rule without inventing results for the excluded items.

FINRA's private-placement guidance calls attention to potentially misleading or selected past-performance claims. For recommending member firms, the review extends beyond accepting an issuer's favorable examples. That scope supports asking about the full population, while leaving the actual investigation duty with the firms to which it applies. [FINRA Regulatory Notice 23-08, May 9, 2023](https://www.finra.org/rules-guidance/notices/23-08).

For an investor, the practical request is simple: show completed outcomes, active programs, and the rules for moving between those categories. Avoid adding unfinished programs to a completed average using guessed exit values. That would hide the very uncertainty you are trying to understand.

## Test Projected Returns Without Calling Them Results

A projection shows what a set of assumptions would produce. It may help explain the business plan, but the output remains conditional. Keep it separate from actual operating results and realized investment returns.

Begin with the assumptions that drive the exit. Net operating income, or NOI, is property income after operating expenses and before financing costs under the definition used here. A capitalization rate, or cap rate, relates that income to property value. In a simplified model, value equals annual NOI divided by the cap rate.

Suppose a fictional property is expected to produce $600,000 of annual NOI at sale. A 5% cap rate implies a $12 million value. A 6% cap rate implies $10 million. Both calculations use the same NOI. The $2 million difference comes entirely from the assumed rate.

Now assume a $5 million payoff and sale costs equal to 3% of gross value. At $12 million, costs are $360,000, leaving $6.64 million after those costs and debt. At $10 million, costs are $300,000, leaving $4.7 million. The difference in this simplified equity result is $1.94 million.

These are scenario outputs, not forecasts or loss probabilities. They omit other charges, reserves, taxes, and possible changes in debt or income. They show why a review should inspect the exit assumptions before repeating a projected return as though it were an observed fact.

Change one assumption first so the cause of the difference stays visible. Then test combinations if they reflect a useful question. Lower income and a higher cap rate can have a different effect from either change alone. Explain each run instead of presenting a wide range with no account of what changed.

Also compare the projection with its own starting point. If a plan assumes higher rents, lower vacancy, or reduced costs, ask what evidence supports the change. Past success elsewhere does not establish that this property's assumptions will occur. The review should show where judgment enters the model.

## Match Performance Dates and Holding Periods

A report can be published in 2026 while describing results through 2025. Both dates are useful. Keep the publication date separate from the measurement cutoff and the dates of the investments included. New design or a new web address does not create newer performance.

Different holding periods also affect the meaning of an average. A four-year result and a ten-year result may have faced different market conditions. One might have ended before a major rate change. The other may still be exposed to it. A side-by-side percentage should not erase that context.

Check the first and last cash-flow dates for a specific investment. The offering's launch date may differ from a particular investor's funding date. Final property closing may differ from the last reserve release. If a calculation uses a standard start or end date, the review should say so.

Be careful with annualizing a short period. Three months of favorable payments do not establish a year of realized cash. A current rate may be useful. Keep its period and the word “annualized” with it. Do not let the formatting turn a short observation into a long record.

When a historical record changes, ask what changed in the method. New programs may have completed, older figures may have been corrected, or the provider may have changed its definition. A new average alone does not tell you which explanation applies.

Keep a dated copy or precise source reference for the numbers used in a decision. If the public page later changes, the record helps you identify whether you compared like periods and like measures. It also makes a follow-up question specific enough to answer.

## Build a Fair Comparison From the Available Evidence

Start with a comparison sheet that describes each number before placing it beside another. Record the metric name, formula, measured period, included population, fee scope, cash-versus-value treatment, and source date. Use a separate field for what you could not verify.

Then decide which figures can share a row. Two current distribution rates may be comparable after their periods and bases are aligned. A current distribution and a completed-program IRR should sit in different rows. A valuation-inclusive result needs its own label beside a cash-only result.

Do not resolve missing evidence by using zero. An unknown fee is not a zero fee. An unreported outcome is not a total loss or a success. Keep the field open and ask how much the missing fact could matter to the decision.

The three public examples in this article show why that discipline matters. A sponsor's reported number can be quoted accurately yet used incorrectly when its date, population, or formula is lost. The useful task is to preserve those definitions and identify which additional records are needed.

Finally, connect performance to the current offering and your needs. Past results may inform questions about a sponsor's experience. They do not establish the price, debt, tenant strength, future distributions, or exit value of a different investment. A review is strongest when it explains the evidence without asking the reader to mistake history for a promise.

## Frequently Asked Questions

### Is a DST Distribution Rate the Same as Its Total Return?

No. A distribution rate describes payments relative to a stated base and period. Total performance also depends on capital contributed, final proceeds or remaining value, costs, and timing. A positive payment rate can coexist with lower capital value or a weak completed result.

### What Does a 1.4x Equity Multiple Mean?

Under a cash-receipts definition, it means $1.40 was returned for each $1 counted as invested. That includes the original dollar, so the gain is $0.40 before any omitted costs or taxes. Check the provider's formula, especially whether the result includes a value for an interest still held.

### Why Can Two Annual Return Figures Be Different?

One may use simple gain divided by years, while another uses dated cash flows and compounding. They may also use different fees, populations, or exit values. Read the formula and source before comparing the percentages. Similar labels do not guarantee similar calculations.

### Does a Full-Cycle Label Mean Every Investor Received Cash?

Not necessarily. Read how the provider defines completion and treats exchanges into continuing interests. A completed transaction can include new ownership instead of cash. Keep the value assigned to that ownership separate from money actually received and available to spend.

### Can I Compare a Sponsor Average With a New Offering's Projection?

You can examine both, but they answer different questions. The average describes a defined historical set; the projection describes an assumed future path. Ask whether the property type, debt, fees, timing, and market assumptions are comparable. Do not treat the historical average as the new offering's expected result.

### Does Net Performance Include My Personal Taxes?

Do not assume that it does. “Net” may refer to specified property, fund, or offering costs. Personal taxes and separate service charges can remain outside the figure. Read the stated deductions and ask for a calculation that matches the costs relevant to you.

### Are the Sponsors in This Article Ranked?

No. The three public documents illustrate different metric types and disclosure limits. This review did not inspect complete investor cash ledgers, audit sponsor results, or survey the whole market. The named examples support a reading method, not a conclusion about which sponsor offers the best investment.

## About Sequoia Research

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

## Sources

Sources accessed October 16, 2026. Named-source figures are attributed to their publishers. All other numerical examples are hypothetical and do not estimate those publishers' results.

- [ExchangeRight Net-Leased All-Cash 16 announcement](https://www.exchangeright.com/news/exchangerights-net-leased-all-cash-16-dst-fully-subscribed-providing-1031-exchange-investors-historically-recession-resilient-retail/), March 13, 2026. Distribution-rate example and closed-offering status at that date.
- [ExchangeRight Full Cycle Returns](https://www.exchangeright.com/resources/full-cycle-returns.pdf), undated public PDF available on the review date. Pages 1–2, exit-method definition; not described here as a 2026 publication.
- [Inland Portfolio Overview – Private Investments](https://assets.inland-investments.com/files/pdf/Inland-Portfolio-Overview-Private-Placements.pdf), printed publication date April 15, 2026; data through December 31, 2025. Pages 1–2, population, measures, definitions and limits.
- [SEC private-placement bulletin](https://www.investor.gov/introduction-investing/general-resources/news-alerts/alerts-bulletins/investor-bulletins/private-placements-under-regulation-d-updated-investor-bulletin), original August 17, 2022; updated September 21, 2026. Private-offering disclosure limits.
- [SEC fee bulletin](https://www.investor.gov/introduction-investing/general-resources/news-alerts/alerts-bulletins/investor-bulletins/updated), July 23, 2025. Product and professional-service charges.
- [FINRA Regulatory Notice 23-08](https://www.finra.org/rules-guidance/notices/23-08), May 9, 2023. Member investigation and potentially misleading selection of past performance.


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