The DST Market: Capital Raised, Sponsor Count and Asset Mix (Sourced)

There is no official count of DST sponsors and no official tally of 1031 money placed in Delaware statutory trusts. The figures quoted in sales decks come from private research firms whose methods are not public, and we do not repeat them. What can be sourced is narrower but solid: every DST interest sold under Regulation D leaves a Form D on EDGAR, the SEC publishes aggregate Regulation D statistics, and Rev. Rul. 2004-86 defines what a DST can and cannot do. This post gives those numbers and says plainly what they cannot tell you.

The ruling that defines the product

Rev. Rul. 2004-86 is the IRS’s only published ruling on exchanging into a DST. Its facts are the template every offering still follows: a trust holds one property subject to a nonrecourse loan and a ten-year net lease; the trustee’s activities “are limited to the collection and distribution of income”; the trustee may not accept new contributions, may not “renegotiate the terms of the debt” or the lease, may not lease to anyone but the existing tenant except on its bankruptcy, and may make “only minor non-structural modifications” to the property. On those facts the trust is an investment trust under Reg. section 301.7701-4(c), and an investor “may exchange real property for an interest in the Delaware statutory trust described above without recognition of gain or loss under section 1031.”

The ruling then lists the powers that break the result: disposing of the property and acquiring new property, renegotiating or re-leasing, refinancing, investing cash to profit from market fluctuations, or making more than minor modifications. A trust with any of them is a partnership for tax purposes, and a partnership interest is not like-kind property. Those limits are the reason a DST cannot raise capital for repairs, cannot refinance and cannot be actively managed, which the seven deadly sins page explains in investor terms.

How DSTs are sold: Form D

DST interests are securities sold in private placements under Regulation D, usually Rule 506(b), to accredited investors; see is a DST a security and who can sell it. Each offering files a Form D, a notice of exempt offering that reports the issuer, the date of first sale, the amount sold and the states in which sales were made. The SEC publishes these as quarterly Form D data sets covering September 2009 through June 2026.

The SEC’s own Regulation D statistics give the market the DST sits inside. For 2025, the SEC counted 34,553 initial Regulation D offerings reporting $2,391.5 billion raised (page updated September 22, 2026) (source). The staff’s March 2025 report counted 32,554 new Form D offerings and $2,148 billion for 2024, and 35,080 offerings and $2,750 billion for 2023 (source). The SEC adds a caution that applies equally to DST counts: filing a Form D “is not a condition to claiming a Regulation D safe harbor,” so the statistics “could underestimate the true number of offerings.”

A rough count from the filings themselves

Form D has no box for “1031 DST.” The closest public measure is a full-text search of EDGAR for Form D filings that contain the phrase “Delaware statutory trust.” Run on September 30, 2026, that search returned 343 filings dated in 2023, 297 in 2024, 374 in 2025 and 347 between January 1 and September 30, 2026 (search tool).

Read those with four caveats. The count includes amended filings as well as new ones. It includes any issuer that happens to be organised as a Delaware statutory trust, including some that are not 1031 programs. It misses offerings whose Form D does not use the phrase. And, per the SEC, some offerings never file. What the series does show is that the first three quarters of 2026 are already close to the whole of 2025.

Asset mix: what can be verified and what cannot

No public source aggregates DST holdings by property type. Each offering’s private placement memorandum and Form D identify the property, so the mix of any one trust is verifiable; the mix of the market is not. Our own traditional DST sourcing covers properties across healthcare, industrial and multifamily, which is a statement about what we review, not about the market. For the figures that would complete this post, annual equity raised, sponsor counts and average offering size, there is no primary source, and we leave them out rather than cite a vendor.

What the filings are good for

For an investor the useful move is not the aggregate but the specific. Before signing a subscription agreement, pull the trust’s Form D on EDGAR: it shows when the first sale occurred, how much has been sold, the minimum investment reported, and the sales compensation disclosed. Then read the trust agreement against the five powers in Rev. Rul. 2004-86. A trust that can refinance or re-lease is not the product the ruling describes, whatever the marketing says. A DST interest is illiquid, the sponsor controls the asset for the life of the trust, and distributions depend on one or a few tenants; those are structural features of the product, not risks of a particular sponsor.

What to do now

1. Decide how much of your net worth belongs in trust interests at all; see how much net worth into DSTs.
2. For any offering you are shown, locate its Form D on EDGAR and compare the amount sold and first-sale date with what the sponsor tells you.
3. If your exchange needs debt replacement or liquidity rather than income, compare a cash out DST with a traditional trust; the DST hub sets out the differences.
4. Request a proposal with your sale date and the debt on the relinquished property; the structure follows from those two facts.

Sources

• Rev. Rul. 2004-86
• SEC, Form D Data Sets
• SEC, Regulation D Offerings statistics (updated September 22, 2026)
• SEC Division of Economic and Risk Analysis, Market Statistics of Exempt Offerings under Regulations A, D, and Crowdfunding (March 2025)
• EDGAR full-text search, Form D filings containing “Delaware statutory trust”