The short answer
A DST's mortgage is fixed at closing, and under Rev. Rul. 2004-86 the trustee may not renegotiate or refinance it except on the tenant's bankruptcy or insolvency, so rising interest rates do not change your monthly distribution; they change what the property is worth when the loan matures and the trust must sell. Leverage magnifies that: in the stress test below a one-point rise in cap rates costs an all-cash trust 23% of its equity, a 50%-leveraged trust 46%, and an 85%-leveraged zero-cash-flow trust more than its entire equity. The loan is non-recourse to you, which protects your other assets but not the money in the trust, and the sponsor's carve-out guarantees to the lender are the only personal liability in the structure.
At a glance
| Refinancing | Prohibited to the trustee except on tenant bankruptcy (Rev. Rul. 2004-86) |
|---|---|
| Typical leverage | About 50% loan-to-value in ordinary offerings; 70%+ in zero-cash-flow trusts |
| Maturity | Ruling's model uses a 10-year note; full balance due at maturity in the SEC-filed loan |
| Prepayment | Lockout, then defeasance or a premium of at least 1% (CF Summerfield DST loan) |
| Recourse | Non-recourse to the trust; investors sign nothing (Del. Code tit. 12 §3803) |
| Carve-outs | Sponsor or guarantor liable for fraud, misapplied rents, insurance lapses, reserve top-ups |
| Foreclosure | Amount realized equals the full loan balance (Reg. 1.1001-2) |
| Debt for your exchange | Your share of trust debt counts as debt taken on (Reg. 1.1031(d)-2) |
Because the trustee can neither refinance nor extend, interest-rate risk shows up at the loan's maturity rather than in your monthly check
Rev. Rul. 2004-86 approved a trust whose loan and lease were fixed for its entire life and whose trustee may not renegotiate the terms of the debt, and the SEC filing cited below from a REIT that invests in DSTs lists entering into new financing among the actions a signatory trustee is barred from taking. A DST therefore borrows once, at terms set before you invest, for a period that usually matches its planned hold.
That removes the payment-shock risk a floating-rate borrower faces and replaces it with an exit risk. When the loan matures the trust must sell the property or convert to the springing LLC, and the sale price depends on cap rates and on the financing a buyer can get that year. A rate spike in year eight of a ten-year loan is the scenario to test, not a rate spike in year two.
Two loan features decide how narrow that exit window is: a prepayment lockout followed by defeasance or a premium, and a full balance due at maturity. The CF Summerfield Multifamily DST loan filed with the SEC in 2021 has both, plus a lender-controlled debt-service reserve the trust is personally liable to replenish.
Stress test: a $10,000,000 property under a 10% rent drop and a one-point cap-rate rise, at 0%, 50% and 85% leverage
Hypothetical, before fees and reserves. The property earns $600,000 of net operating income and is bought at a 6% cap rate. The 50% trust borrows $5,000,000 at 5.5% interest-only, so it pays $275,000 of interest and starts with debt-service coverage above 2.0x; the 85% zero borrows $8,500,000 on an amortizing loan whose $600,000 of annual debt service equals the rent by design.
Cash yield on equity starts at 6.0% for the all-cash trust and 6.5% for the 50% trust; the zero pays nothing. Cut net operating income 10% to $540,000 and the all-cash yield falls to 5.4%, a 10% cut, while the 50% trust's cash after interest falls from $325,000 to $265,000, an 18% cut, and the zero's rent runs $60,000 short of its debt service, which is where the debt-service reserve, and then the lender, take over.
Now raise the exit cap rate one point to 7% on the reduced income: the property is worth about $7,700,000. The all-cash investors get back 77% of their money, a 23% loss. The 50% trust repays $5,000,000 and returns $2,700,000 on $5,000,000 of equity, a 46% loss. The zero owes $8,500,000 less whatever it has amortized, and at that price the equity is gone.
Interest-only versus amortizing, and what the maturity date does to your exit timing
An interest-only loan maximizes the distribution and leaves the whole principal due at maturity; an amortizing loan lowers the distribution and builds equity the sale can return. Neither can be changed mid-hold, so the choice is made when you pick the offering, and the PPM's loan summary states the rate, any interest-only period, the maturity date and the prepayment terms.
A maturity date is a forced sale date. If the loan matures in a year when buyers cannot finance at yesterday's rates, the trust sells into that market anyway, unless the loan documents allow an extension the trustee can accept without renegotiating; ask for that clause. Portfolio DSTs with several loans maturing in different years spread this risk, which the portfolio analysis page covers.
The prepayment side matters when the sponsor wants to sell early into a strong market: lockouts and defeasance costs can make a year-four sale uneconomic even when the price is right, so the realistic hold is the loan term, not the sponsor's target.
Non-recourse debt keeps the lender away from your other assets, not away from your equity, and the sponsor signs the carve-outs
Delaware Code title 12, section 3803(a) gives beneficial owners the same limitation of personal liability as stockholders of a Delaware corporation, and the ruling's facts state that neither the trust nor its owners are personally liable on the note. The lender's remedy is the property; a deficiency judgment against you is not available under a non-recourse loan.
The exceptions are the carve-outs. In the CF Summerfield loan the borrower trust is personally liable for losses from misapplied rents and security deposits, lapsed insurance, misapplied insurance or condemnation proceeds and fraud, and for replenishing the debt-service reserve, with the REIT sponsor named as key principal and guarantor. The outline cited below makes the point that investors do not sign these guarantees, one reason DSTs displaced tenancy-in-common deals.
What non-recourse does not protect is the equity itself and your tax position. If the lender forecloses, Reg. 1.1001-2 sets your amount realized at the full loan balance whether or not the property is worth it, so the deferred gain and depreciation come due in a year you received nothing; the bankruptcy page covers the sequence. Separately, a REIT's 2025 annual report cited below describes loans it makes to investors for up to 50% of the price of its DST interests; that debt is yours, not the trust's, and sits outside every protection above.
When an all-cash DST is the better answer despite the lower headline yield
A debt-free trust has no maturity date, no lender ahead of you in the cash waterfall and no covenant that can trip; the outline cited below notes that a 50% loan is typical in DST offerings, so a 0% trust is a deliberate choice against the market's default. It fits an exchanger who paid off the relinquished property or who is replacing debt through a small zero, and a retiree who cares more about the floor than the ceiling.
The costs are a lower projected distribution, no debt replacement for your exchange, and less depreciation per dollar because you own less building per dollar of equity; the distributions page and the yield versus total return page show how to compare the two on a like basis. Confirm the debt-replacement arithmetic for your own exchange with your CPA or attorney before choosing either.
- Choose leverage when you must replace debt and want income at the same time, and you can absorb an exit at the loan's maturity.
- Choose a zero plus debt-free trusts when you must replace debt but do not want it standing behind your income.
- Choose all-cash when you have no debt to replace, or when a forced sale date is the risk you least want.
Related questions
Does a DST's loan count toward the debt I must replace in my exchange?
Yes; your proportionate share of the trust's non-recourse debt is debt you take on for Reg. 1.1031(d)-2, so a $400,000 investment in a 50% leveraged trust replaces about $400,000 of mortgage. The exchange equation guide works the full formula.
If rates fall, can the sponsor refinance to raise my distribution?
No; refinancing is one of the powers the trustee gives up to keep the trust eligible for 1031 treatment. Lower rates help only at exit, through the price a financed buyer can pay.
Can the lender force the trust to sell or convert?
A default can, and loan documents can be drafted to require lender consent to a conversion; the outline cited below flags lender powers to compel a transfer distribution as a drafting point to avoid, since a forced conversion changes your tax status.
Is a 40% loan safer than a 60% loan in a meaningful way?
In the stress test above the same one-point cap-rate rise on reduced income costs 38% of equity at 40% leverage, 46% at 50% and 58% at 60%; the maturity year and the debt-service coverage in the PPM tell you more than the loan-to-value figure alone.
What does the sponsor's carve-out guarantee mean for me?
It means the lender has someone to pursue if rents are misapplied or insurance lapses, which protects the trust's property, and it means the sponsor's interests and yours can diverge in a workout; the sponsor evaluation page covers the balance-sheet questions to ask.
Sources
Checked against these publications on September 19, 2026. Rules and figures change; confirm the current version with your CPA or attorney before you act. This page is general information, not tax or legal advice.
- Rev. Rul. 2004-86 (fixed loan and lease; trustee may not renegotiate debt)
- CF Summerfield Multifamily DST loan agreement, SEC EDGAR exhibit (non-recourse carve-outs, lockout, defeasance, reserve)
- Strategic Student & Senior Housing Trust 10-K (trustee restrictions; master-tenant and foreclosure risk)
- Ares Real Estate Income Trust 10-K for 2025 (DST program; loans to investors up to 50% of price)
- Delaware Code title 12, chapter 38, subchapter I (§3803 limitation of liability)
- Treas. Reg. §1.1001-2 (amount realized on discharge of non-recourse debt)
- Treas. Reg. §1.1031(d)-2 (liabilities assumed as consideration)
- David L. Silverman, Delaware Statutory Trusts outline (2024), leverage and carve-outs
- Wealthstone Group on zero-coupon DST leverage levels
