ADREX Diversified 12 DST claimed an exemption prohibiting general solicitation. Its predecessor claimed one permitting it, subject to accredited-investor verification.
Both are Delaware Statutory Trust (DST) offerings whose notices name Ares (ADREX) as sponsor, rendered in the filings' own wording as Ares Diversified Real Estate Exchange LLC, and the difference between them is the exemption each claimed. The Form D for 12, filed August 31, 2026, claims Rule 506(b), under which general solicitation and advertising are prohibited and up to 35 non-accredited purchasers meeting sophistication requirements may participate alongside accredited investors. The notice for ADREX Diversified 11 DST, dated February 27, 2026, claimed 506(c), where advertising is permitted and every purchaser must be verified as accredited.
The filing does not say why the election changed. It names Ares Wealth Management Solutions, LLC as the sole broker-dealer. The exemption does not establish whether purchasers are existing customers or already known to the sponsor or broker-dealer.
Term | ADREX Diversified 12 DST | Trailing-twelve-month median across tracked DST Form D filings, including amendments |
|---|---|---|
Maximum offering amount | $537,906,336 | $48,917,049 |
Minimum investment | $500,000 | $100,000 |
Estimated sales commissions | $26,895,317 | |
Estimated commissions as share of maximum offering | 5.0% | 6.5% |
Amount sold as of August 31, 2026 | $0 |
The minimum is unchanged from 11's notice. The minimum and maximum offering amount exceed the filing-level medians. Of the 227 published Active Trusts in Top1031's directory as of September 8, 2026, five are ADREX offerings. This count includes fully subscribed offerings and excludes delisted records.
Two of them precede this one in the recent record.
Trust | Form D date | Maximum offering | Amount sold as reported |
|---|---|---|---|
ADREX Diversified 10 DST | $539,559,229 | $381,006,617 as of the February 27, 2026 amendment | |
ADREX Diversified 11 DST | February 27, 2026 | $476,308,540 | $0 at filing |
The dates in that first row and the date on 11's first notice are the same day: the prior Trust's amendment reported an unsold balance on the day the next Trust's notice was filed.
As for the asset, the industry line reads Other Real Estate. The notice does not identify properties, property-level debt, or a holding period. Its related-person list identifies ADREX Diversified 12 Manager LLC as Manager and ADREX Diversified TRS LLC as Depositor. No matching trade coverage was located in the searches reviewed for this report through September 8, 2026.
For a raise of this scale, the notice names exactly one human being: Stefanie Sommers, who signed as Managing Director and Assistant Secretary. In ADREX 10's February amendment her title reads Managing Director and Associate General Counsel. No other ADREX principal appears in either document.