The 100 shareholder test is generally not a problem for actively traded public REITs or for non-traded REITs (REITs that are listed but are thinly traded). However, private REITs, which are often used in real estate private equity structures, would have a hard time meeting this test if not for the existence of REIT shareholder accommodation services that help secure shareholders for the REIT. The shareholders secured by shareholder accommodation service firms are typically preferred shareholders with no voting rights who receive an annual dividend coupon in exchange for their investment. This is allowed because there are no restrictions stating that a REIT can’t have more than one class of stock, and all shareholders are accounted for in the 100 shareholder test. A REIT that has 100 preferred shareholders who receive an annual dividend and a partnership owning 100% of the common stock of the REIT will pass the 100 shareholder test.