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The three-property rule lets an exchanger identify up to three replacement properties regardless of value, but Detroit exchangers who want a longer list, spreading proceeds across an industrial building near the I-94 corridor, a small multifamily property in the city, and a net-leased pad on a mile road, need the 200 percent rule instead: identify as many properties as needed as long as their combined fair market value does not exceed twice the value of the relinquished property.
Running the Ceiling Like a Budget Cap
We treat the 200 percent ceiling the way an estimator treats a hard construction budget: every candidate property gets a line, a current asking or underwritten value, and a running total against the cap. If a START EXCHANGE REVIEW nets $2.4 million, the identification list has a ceiling of $4.8 million in aggregate value across every property named, and every addition to the list gets checked against that total before it goes on the notice, not after.
Why Detroit Investors Reach for This Rule
Detroit's mix of asset types is exactly the situation this rule was built for. An investor selling one larger holding can spread the reinvestment across several smaller assets, an industrial bay in a supplier corridor, a small apartment building in a recovering Midtown-adjacent neighborhood, a net-leased retail pad along a mile road, and a fractional DST allocation, without being capped at three total properties. The tradeoff is that every additional line item on the list adds diligence work and closing risk, since more moving pieces means more chances for one deal to slip.
Building the Aggregate Value Line Item by Line Item
A defensible 200 percent identification list needs each property's value supported the same way a bid package supports a cost line: a broker opinion or appraisal-grade estimate, not a guess. We assemble that support before the notice goes to the qualified intermediary, so the aggregate figure holds up if a lender, CPA, or the investor's own later review questions how a value was reached.
- Confirm the relinquished-property sale price and calculate the 200 percent ceiling first
- Assign a supported current value to every candidate property before adding it to the list
- Track the running total against the ceiling as candidates are added or dropped
- Flag any candidate whose value is soft or under negotiation for re-check closer to day 45
Where This Overlaps With the 95 Percent Fallback
If the list ends up close to the ceiling, or if the investor is unsure how many of the identified properties will actually close, the 95 percent rule becomes the relevant comparison: it drops the value ceiling entirely but requires the investor to actually acquire at least 95 percent of the aggregate value identified. We walk through both structures side by side before day 45 so the choice reflects how confident the investor is in each property's closing probability rather than which rule sounds simplest on paper.
Keeping the Notice Clean for the Intermediary
The written identification itself has to name each property unambiguously, typically street address or legal description, and the qualified intermediary needs that notice inside the 45-day window regardless of which counting rule applies. We keep a single working document that tracks the aggregate value math on one side and the exact identification language on the other, so what gets filed with the QI matches what was actually underwritten, not a rounded or informal version of it.
A Detroit list built under this rule commonly pairs a mid-size industrial building near a supplier corridor with a smaller multifamily property and a net-leased pad on a mile road, each carrying its own supported value, since the ceiling calculation only cares about the combined total, not how the total is distributed across asset types. Recalculating the running total every time a broker opinion changes on any single property keeps the list from drifting past the ceiling without anyone noticing until the notice is already filed.
Common 1031 Exchange Questions
Does the 200 percent rule limit how many properties I can identify?
No. There is no cap on the number of properties under this rule, only a cap on their combined fair market value, which cannot exceed 200 percent of what the relinquished property sold for.
What counts toward the 200 percent value ceiling?
The aggregate fair market value of every property named on the written identification counts, including fractional interests such as a DST allocation. Properties later dropped from the list before day 45 do not count against the final notice.
Is the 200 percent rule better than the three-property rule for a Detroit investor?
It depends on the reinvestment plan. An investor consolidating into one or two larger Detroit assets usually has no need for it, while an investor spreading proceeds across several smaller properties across asset classes typically needs the 200 percent structure to stay compliant.
What happens if my identification list exceeds the 200 percent ceiling by mistake?
If the aggregate value of everything identified exceeds the ceiling, the identification for property counting purposes can fail unless the investor still qualifies under the 95 percent rule by acquiring nearly all of the value identified. This is a technical area where confirming the specific facts with a qualified intermediary or tax advisor before day 45 matters.
Can I combine an industrial building with a DST allocation on the same 200 percent list?
Yes, direct real property and DST interests can both appear on the same identification list, and their values are combined for the ceiling calculation the same way any other properties would be.




