Multiple tenant LLCs under common control are one exposure. Concentration limits apply to tenant groups, not to who sources a property.
Aggregate by common control
The research suggests an operator-group target of no more than 15% with a hard cap of 20%, measured by the largest share of gross rent, NOI and acquisition cost and aggregating common control, guarantees and dependent affiliates. These are research recommendations; final policy is set by governing documents.
Sourcing is a different question
Where a property comes from — including Steward Housing sourcing — is not capped by the tenant-group limit. Sourcing relationships are instead addressed by related-party conflict checks: independent valuation, disclosure, recusal and documented approval. A tenant cap should not be read as a cap on sponsor sourcing, and vice versa.
Shared funding can fail together
Several tenants may depend on the same clinical billers, grant programs or referral channels. The research recommends aggregating those exposures and keeping a qualified alternative-operator bench by catchment. Early portfolios should not be presented as diversified before limits are met.