Upon IC approval to pursue a market, the acquisitions team moves quickly to establish on-the-ground intelligence, identify target sites, and build broker and city relationships. The market tour is the primary vehicle for this effort and must be executed with intention and preparation.

• Within three weeks of IC approval, the Director of Acquisitions and the analyst coordinate a market tour date.
• At least one week prior to the tour, the Director and analyst compile the Market Tour Packet — a comprehensive briefing document covering target areas, candidate sites, broker contacts, city planning staff, key questions, and a preliminary underwrite.
• Prior to departure, the Director and analyst schedule a pre-tour review meeting with the VP of Acquisitions and the EVP of Development to confirm target areas, potential sites, and tour objectives.

• Identify and physically evaluate target areas and specific sites within the desired walking radius.
• Meet with potential brokers who are active in the student housing or commercial land market.
• Meet with the city planning department, civil engineer, and/or land use attorney to understand the entitlement environment and any active or pending zoning changes.
• Tour campus to understand circulation patterns, student housing demand drivers, and proximity dynamics.
• Tour comparable properties to evaluate rent levels, amenity programming, occupancy, and lease pace.

• After the tour, the Director and analyst schedule a debrief with the VP of Acquisitions and EVP of Development covering tour highlights, target areas, candidate sites, completed Market Tour Questions, and a test underwrite.
• The Market Tour Packet and completed Market Tour Questions are uploaded to TermSheet to document the pursuit activity.

Once the market tour is complete, site selection begins in earnest. This process combines data-driven spatial analysis via LandVision with ground-level market knowledge gained during the tour.

• The analyst configures LandVision with the applicable layers for the target market. Layers include a combination of manual entries (e.g., pinned parcels, walking radius overlays) and shapefile uploads (e.g., zoning districts, flood zones, future land use maps).
• Reference the LandVision Layer Guide for the standard layer configuration for student housing markets.

• Walking radius first. Begin with sites that fall within our target walking radius from campus. These provide the "fall out of bed" location that is central to the Subtext product thesis.
• Common ownership in assemblages. Look for parcels with common ownership to reduce the number of counterparties in an assemblage. Fewer sellers means fewer negotiating paths, faster execution, and reduced risk of one party derailing the deal.
• Zoning analysis. Review current zoning, the future land use plan, and recent zoning approvals in the market to identify locations where our product is permitted by right or achievable through a manageable entitlement process.
• Product type viability. Determine what product type is financially viable in the market based on achievable rents, construction pricing, property taxes, and operating expenses. Use the following minimum site size thresholds as a guide: High-rise requires at least 0.5 acres, podium requires at least 1 acre, and wrap requires at least 2 acres.

Once the target site list is finalized, the team initiates outreach to landowners following the Owner Discussion Script. This script provides a framework for the initial conversation and helps ensure consistency in how Subtext introduces itself and its interest in the site.

Site underwriting happens in parallel with — and closely informs — the site selection and entitlement processes. Before a model or schedule is submitted for internal review, the analyst must have a clear understanding of the site's zoning, potential product program, and construction constraints.

• Zoning & Entitlements First. Before modeling begins in earnest, the analyst should understand what is achievable on the site from a zoning and entitlement standpoint. What is allowed by right? What requires a variance or rezoning? What are the development standards (height, setbacks, FAR, parking, etc.)?
• Program Development. Based on site constraints and market demand, develop a preliminary unit mix and program that is financially viable. The Program Document captures the project's key parameters — unit count, unit mix, gross square footage, amenity program, and parking — and is the foundation on which the financial model is built.
• Financial Model. Run the financial model using the approved Subtext underwriting template. Ensure the model reflects current construction cost assumptions, market rents from the Phase 2 analysis, and current financing assumptions. All models must be reviewed by the Director of Acquisitions before submission to leadership.
• Schedule. Develop a preliminary development schedule that reflects realistic entitlement timelines, design milestones, permit timelines, construction duration, and lease-up. Reference the Schedule Best Practices document when building the project schedule.
• Test-Fit. Use TestFit to validate that the program fits on the site and is architecturally achievable. TestFit should be used early and often as program parameters are refined. Reference the TestFit Training Videos for guidance.

Before any LOI is submitted, the acquisition must be internally reviewed and approved. The following process and submission requirements apply to all LOI activity.

The following materials must be prepared and submitted for internal review before an LOI is drafted or submitted to a seller:

• Updated financial model reflecting current program, rents, costs, and financing assumptions
• Preliminary project schedule
• Program document with proposed unit mix, square footage, and parking
• Summary of entitlement strategy and key risks
• Completed LOI drafting questions (see resource link below)

Subtext LOIs for land acquisitions are structured to reflect the following standard terms and timelines. Specific terms will vary by deal, but the following represent our typical starting point:

• Earnest Money Deposit (EMD): Negotiated based on seller expectations; initial deposit is typically hard at a later milestone or upon satisfaction of key contingencies.
• Due Diligence Period: Typically 90–120 days, during which the deposit is refundable. Extension options are desirable.
• Closing Timeline: Typically 30 days following due diligence expiration, subject to entitlement milestones where applicable.
• Contingencies: Standard contingencies include entitlement, financing, and environmental clearance. The extent of hard money and when it goes non-refundable is a key negotiating point.

The following provisions are commonly negotiated in land acquisition LOIs and Purchase Agreements. The list below reflects areas where Subtext has flexibility and items we typically push back on:

• Hard money timing: Push to delay hard money as long as possible, ideally until after receipt of entitlement approvals or a major milestone.
• Termination rights: Preserve broad termination rights during due diligence and at entitlement milestones. Sellers will push for more limited termination triggers.
• Closing extensions: Negotiate the right to extend closing at a reasonable cost if entitlements are delayed.
• Seller representations: Negotiate for robust reps on environmental condition, lease status, litigation, and title.
• Access rights: Ensure broad access rights for due diligence activities, including environmental testing, survey work, and soil borings.

A clean, thorough handoff from acquisitions to development is critical to ensuring nothing falls through the cracks during the transition. The following process governs how projects are formally transferred from the acquisitions team to the development team after LOI execution.

Due diligence is the period during which the development team investigates all material risks associated with the site. The goal is to fully understand the physical, legal, and environmental condition of the property before going hard on deposits and committing to close.

Entitlements are frequently the most time-consuming and unpredictable aspect of the pre-development process. Our approach prioritizes early stakeholder engagement, design efficiency, and proactive relationship building to maximize the probability of approval and minimize timeline risk.

• Before beginning any entitlement process, the development team must have a clear, documented understanding of every required approval — rezoning, variance, site plan, design review, conditional use permit, etc. — and the timeline associated with each.
• Understand submittal requirements for every application before beginning design. If the city cannot provide a checklist, review prior approved submittals and clarify with city staff. The goal is to advance design only as far as required for each submittal — avoid showing unnecessary details that could restrict future flexibility.
• Where renderings or visualizations are required for stakeholder presentations, clearly communicate that early materials represent conceptual designs subject to change.

• Invest time early in understanding what city stakeholders, planning staff, and neighborhood associations care about most. This intelligence should directly inform design decisions and talking points.
• Subtext's typical focus areas in entitlement discussions: streetscape quality, pedestrian experience, activation of ground-floor uses, community benefit provisions, and how the project relates to the surrounding neighborhood context.
• Frame the project as a community asset — create a safe, vibrant, active pedestrian environment that benefits both residents and the surrounding community.

• Do not wait for the formal application process to begin outreach. The development team should proactively meet with city staff, neighborhood associations, adjacent property owners, and other key stakeholders before submitting any application.
• The goal is to make stakeholders feel like partners in the process — give them a genuine opportunity to provide input before the plan is finalized.
• A project website should be live before any public stakeholder meeting. This serves as the primary reference point for community members and media.

Underwriting doesn't end at LOI — the financial model must be continuously updated throughout pre-development to reflect new information as it is gathered. The goal is to ensure the investment thesis remains intact as design, entitlements, and market conditions evolve.

• Unit Mix. The unit mix should be refined as the design progresses and as market data is updated. Changes to the unit mix have a direct impact on revenue projections and must be reflected in the model promptly.
• Supply and Demand Report. Maintain a current view of market supply and demand dynamics. The supply and demand report should be refreshed whenever a new project is announced, a comp delivers, or rent data is updated. This report underpins the absorption and rent growth assumptions in the model.
• Comp Property Report. Maintain an active comp set and update the comp property report to reflect current rent levels, occupancy, prelease pace, and amenity offerings. This report is the primary basis for the rent assumptions in the proforma.
• Operating Expenses. Operating expense assumptions should be benchmarked against comparable Subtext assets and current management fee expectations. Update expenses as construction costs, tax estimates, and management structure are refined through pre-development.

• Focus Groups and Surveys. Where possible, conduct resident focus groups and market surveys to validate unit mix assumptions, amenity preferences, and program decisions. Reference the standard survey questions template and review prior survey results from comparable Subtext markets before designing new research instruments.
• Survey results should inform — but not drive — program decisions. The development team is responsible for synthesizing resident input with financial constraints and market data.

• Design proposals should be solicited using a structured RFP process. The RFP should clearly define scope, schedule expectations, deliverables by phase, and fee structure.
• At-Risk Structure. Where possible, Subtext structures design contracts to bring major consultants (structural, MEP, civil) under the architect of record. This simplifies contract management, establishes clear liability, and reduces coordination gaps between disciplines.
• Reference the Design Proposal Best Practices document for guidance on evaluating proposals, negotiating fees, and structuring consultant agreements.

• The internal concept design process is governed by the Design Flow Chart, which defines deliverables, review milestones, and decision gates from schematic design through construction documents.
• Best practices for design set reviews: review sets systematically using the Design Deliverable Checklist; document all comments in writing; confirm responses from the design team in writing before proceeding to the next phase.
• Standard unit plans should be the starting point for all new projects. Deviations from standard plans require written justification and EVP approval.
• The Design Handbook and Outline Spec define Subtext's minimum product standards and should be incorporated into every project scope of work.
• Design metrics (cost per square foot, efficiency ratios, unit mix composition) should be tracked and benchmarked against prior projects throughout the design process.

VE should be approached proactively — not reactively. The standard VE items list captures categories where cost savings have been achieved on prior projects without compromising product quality or resident experience. The DM should reference this list when reviewing preliminary pricing and push for VE analysis before GMP is established.

The building permit process is a critical-path item that must be tracked with the same rigor as entitlements and design. Permitting timelines vary significantly by jurisdiction and can meaningfully impact the project schedule and cost if not planned for properly.

• Engage the city's building department early — ideally during entitlements — to understand the permitting process, required submissions, and review timelines for projects of this scale and type.
• Where available, pursue phased or foundation permits to allow early construction activities to begin while the full permit is under review.
• Identify the city's preferred plan review track (standard, expedited, third-party review) and build the appropriate timeline and cost into the project schedule and budget.
• The DM is responsible for maintaining a permit log that tracks all submitted, pending, approved, and expired permits on the project.
• Coordinate with the Preconstruction Manager to ensure all plan check comments are responded to promptly and that resubmittal timelines are tracked in the project schedule.

Projects require Investment Committee approval at multiple milestones throughout the development lifecycle, including initial market approval, project greenlight, capital events, and budget changes. The following guidance applies to all IC presentations.

• IC presentations should be concise, visually clear, and data-driven. The IC relies on the development team's analysis and judgment — present findings with confidence and a clear recommendation.
• All financial models presented to the IC must be reviewed and approved by the EVP before submission. No model goes to IC without EVP sign-off.
• Anticipate questions: prepare a diligence backup package covering key assumptions, market data, and sensitivities. Know the answers before the meeting.
• Meeting notes and the IC decision should be captured in TermSheet within 24 hours of the meeting.

Where Subtext has Co-GP partners on a project, the development team must understand and adhere to the approval rights and notification requirements set forth in the joint venture agreement. Failure to obtain required Co-GP approvals before acting can constitute a default under the JV agreement.

• At project kickoff, the DM should review the JV agreement with legal counsel and document all decisions that require Co-GP approval, consent, or notification.
• Maintain a Co-GP approval log and build approval timelines into the project schedule — Co-GP review periods can impact critical path milestones.
• Prepare Co-GP approval packages with the same rigor as IC presentations. Co-GP partners are sophisticated — provide complete, well-organized materials with adequate review time.
• All Co-GP communications on material items should be in writing and copied to the EVP.

The capital process encompasses the sourcing, negotiation, and closing of construction debt and equity for each project. The development team works closely with Subtext's capital markets relationships and external advisors to structure the optimal capital stack for each transaction.

• Recourse and Carve-outs. Construction loans are typically non-recourse with standard carve-outs. Push to limit the scope and definition of bad boy carve-outs and ensure they are symmetrical where possible.
• Interest Reserve. Ensure the interest reserve is sized appropriately for the full construction duration plus a contingency buffer. Under-reserved interest can create a liquidity crunch mid-construction.
• Completion Guarantee. Understand the completion guarantee terms before term sheet execution. Scope and duration should be carefully reviewed by legal counsel.
• Equity Funding Order. Confirm the equity funding waterfall and contribution timing with all equity partners before construction loan closing.
• Extension Options. Negotiate extension options on construction loans to protect against entitlement or construction delays.
• Lender Approval Rights. Review and limit lender approval rights over project decisions — overly broad approval rights can slow decision-making and create friction during construction.

During construction, the development team's primary responsibilities are budget management, schedule oversight, lender compliance, and contractor relationship management. The following guidance reflects Subtext's standard practices during the construction phase.

• The DM maintains the project budget on a continuous basis throughout construction. Budget variance reports are prepared monthly and reviewed with the EVP.
• All budget changes — regardless of size — must be documented via a formal change order or budget transfer process. Verbal approvals are not sufficient.
• The DM is responsible for ensuring the construction loan draw schedule aligns with the project budget and lender requirements. Draw packages must be complete and accurate before submission to the lender.
• Track contingency usage carefully. Alert the EVP when contingency falls below 50% of the original allocation so proactive steps can be taken.

• VE during construction should focus on scope changes that reduce cost without compromising the resident experience, design intent, or project schedule.
• All material VE changes must be reviewed by the EVP and design team before execution. Changes that affect the exterior, unit finishes, or amenity programming require additional scrutiny.
• Document all VE decisions in writing, including the rationale for acceptance or rejection, and maintain a running VE log throughout construction.

The Temporary Leasing Office (TLO) is a critical pre-opening asset that enables the leasing team to begin pre-leasing before the project delivers. The following process governs the TLO kick-off from initial planning through opening.

The Redzone period covers the final weeks before a project's opening and the initial weeks of operations, when all construction, leasing, marketing, and operational activities converge. This is one of the highest-risk periods in the project lifecycle and requires proactive coordination across every team.

• The DM is responsible for leading weekly Redzone meetings with representatives from construction, leasing, operations, marketing, and management during the final 90 days before opening.
• All open punch list items must be tracked in a shared punch list log, with owner assignments and target completion dates. The DM reviews the punch list with the GC weekly and escalates items at risk of missing the opening date.
• Certificate of Occupancy (CO) timing must be tracked closely and communicated to the leasing team, as it drives the move-in schedule.
• The development team coordinates the formal operations handoff, including the transfer of warranties, equipment manuals, as-built drawings, and all construction documentation to the property management team.

• Following stabilization, the DM prepares a project closeout report documenting final budget outcomes, schedule performance, key lessons learned, and recommendations for future projects.
• All project files, contracts, permits, and as-built drawings are archived in TermSheet upon project closeout.