X0306 4 2016-02-23 0 0001412502 Sterling Real Estate Trust NONE 0001519609 Regan Kenneth P 1711 GOLD DRIVE SOUTH SUITE 100 FARGO ND 58103 0 1 1 1 Chief Executive Officer Trustee Limited Partnership Units 2016-02-23 5 J 0 E 4074.0310 15.50 D Common Shares 4074.0310 0.000 I by Kenneth P Regan, LLC Limited Partnership Units 2016-02-23 5 J 0 E 4074.0310 15.5 A Common Shares 4074.0310 2059740.8500 D Pursuant to the LLLP Agreement of the operating partnership, holders of limited partnership units may, after a two year holding period, elect to have their limited partnership units redeemed. Upon a redemption request, Sterling Real Estate Trust has the option to purchase the limited partnership units directly, either in cash or in common shares of beneficial interest at an exchange rate of one-to-one. These derivative securities do not have an expiration date. Represents a transfer of shares held indirectly by an LLC to Mr. Regan for no consideration. The excercisable date is not applicable as no limited partnership units remain in the account. These Limited Partnership Units may be redeemed as described under footnote 1 anytime after a two year holding period. /s/Bradley J. Swenson Attorney-in-Fact 2016-02-25