Talk to a CPA before doing what you are considering, because from what you have described this would be trouble if you are audited.

The assets must be valued to market value annually, which for RE means an appraisal on each parcel and Trustees may not like having trust funds flowing through an RE management firm as they audit thier funds.

If I were you, I would amend your tax returns to correct this, and pay the taxes and penalties now rather than risking getting it discovered during an audit.

The name will pop up and you won't be registered as an operating Trust company with the state finance people, they will want to know what you are doing holding yourself out to the public as an unregulated bank or trust department.If you use Realty, expect the Real Estate Commission to come knocking, as they audit real estate companies.

I can tell you from working for a fortune 100 financial services firm and now a self-directed IRA custodian that the audit risk is much higher for any plan without a custodian, so keep that in mind. 

Several contractor friends have been 'sales tax' audited recently & it was a very expensive experience.

@Mathuw Chandler   I would suggest getting an "Energy Audit". 

You might get away with calling it a short term capital gain (and avoiding SET), but I don't think that position will survive an audit.

.- Typically, the most expensive component is the replacement reserve, but there are also HUD inspection fees, a phase 1, an application fee of 1/3 of 1% of the loan amount, MIP if over 80%, and audit fee, etc.- HUD 223(f) loans go up to 85% LTV on a 35 year term-Typical PPP is 10 years.

Intent can change over time, so understand that if ever audited, the IRS may take the stance that you were not building with investment intent and rather meant to spec build as a business.