In order for a TIC offering to be considered a real estate transaction for 1031 exchange purposes, it must follow the guidelines established in Revenue Procedure 2002-22. One of the guidelines states that there can be no more than 35 co-owners. This limitation effectively restricts the size of real estate transactions, as the investment minimum increases along with the purchase price of the property. As minimums increase, it becomes more difficult for TIC sponsors to assemble an investor group. Another limitation is the logistical effort required to create up to 35 single purpose entities (LLC's) and simultaneously underwrite and close multiple loans. Lenders frequently limit the number of co-owners in a TIC transaction to fewer than 35 in order to make the underwriting and closing process less cumbersome.