According to federal law, an REIT must meet all of the following requirements except. it must distribute 90% or more of its taxable annual earnings to shareholders. it must hire independent real estate professionals to perform certain management activities. it must have at least 100 shareholders, with no more than half of all shares owned by five or fewer people. it must directly invest in apartment houses, shopping malls, and other commercial property. it must invest at least 70% of the total assets in real estate.