Frankly, I have no clue. But I saw this post didn't have a response, and I didn't want it to be lost. Bottom line, the FAFSA rep at the intended university will be able to help interpret the rules for your specific situation. A CPA may be able to help too.

A preliminary ask on ChatGPT (so take it as you see fit) said, "Yes—usually it’s still counted, but it depends on who controls the trust.

FAFSA treatment (key cases):

• Revocable / grantor trust (you or parent can change or revoke it): → Counted as an asset at current net value.
• Irrevocable trust, but you/parent is beneficiary and can access principal or income: → Counted (asset and/or income).
• Irrevocable trust, no access or control, discretionary distributions only: → Not reported as an asset, but any distributions received count as income in the year received.

Rental property itself:

FAFSA counts non-primary real estate regardless of being in a trust if the filer has control or access.

Bottom line: Trust form alone doesn’t shelter it—control and access do. If this is for planning, review trust terms carefully before relying on FAFSA outcomes."