SpawnActor is allocating the space so the best I could do is pass a reference holder for it, circumventing whatever bug I’m seeing. Certainly seems like this must be a bug as any error situation should be returning nullptr (or generating an exception). Definitely I planned to try to capture it just to see what would happen but I do know that Destroy was not called on any actors during that period so I don’t think its getting garbage collected - its just passing back an invalid pointer.
I should also say that this is a behavior difference between running PIE and standalone.