Syndication Fund 506c Investor Rules and Regulations

And I’m performing what we call substantial duties, you know, helping out however I can help out and then you know, once I do that, then Nihlus is as good as your list and we can use all of our lists, but I have to do I have to perform substantial duties, you have to do real work basically, right. And you still can’t pay me based on how much money I bring in. It’s kind of you’re paying me, you know that 8020 split the week that 20% that we talked about instead of being you know, 10% to you 10% to Cody, you know, I might get 2% of that maybe got it.

Okay, so if I if I knew somebody is like, Look, I just I just know everybody in town, they are always asking me to invest in deals, but I’m not actively looking for deals anymore. And I wanted that person’s Rolodex, I would have to have two things. One, they would have to be part of my sponsorship team, which means they would have to be part owner of that 20% They would be front facing meaning I could they could pull up the company’s website and they would see that person’s name as part of the sponsorship team.

And then to they would actually have to perform some sort of duties like maybe I’ll throw this out there. Maybe it’s something like they are verifying that people are actually accredited and they’re going they’re actually doing the duty of taking people through that process, or what would they be doing? Now it’s got to be substantial. I mean, even just being an investor relations person, think of it this way once the deal closes, right.

So you finished the rage, you bought the property? What are they doing now? You’re doing anything? You know, they are they acid managing? Are they are they helping you go down and you know, run? What are they doing after you close? Because if all they’re doing all this little work on on the front end, and then once it closes there, they’re no longer involved, then that’s probably not going to work either. Okay, right.

The one thing you could do, and I hate to even sometimes go in there because there’s actually there’s no there’s no exemption at the federal level. But theoretically, if you’re really careful, this would literally be it’s hard to do with hypotheticals with its facts and circumstances but you could get paid. Like the reason it came up because you just mentioned that thing, you could get a thought you could get paid not to raise capital, that list that you mentioned, you could become a finder, right?

So if you can be a finder, if I said pays, I’ll pay you $10,000 For that list that you just mentioned, right, I’ll pay you 10,000. If you give me that list, and then obviously, with that list, I can do whatever I want with an email people and spam them or do whatever I wanted to do, then you’re not getting paid to raise capital, you’re getting paid for access to that list. The problem is, it’s rare, you know, most of the time, that doesn’t work most of time, there’s going to be some kind of the value of the list is actually the introduction to that list.

That’s right. So the introduction is the is the tricky part, right? Because now, you know, are you recommending securities? You know, that’s where you get really get tied into that gray line of crossing over to being a broker acting as a broker, because you’re making an introduction? Again, theoretically, if all they said was pace, please meet Johnny, Johnny’s looking to invest and I know you have a deal. I’ll let you guys connect from there. A little bit of a gray area, but not a little bit, a lot of a gray area.

But there’s an argument to be made. Well, I’m not getting paid to raise money. I’m paying for the introduction. But the problem is nobody. People can’t help help themselves, right. So they’ll say, Oh, this is pays us a really good spot. You know, right there, boom, I just crossed the line because I’m, I’m saying sponsors, base got a really good deal. He’s a great guy. So it becomes a really, really gray area. And like I said, some states even have a registered finders, but they don’t have anything like that at the federal level.

So you’re always risking even the fat guy. So this the way or the way around this or not even around this, the way to just do it right is if somebody comes in and says, Hey, I’ve got relationships that have money. The only caveat to that is that those people whoever bring that in and have ownership in the sponsorship team, have to do activities beyond the closing of the property could be maybe running all the financials and handling all the documentation and running the books, filing the taxes, doing all that stuff.