506(b) private offering necessary IF raising capital amongst friends and family?

[Adriel Cisneros]

Good afternoon -- 

IF I am raising funds amongst friends and family with a pre existing relationship, is a JV agreement more applicable than a syndication with both accredited and non accredited investors?

Stated differently -- do I need to register the offering IF my partners are *only* friends and family? 

Acquisition size will not exceed 2.5 mm USD with equity contributed by approximately 7 to 12 partners. 

Follow up question: 

Any lender recommendation in south Florida who would underwrite small multifamily using a JV structure?

Thanks!