Real estate syndication Rule 506(c)

[Storm S.]

Hello I was wondering if any real estate syndicators on here who use exemption 506(c)? Are you able to put out a ad searching for investors without specifying what the deal is and do I need to file form d with the sec before putting out the ad or within 15 days of taking money from a investor?

[Kim Lisa Taylor]

Thanks @Alina T. for your mention.

Rule 506(c) was designed to allow a Syndicator to advertise "an offering". It's not a carte blanche rule that allows anyone to advertise for investors without a specific offering. 

Technically, for any Rule 506 offering (b or c) the Syndicator needs to file a Form D with the SEC within 15 days of when the first investor's funds become "irrevocably committed".  State securities notices must also be filed where the investor claims residency. 

Additionally, for a Rule 506(c) offering, the investor must provide verification that they are accredited. Any third party verification must have been completed within 90 days of the investment.