Legality of Private Money & SEC

[Ken Latchers]

Given the SEC rules, I see some real estate course gurus who seem basically to pursue private money as follows:

1) You contacted us about our course (perhaps through one of thier spams, facebook or LinkedIn postings.

2) Therefore, we "know" you (and did not get you directly through the now-illegal advertising such as newspaper ads). NOTE: I noticed statements to this effect (you know us because...) in their emails

3) How would you like to become one of our private money lenders? Why, here is a great 16-unit apartment and you could get up to 15% by jumping in now...

Is this REALLY fulfilling the SEC requirements/exceptions (REG D, etc.)