Managing Private Money

[Uneeq Khan]

I have some private money I can use from multiple people. How should I go about managing it? Do I create one checking account and have everyone transfer money in there? Would this get flagged by the FBI if there's transfer of 40k to 100k going into it? Or do I get a lawyer and do an escrow? 

[Doug Smith]

I would be very careful as it sounds like you might be creating a security by managing money in a pool. Reg D (Particularly 506(c)) is the exemption from registration that most funds like ours use, but it has strict rules on who you can take money from (accredited/qualified investors). We have a private offering memorandum set up to create the fund and a management agreement between the fund and our company to manage the fund. We don't do business in NJ, so I don't have an NJ attorney to refer you to, but you would want to chat with a securities attorney about the possibility of forming a Reg D offering if you are accepting $ from a lot of people. If it's just one or two in a partnership of some sort, then that's a different story. I hope that helps. Good luck!