506(b) rules on accredited investors?

[Michael Orlando]

Hey all! We're raising capital for a couple killer deals here in Cleveland. We've done some JV's but are syndicating these deals and doing a 506(b). I have a pretty straightforward question.. if we have a personal relationship with an investor and they mention they have someone who'd probably be interested and is accredited, do we still need a relationship with the accredited investor? Or since they're accredited, do we not need that same relationship?

[Evan Polaski]

@Michael Orlando, as noted, you still need a relationship with them.  At the end of the day, your securities and/or compliance attorney will have the best answer, but typically you are going to need to have a conversation with them, probably exchange several emails, and have some detailed notes, should this ever be investigated by the SEC.  

But the key to me is that it needs to your YOUR relationship, not friend of a friend relationship.