Sending mailers for private money

[Michael B.]

Hey everyone, I recently read Susan Lassiter's book "Getting the money." And I just started reading @Matt Faircloth's "Raising Private Capital." 

Susan's way of finding private lenders is to use Listsource -> "Private Party Lender Prosepcts" and send mailers to this list. To be SEC compliant her mailers say something like "The fact that you recently invested in real estate makes me realize that we should talk." After the first meeting with prospects she waits 45 days without presenting a deal to show a pre-existing relationship. 

What is your guys' take on this strategy? Has any of you ever talked to an attorney about this way of finding private lenders? I obviously don't want to get in trouble with the SEC. I'm not trying to do big syndication deals. I usually buy SFRs and small multi units in the Midwest that cash flow well.