1 deal, 5 private lenders & 5 trust deeds, do I need SEC filing?

[Manuel Angeles]

I am looking to purchase an investment property ($500k purchase price).

I have 5 private lenders to provide $100k each.

Each will have a separate trust deed - in 1st, 2nd, 3rd, 4th, 5th position.

Since I am pooling investor money into one investment, do I need to file this with the SEC as a security?

[Tim Herman]

@Manuel Angeles I would hate to be the lender in the fifth place ( who gets recorded in what order). If you don't pay then they have to pay the preceding 4 loans so they don't get wiped out in a foreclosure. It would be better to have one first place loan that each owns 20%, this way they all share the risk you won't pay. I would consult with a good attorney on drawing this up.