Forming LLC to broker money to local investors?

[Account Closed]

Hello everyone,

I have recently formed relationships with a number of real estate investors in my area (Akron / Cleveland, OH) via a law degree I started last August.

I happen to have good relationships with people more towards the Columbus area who have resources and are always looking for avenues through which they can invest. I would like to broker some of their money up to the connections I have in northeast Ohio. 

I understand that there are SEC regulations regarding operations of securities funds and I certainly don't want to violate any of them. I am not attempting to start a REIT. However, I would like to be able to collect money and distribute it to investors in my area; while standing in the middle and taking a mgmt fee. Does anyone have an opinion on if it would be legal for me to form an LLC with myself owning 10%, bringing no money to the table, the other "partner" owning 90% and keeping a type of preferred stock entitling them to receive their own money back before any "common stock" distributions are made?

Is the SEC okay with this or is it seen as a workaround that does not pass the smell test?

Thank you!!!