506(b) for my small syndication deal

[Michael H.]

I recently closed on a property late last week where I pooled money from friends and family of $450,000. The structure is very fund like so it falls under "selling of a security". Unfortunately, I had not looked into it as much given the $ amounts.  Now, after researching, I realized that I have to hire a securities attorney to draft the PPM, subscription document, and file Form D exemption. Below are some questions I have before really discussing it with a attorney

1. Is it too late to get all of my documents in place? What if I am late? For example, Form D I believe is required 15 days when the sale happen

2. At a $450k raise, it feels like a small amount to register. Can I do the following:

A. Since I will be doing this more with other investors that I have pre-relationship with, would it make sense to set up a bigger fund with first close being $450k, and subsequent closes to be $1M plus. The structure will be based on a deal by deal basis. So the first set of investors will only be investing in this first deal. Next close will be for another deal. Carry will be paid on a deal by deal basis. There would be an option for investors to exit after the target investment is disposed (within a year since these are quick flips).

B. From my understanding, File Form D is filed with a CIK number. All of the other documents are not submitted. I know this is not a popular option, but what if I drafted the PPM and subscription documents myself as a DIY. All of the investors that we are working with currently are people we have done business with so there is a high level of trust. In addition, this will be a 9 month hold and we will liquidate the LLC.

C. Is a PPM required if all of the investors are accredited? Out of the group, only 1 is non-accredited and I can negotiate with him to possibly loan money for interest. I will do that if it makes things easier. 

Thank you!
Mike