If I was the owner I would be asking why is it not published in the NY times, or other publications that have high net worth individuals.

For existing companies, individuals who own at least 25% of the entity or exercise substantial control over it must submit BOIR to the Financial Crimes Enforcement Network (FinCEN) by December 31, 2024.

Some places like Illinois for example require individuals to be licensed with the state in order to wholesale more than 1 deal per year. 

If I were to go this route I would clearly identify each of these risks individually, understand how the Govt would potentially challenge each of them and then assess in your particular fact pattern how you would effectively rebut a challenge to each. 

If not, you can always increase the rent to market value, but my guess is it being California, there are limits to rent increases.There are rent caps but they do not apply to single family homes owned by individuals (not LLCs or Corps) 

Quote from @Rich Davis: Read the HUD guide.

The victims weren’t a bunch of super rich people where it didn’t affect them.

It feels like everyone and their grandma is on the Do Not Call list nowadays and my worry is the fines associated with accidently calling these individuals. 

I would assume that you'd just simply sell each individual lot to the developer at a set lot price such that your cost to purchase the raw land and improve it to buildable lots was worth the proposed profit per lot.  

If a cash out refinance, many lenders will allow the cash out to satisfy the reserves requirement.DSCR lenders generally let you vest either individually or as an LLC.