And it is a civil matter, not criminal, where burden of proof is a bit lower.

Even the folks who you might want to rent were either not financially qualified, credit scores below 550, or had criminal records.So far, I have not found Waterbury to be viable for investing in real estate, for short term projects.I swore not to buy another one in Waterbury, however, one of the contractors I hired, has asked me to partner with him on some multi-family homes, but I am not convinced.  

We do criminal checks on people who move in after the fact.

They are usually only for traffic enforcement or vehicle accident type activities not responding to criminal activity.

We are not privy to internal lender policies of how loans are monitored and what triggers a call.

The important thing is to find out whether the terms have been vetted internally at the bank.

Do some reading up on wholesaling, get the basics down, find a deal yourself and offer interning rather than a referral fee.

FHA is FHA, it's just a matter of lender fees and internal overlays/restrictions.

Further, how would this potentially absolve the promoter from CRIMINAL liability for these investors not being accredited.

Always do a thorough tenant screening including employment verification, credit, background, criminal and eviction reports.