For example, I have a lot of grad school loans as high as 6.8% but have a HELOC with a promotional rate of 2.99% (fixed for one year, then floating).

I know they pay to be promoted on the website, so I'm not sure if this would be considered ethical.  

Similarly, making unspoken distinctions by promoting a school in one district while keeping silent about the quality of another school can have the same effect.

However, while the real estate gurus like to promote wholesaling as the end-all answer to no-money down investing, it does take some money for marketing in order to keep the funnel filled with deals.

I will just make this point again, these programs are not all about the investors, they are about serving the desires of the promoter.  

Often times the [Seller's] model promotes a resale of the loan after a set amount of periods have passed where the Borrower has made a payment.  

How do you promote it?

See SEC v Howey:A security is defined asinvestment of money due toan expectation of profits arising froma common enterprisewhich depends solely on the efforts of a promoter or third partyTo me the dispositive issue here is the last prong. 

The "wholesaling" gurus are trying to make a buck promoting assignments, etc.

In todays market, a lot of companies are promoting universal design.