We are also days away from filling our first round confidential S-11 with the SEC as we will be seeking an IPO on the OTCQX 1Q21 (NYSE & NASDAQ are accepting listing of US Cannabis related companies).

If it's truly an accredited investor only deal, you're out of luck.The best advice you can ever get is "Don't mess with the SEC".  As

Securities and Exchange Commission (SEC) as: a bank, insurance company, registered investment company, business development company, or small business investment company;an employee benefit plan, within the meaning of the Employee Retirement Income Security Act, if a bank, insurance company, or registered investment adviser makes the investment decisions, or if the plan has total assets in excess of $5 million;a charitable organization, corporation, or partnership with assets exceeding $5 million;a director, executive officer, or general partner of the company selling the securities;a business in which all the equity owners are accredited investors;a natural person who has individual net worth, or joint net worth with the person's spouse, that exceeds $1 million at the time of the purchase, or has assets under management of $1 million or above, excluding the value of the individual's primary residence;[10][11]a natural person with income exceeding $200,000 in each of the two most recent years or joint income with a spouse exceeding $300,000 for those years and a reasonable expectation of the same income level in the current year;[12] ora trust with assets in excess of $5 million, not formed to acquire the securities offered, whose purchases a sophisticated person makes."

My biggest concern would be falling into the camp of having to register as a broker dealer with the SEC as this is something prohibited.

HOWEVER, the PM LLC will book the property management income as Sch C active income, and it will be subject to SECA tax.

For example, if you are a sophisticated investor (meaning you do not meet the qualfications set forth by the SEC as an accredited investor) that means you are limited to 506b offerings, and those require you to have a substantial business relationship with the operator. 

While until now most have been restricted to accredited investors, new regs from the SEC as required by congressional action has opened opportunities to non accredited investors as well.Successfully investing in these syndicated offerings does not require the ability to FIND deals, it requires the ability to ANAYLZE deals.

As with all novel areas of law, there will be much uncertainty for the first few years until we receive further guidance from the SEC as to how to interpret such rules.It's not my place to opine on a public forum as to who is right and who is wrong, and no one should be relying on or be taking as legal advice anything in this post--I post for educational purposes only.

That isn't how RE investments work, people don't give you money like that and if you solicit investments from strangers you probably need to have a conversation with the SEC as that is very close to syndication.

My question is how do I legally set up a Syndication with I believe it is the SEC as a 506 (c)?