Without going into details under the relatively new expanded definition of securities offerings, adopted by the SEC and almost all state securities regulatory agencies, if a financial investment is involved, and people putting up the money or having money at risk don’t have control of the decision making, then its a securities offering.All Securities offering must be registered with the SEC if they’re interstate offerings, or a state securities agency if they’re intra state offerings, unless they qualify for an exemption from registration.

Thanks everyone...I'll be in contact with each of you who have reached out...Karen - Half acre lot, but setbacks create a pretty small building envelope that week require a specific design (no more than 42' deep, side entry garage, etc).

I believe the market is hungry for such as it's been a bit starved for such since the post '08' regulatory actions. 

It was a setback for us financially and emotionally. 

Regulators do not give legal advice, they may give their opinion of a regulatory policy.

That changed over the last few years where a back up strategy was an afterthought or non excitant.Headwinds: regulatory, interest rates, house prices, "professional" competition, and market saturation.

As a broker you'll have regulatory requirements.  

I was not aware that if there was no 'release' that a tank could be left in-place, washed and then abandoned with with fill / foam inside.I get that regulatory agencies are unlikely to say there will never be any 'liability' but it sounds as if the closure report / 'no further action' letter stands as comfort to the (new) owner and any lender that the issue has been fully addressed.Oren

Full disclosure our house buying company wholesales hundreds of properties a year but i advocate that if you are to wholesale properties that they should be required to be licensed just to bring some regulatory oversight and make it just a smidge harder for people to get started.Our wholesaling company is working really hard to grow large and train our client buyers and sellers to expect more from their wholesaler then "buyer beware" and a bunch of weasel clauses for sellers they are getting now.For instance:Every seller knows we are wholesaling  and is given the option to list the house with us at a higher priceWe guarantee our ARV and rent comps to our buyersWe own a construction company as well so we KNOW our rehab numbers and adjust quickly as prices adjustWe still take $3-$5k non refundable (unless we cant get clear title) from buyers and i know thats a source of contention for BP but as a business operator those deposits protect our sellers and ensure that whoever puts the money down is ready to close then. 

Some require frontage that might be hard to get on a subdivision unless you put a road in etc... setbacks, minimum lot sizes etc.