By removing the fee it’ll make it that much harder to put it back on and the smartest thing to do is have an escrow account so money is there dor either party that needs it.

Chris in CA  and with a current RE Broker license you May bring in up to 10 parties to a fractionlized DT / mortgage / note WITHOUT any PPM reg A reg D. the broker uses the CA real estate agencies disclosures for these transactions over 10 and yes you need to then move to some sort of PPM Reg A B C D or what have you.. this is HML i started in back in the early 80s every loan we made was fractionlized. 

As long as you have a day job, and do R/E on the side, the if your income exceeds $100K, your allowable loss slowly reduces and by the time you hit $150K, the current year loss is zero.

I eventually ended up using my lender (who pre-approved me).Due diligence, I looked up Wise's blog ensuring this was not in D or F zone.

https://www.oregon.gov/DOR/programs/businesses/Pages/corporate-activity-tax.aspx

D. Or

If you are in a C to D, or focusing on very low cost product in general, it is always the lower income demographics that are hit hardest with slow downs, and you will have trouble renting/selling. 

I would call the state DOR and ask if that's correct given the nature of your company and explain. 

DOR refused to let my time of purchase go back to 2012 and thus a certificate was issued to me.  

Thank you @Tchaka Owen for taking the time to answer.I ll ask the broker to find homes that aren't D (or at least work at it at best).