Should You Buy Accredited Investor Leads or Lists for a Real Estate Raise?
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You can buy accredited investor leads, but the list does not do what its name suggests. A list vendor's "accredited" label is a guess from income or wealth models, not verification, and the people on it have no relationship with you. Contacting them about a live offering is general solicitation, which fits only a Rule 506(c) raise, where you must still take reasonable steps to verify every investor yourself. For a Rule 506(b) raise, a bought list is off limits for offering the deal.
What is an accredited investor lead list?
Lead vendors sell names, emails and phone numbers of people they estimate meet the accredited investor thresholds: income over $200,000 (or $300,000 with a spouse or spousal equivalent) in each of the last two years, or net worth over $1 million excluding the primary home (17 CFR 230.501). The estimate usually comes from consumer data such as home value, zip code or job title.
For scale: the SEC staff estimated that about 24.3 million U.S. households, or 18.5% of households, met the income or net worth tests in 2022 (SEC staff review of the accredited investor definition, 2023). A list of "accredited investors" is a slice of a very large group, sorted by guesswork.
Some vendors sell "opt-in" leads: people who filled in a form on an investing website. They are warmer, but they agreed to hear from that website, not from you, and they still have not been verified.
Can you use a bought list in a 506(b) raise?
Not to offer the deal. Rule 506(b) bars general solicitation (17 CFR 230.502(c)). The SEC says an offering avoids it by limiting itself to people with whom the issuer had a pre-existing, substantive relationship before the offering started (SEC, general solicitation). A row in a spreadsheet you bought last week is neither pre-existing nor substantive.
Could you build relationships with people on a list long before any offering, without mentioning a deal? In principle a relationship can start anywhere, but it has to be real: you know the person well enough to judge their finances and experience, and you actually did. Our post on the substantive relationship test covers what that takes.
Can you use a bought list in a 506(c) raise?
Yes. Rule 506(c) allows general solicitation, provided every purchaser is accredited and you take reasonable steps to verify it (17 CFR 230.506(c)). Three things still apply:
- Verify every investor yourself. Reasonable steps include reviewing tax returns or W-2s for income, bank and brokerage statements plus a credit report for net worth, or a written confirmation from a CPA, attorney, registered investment adviser or broker-dealer. Since March 2025, SEC staff also accept a high minimum investment ($200,000 for an individual, $1 million for an entity) plus written representations, in the right circumstances (SEC staff letter to Latham & Watkins, 2025). See accredited investor verification.
- Follow the email, call and text rules. CAN-SPAM covers every commercial email (FTC). Calls and texts to cell phones have separate federal consent rules, and many states add their own. Check before you dial.
- Say nothing misleading. Antifraud rules apply to every message (17 CFR 240.10b-5).
How should you pay a lead vendor?
A flat fee for data. Avoid any deal where the vendor is paid per investor who invests, or a percentage of money raised. Transaction-based pay is a hallmark of broker activity, and a person who is paid that way to bring investors into a securities offering generally must be a registered broker-dealer (SEC, guide to broker-dealer registration). Our post on paying capital raisers goes deeper.
What works better than a bought list?
For the sponsors DoorRaise is built for, the best investors are the friends and followers who already watch your work:
- Your own list. People who signed up to hear from you. See building an investor waitlist before you have a deal.
- Your content. Videos, posts, a podcast or a newsletter where people learn how you think. See how to find accredited investors.
- Your professional circle. Colleagues, clients and peers you already know, which also keeps 506(b) open.
Our take
Bought lists produce a lot of activity and few investors, and they push you into 506(c) for every deal. If you use one, treat it as a list of people to teach, not to sell, and spend the effort on content your own followers ask for.
Trade-offs and who this is not for
- Not for 506(b). Offering a deal to a bought list breaks the exemption.
- Not a verification shortcut. The vendor's label does not count.
- Common mistake: mixing lists. Keep bought contacts separate from people who know you, so you never offer a 506(b) deal to the wrong one.
How DoorRaise fits in
DoorRaise helps sponsors raise equity for apartment buildings with 5+ units from friends and followers who already trust them, under Rule 506(b) or 506(c). We are software, legal document preparation, escrow coordination and verification services. We are not a law firm, broker-dealer, investment adviser, funding portal, bank or escrow agent, and we do not hold investor money: investors wire their money to escrow at Enterprise Bank & Trust, in the deal's name.
DoorRaise verifies that every investor is accredited, in 506(b) and 506(c) raises alike, so verification never depends on where the lead came from. Flat fees, never a percentage of the raise (see pricing). Create your free sponsor page.
FAQ
Are accredited investor lists legal to buy?
Buying marketing data is generally legal. What matters is how you use it: offering a deal to the list is general solicitation, allowed only under 506(c), and email, calls and texts must follow their own rules.
Does an "accredited" list count as verification?
No. Under 506(c) you must take reasonable steps to verify each investor yourself, such as reviewing income or asset documents, getting a third-party letter, or using the high minimum investment approach SEC staff described in 2025.
Can I pay a lead vendor a percentage of what investors put in?
Avoid it. Pay tied to money raised is a sign of broker activity, and an unregistered person paid that way creates risk for you and the offering.
How many people are accredited investors?
SEC staff estimated about 24.3 million U.S. households, 18.5% of the total, met the income or net worth tests in 2022.
Sources
- 17 CFR 230.501
- 17 CFR 230.502
- 17 CFR 230.506
- SEC, general solicitation
- SEC staff, review of the definition of accredited investor (2023)
- SEC staff letter to Latham & Watkins, March 12, 2025
- SEC, guide to broker-dealer registration
- FTC, CAN-SPAM Act compliance guide
This article is general information, not legal, tax or investment advice. Talk to a securities attorney before you market an offering. DoorRaise is not a law firm, broker-dealer, investment adviser or funding portal.