Investor acquisition glossary for real estate sponsors

Legal terms

Accredited investor

A person or entity that meets the tests in Rule 501(a) of Regulation D. For a natural person, the common tests look at income or net worth. Income must be above $200,000 in each of the last two years. Joint income must be above $300,000. Or net worth must be above $1,000,000, not counting the primary residence. Since 2020, holders of the Series 7, 65 or 82 licenses count too. Entities have their own tests. One is more than $5,000,000 in investments.

Regulation D

The SEC's set of rules under the Securities Act. They let some private offerings skip registration. Rule 506 is the exemption used most. It has two paragraphs. Almost every real estate syndication raises money under one of them. So does almost every private real estate fund.

Rule 506(b)

The Regulation D exemption that bans general solicitation. Any number of accredited investors may buy. So may up to 35 others. They are not accredited, but they must be sophisticated. The issuer must reasonably believe each buyer is accredited. That belief is usually based on self-certification. Buyers come from pre-existing relationships.

Rule 506(c)

The Regulation D exemption that allows general solicitation. The JOBS Act made it in 2013. Each buyer must be an accredited investor. The issuer must take reasonable steps to verify that status. It is the only Rule 506 path where paid investor acquisition is lawful.

General solicitation

Offering or advertising securities to the public. Paid ads count. So do a public offering page, social media, mass email and public events. Rule 506(b) bans it. Rule 506(c) allows it. The way you reach people does not matter. Telling strangers about an open offering is solicitation.

Reasonable steps to verify

The 506(c) standard for checking that a buyer is accredited. It is based on principles. It names four safe harbors. Other ways can work too, since the four are non-exclusive. They are income documents, net-worth documents, third-party confirmation and grandfathered investors. In March 2025, an SEC staff no-action letter added a minimum-investment approach. It is set at $200,000 for natural persons and $1,000,000 for entities.

Form D

The notice an issuer files with the SEC. It is due within 15 days of the first sale in a Regulation D offering. It names the exemption used. It shows the amount offered and sold. It shows the minimum investment. It lists any sales compensation paid. Anyone can see it on EDGAR.

Regulation A+

An exemption for public offerings of up to $75 million (Tier 2). The SEC must qualify the offering statement. People who are not accredited can invest too, within limits. It allows general solicitation. Paid investor acquisition can serve two structures. Rule 506(c) is one. Regulation A+ is the other.

Broker-dealer

A person engaged in the business of effecting transactions in securities for others. This person must register under Section 15(a) of the Exchange Act. The clearest sign of broker work is transaction-based compensation. That means a fee tied to capital raised.

Placement agent

A registered broker-dealer an issuer hires to find and solicit investors. It is paid a share of the capital raised. The share is often quoted at several percent. In private real estate it is 6 to 8%. It is lawful because it is registered. It is priced to match.

Finder

An unregistered person paid to introduce investors. Say the fee depends on the money raised. Then the SEC generally treats the finder as an unregistered broker. A 2020 proposal would have exempted some finders. It was never adopted.

Transaction-based compensation

Any fee that depends on whether capital is raised, or how much. It also covers a fee tied to how many investors are introduced. Or one tied to how many subscriptions close. A flat fee for a defined service has none of this. That keeps a marketing vendor on the vendor side of the broker line.

Rule 3a4-1

An Exchange Act safe harbor. It covers certain associated persons of an issuer. These are employees or officers who are not paid commissions. They must also meet the rule's other conditions. They may take part in selling the issuer's securities. If so, they are deemed not to be brokers.

Bad-actor disqualification

Rule 506(d). A disqualifying event can mean the issuer cannot use Rule 506. Such events include certain convictions, orders or bars. The event must involve the issuer or a covered person. Covered persons include anyone paid to solicit investors.

Sponsor / issuer / general partner

The party that sets up the offering and sells the securities. On this site, sponsor means the operating business. Issuer means the entity that sells the securities. The investors are always the sponsor's. They never belong to a vendor.

Syndication

A real estate offering of one asset or a small portfolio. The sponsor raises equity from a group of investors for one deal. Each syndication is its own offering. So the investor list must be built again each time. That is, unless the sponsor keeps the list and works it.

Evergreen fund

A fund that raises and invests money all the time. It does not close on a fixed date. It is always open. This is the structure where a standing investor acquisition system is worth the most.

Marketing and lead response terms

Investor acquisition

Getting investor leads for a 506(c) or Reg A+ offering. Then you work each lead until a meeting with the sponsor is actually held. Media, response and appointment setting run as one system. It is reported as cost per appointment held.

Investor lead

A person who answered the sponsor's ads and asked to hear more. They filled in a form and agreed to be contacted. Ascent never uses the word prospect for an inbound lead. Ascent never calls anyone who did not ask.

Cost per investor lead

Media spend divided by the number of investor leads in the period. Published category benchmarks put it at $50 to $100 on Meta. On LinkedIn, they put it at about five times that. Agencies report this number. They do so because it is the number they control.

Speed to lead

The time from a lead's form to the first outbound try by a live person. Ascent reports the median in minutes. It calls this speed to first human touch.

First touch / first human touch

Two events, each with its own time stamp. The first is the instant automatic reply (text and email). The second is the first try by a person. A CRM with only one field will report the auto-reply and call it speed.

Contact rate

The share of leads who had a connected conversation. That means a live voice, not a voicemail. Ascent reports it in buckets by response time. The buckets are under five minutes, five to sixty minutes, one to twenty-four hours, and later.

Appointment set / booked

A meeting placed on the sponsor's calendar. Any vendor can inflate this count. That is why Ascent never manages to this number.

Appointment held

A booked meeting that took place. The investor showed up and the sponsor made the case. It is the unit of Ascent's reporting. It is also the unit of every written minimum in a proposal.

Set-to-held rate

Of the meetings booked, the share that were held. This number shows the no-shows. A confirmation the day before moves it. So do reschedules and nurture between touches.

Cost per appointment held

Media spend divided by appointments held in the period. It counts media only, unless a report says fully loaded. Booking meetings nobody attends cannot inflate it. That is why it is Ascent's main metric.

Fully loaded

A cost-per figure that counts the vendor's fee as well as media. Compare it across vendors only when both figures are labeled the same way.

Setter / appointment setter

A live person who is recruited, scripted and supervised. They call inbound investor leads as the sponsor. The call comes from a number registered to the sponsor. They check that the lead asked to hear from the sponsor. Then they get a meeting onto the calendar. They handle logistics only, never the offering. Each call is recorded.

Compliance gate

The written conditions that must be met before anything goes live or anyone dials. The exemption is confirmed. An approver at counsel is named. Every legend and script is approved. On an Ascent engagement, the gate has nine conditions and one review deadline.

Legend

Required disclosure text on an offering communication. Counsel sets the words for an ad, a landing page or an email. They are used word for word.

Flat monthly fee

A fixed fee for a defined service. It scales with media under management. Nothing in it is tied to capital raised, investors brought in or appointments held. This fee model lets a marketing vendor stay a vendor.

Media under management

The monthly ad spend a firm runs for the sponsor. The sponsor pays it to the platform, on the sponsor's own account. The vendor never holds, advances or marks up this money.