b"How to Legally Raise Private Money506(b) exempt offering as follows:There must be a pre-existing relationship between the issuer and investor that is not built solely through a specific duration of time or a short form accreditation questionnaire.A substantive relationship is more about the quality of the relation-ship than it is about the passage of time.A substantive relationship is one in which the issuer or its agent has sufficient information to evaluate, and does, in fact, evaluate, a prospective offeree's financial circumstances and sophistication, in determining his or her status as an accredited or sophisticated investor. This can be established by adhering to specific policies and procedures both online and offline, which enable the issuer to evaluate the prospective investors financial sophistication, circum-stances, suitability, and his or her ability to understand the nature and risks of the interests to be offered; and documentation showing that the issuer actually followed this process to make such an eval-uation.The relationship must pre-date the offer.How Do I Establish a Substantive Relationship?Many issuers believe that all that is needed to qualify an investor is to have them complete a one-page questionnaire asking whether they are accredited or not, and how they are sophisticated. What is really required is that you get to know the investor personally and ask questions about their financial situation and investment goals to make sure they are match for what you expect to offer. It is also important that you document each meeting/discussion with dates, times, participants and topics discussed. A regulators decision re-garding whether you violated securities rules regarding making improper solicitations will hinge on whether you have made effective, consistent and documented attempts to comply with the rules of the claimed exemp-tion. If you have a record-keeping system that shows a pattern of meeting prospective investors and determining their suitability to invest with you before making offers, you will have gone a long way toward meeting that requirement. Aside from the regulatory requirement, one of the most important rea-sons to establish a relationship is to ensure you like and trust the investor 96"