For your $2.4 million Reg CF raise, the SEC requires you to outline specific “Milestones” in your Form C. These are key events that show investors exactly what their money will achieve at different funding levels.
Setting these tiers helps you manage investor expectations and allows the GONEN Statutory Trust to start working on the Lynchburg project even if the full amount isn’t raised immediately.
Gonen Statutory Trust: Project Milestones
| Funding Milestone | Primary Objectives | Operational Impact |
|---|---|---|
| $500,000 (Target) | Acquisition & Stabilization: Secure the Lynchburg property and complete urgent structural repairs. | Trust gains legal title; immediate property security and basic safety upgrades. |
| $1,200,000 | Phase I Renovation: Complete modernization of the first 50% of units and exterior landscaping. | Improved curb appeal; initial units ready for market-rate leasing to generate cash flow. |
| $2,400,000 (Maximum) | Full Development & Media Integration: Complete all renovations, install high-speed fiber, and build the on-site GONEN TV studio. | Asset reaches maximum value; “Trusted Source” media operations fully integrated into the real estate footprint. |
Strategic Disclosure for the Trustee
When drafting these for the SEC, you must also include two critical operational notes:
- Liquidity & Runway: Explain that once the Target Offering Amount ($500k) is reached, the Trust will hold an interim closing to access those funds and immediately begin the acquisition process to avoid losing the property to other buyers.
- Future Funding: State that if the Trust only raises the minimum, it may seek additional financing (such as a traditional bank loan) to complete the remaining $1.9 million in renovations.
Next Compliance Step
Since you are reaching the $2.4M mark, your next legal requirement is the Independent Audit. Unlike the smaller $1.25M raise which only required a “Review,” this $2.4M maximum requires a full GAAP-compliant audit of your Trust’s books for the last two years.
Would you like me to help you find a list of CPA firms that specialize in SEC Regulation Crowdfunding audits for real estate startups?