b'properties, because ownership belongs to the entity that holds title and its members. If there are multiple members of the title holding entity, then they are the likely owners of the company and the asset.If there are investors or other members in an ownership structure that an asset manager wants to claim as part of their track record, it would be accurate for an asset manager to say they participate in ownership. If the asset manager actually participated in management of such entities, it would be accurate to say they participate in control of a property. These may seem like trivial nuances to you, but securities regulators may see it as the difference between making a truthful or a fraudulent statement. I actually knew someone who was sued by the SEC, and one of their claims was that the asset manager made fraudulent statements when they stated that they owned several properties on a website. The SEC said, you dont own the properties, investors do! Now, do you see the importance?Asset managers must be precise in describing their past roles in other investments. Omissions or misrepresentations can lead to charges of fraud. The misrepresentation may also involve inaccurate statements contained in yourofferingdocumentsormarketingmaterials.Suchstatementsmay becomethebasisofacomplaintbytheSecuritiesandExchange Commission (SEC), or a state securities regulator.It is your responsibility to review all marketing materials and legal documents before circulating them to investors to make sure they are 100% accurate. This is not a responsibility you can pass off to someone else (even your attorney), as only you know the material facts related to the property you are acquiring and your background.28'