That's soliciting, which is regulated at least for soliciting non-accredited investors.
The hypotheticals being pushed on this thread have a foregone conclusion that the arranging party is completely free of any hit.
Naive searching on the term shows that they common in PE, and they do have a worse default rate at 20% over 2% otherwise. Certainly something to look at more closely. And I would be nervous being party to one. That said, 80% success is still better than what some companies are looking at otherwise.