The question is not really about the PPM or Private Placement Memorandum, Offering Document, it is really about compliance with the securities regulations. So, the best answer would simply be this. Unless you are raising money from a limited number of friends or individuals you have had relationships with in the past, you do have to comply with securities regulations. Almost always those securities regulations require a Private Offering Memorandum, Subscription Agreement, and Qualification Profile, among other documents. In addition, you need to make sure that the structure of the offering, not just the documentation, is in order.