Legal Question in Real Estate Law in California

I can't answer the securities license question without substantially more information on what, exactly, the proposed firm will be doing with securities - but do note that these licenses tend to be for persons who act as brokers, dealers, underwriters, advisors, etc. than as issuers of securities. On the other hand, a "commercial real estate investment firm" is more likely to be in the role of an issuer, rather than a dealer. So maybe the right line of questioning to pursue is what kind of SEC registration (S-1, S-18, Reg. A, etc.) or exemption from registration (Regulation D, etc.) would be suitable. A lot of commercial real estate investment firms main activity is organizing and managing limited partnerships, real estate investment trusts, and so on, and these involve raising money by issuing securities rather than peddling them in the aftermarket.