INDEPENDENT VERDICT
REA CAPITAL III LTD is not an isolated September 2026 entity. SEC records show a three-stage sequence centered on Justin Spillers and the same Piqua, Ohio address and telephone number: REA Capital Ltd appeared in November 2024 with a $10 million Rule 506(b) equity offering; REA Capital II Ltd followed in March 2025 with another $10 million offering but switched to Rule 506(c); and REA CAPITAL III LTD arrived on September 14, 2026 with the target increased fivefold to $50 million while retaining the same $50,000 minimum used by Fund II. All three filings identify Justin Spillers in the management chain and classify the business only as "Other," rather than as a pooled fund, real-estate fund or investment company. Fund III had not completed a first sale and reported $0 sold and zero investors at filing. The most important research issue is therefore not whether the SEC filing exists—it does—but what operating business and assets sit behind this growing REA series, because the public filing describes the securities offering far more clearly than it describes the underlying enterprise.
THE SEC HISTORY SHOWS A REAL REA SERIES — BUT ITS SCALE CHANGED SHARPLY
The first entity, REA Capital Ltd, CIK 0002045915, was organized in Ohio in 2024 and filed Form D on November 22 of that year from 1268 East Ash Street, Suite 108, Piqua, Ohio 45356. Justin Spillers signed as President. That issuer sought $10 million of equity under Rule 506(b), reported no first sale, $0 sold, zero investors, a $10,000 minimum and "No Revenues." REA Capital II Ltd, CIK 0002063080, was then formed in 2025 at the exact same address with the same 419-305-3732 telephone number and Justin Spillers as executive officer and Member & Manager. Fund II again targeted $10 million and had sold $0 at its March 24 filing, but it changed the exemption to Rule 506(c), raised the stated minimum from $10,000 to $50,000 and declined to disclose issuer size. The sequence therefore already shows a meaningful evolution before Fund III: same management and location, but a change from a private 506(b) process to a generally solicitable 506(c) structure and a materially higher minimum investment.
REA CAPITAL III LTD, CIK 0002154823, continues that chain but changes the economic ambition. The Ohio LLC was formed in 2026, uses the same 1268 E. Ash Street Suite 108 location and 419-305-3732 telephone number, and identifies Justin Randall Spillers as executive officer and signer in his capacity as Member & Manager. Its September 14 filing increases the offering target from the prior $10 million level to $50 million while preserving the $50,000 minimum. It offers equity rather than pooled investment fund interests, reports no broker-dealer or sales-compensation recipient, no commissions or finder fees, $0 sold and zero investors, and says the first sale has yet to occur. In other words, the public evidence supports continuity of the sponsor/operator but not continuity of the underlying investment strategy, because none of the three filings explains what assets or business model justify the progression from $10 million to $50 million.
FUND III CONTAINS TWO FILING DETAILS THAT DESERVE MORE ATTENTION THAN THE HEADLINE TARGET
The first is the investor-eligibility entry. REA Capital III relies on Rule 506(c), yet its Form D display checks the box indicating that securities "have been or may be sold" to persons who do not qualify as accredited investors, while separately reporting zero such investors and zero total investors. That is difficult to reconcile with the basic structure of Rule 506(c), under which purchasers are required to be accredited investors and the issuer must take reasonable steps to verify that status. Because no sale had occurred, this may simply be a Form D completion error rather than evidence that non-accredited securities were actually sold. FilingDossier therefore treats it as a disclosure inconsistency that should be corrected or explained, not as proof of a securities-law violation.
The second is a simpler but still useful data-quality issue. REA Capital III's issuer address is displayed as 1268 E. Ash St., Suite 108, Piqua, Ohio 45256, while Justin Spillers' related-person record uses the same street address with ZIP 45356. The earlier REA Capital and REA Capital II filings also use 45356. That pattern strongly suggests the 45256 entry in the Fund III issuer section is a filing typo, but the regulatory record should still be reported as filed rather than silently normalized. These two inconsistencies—investor eligibility and ZIP code—make Fund III a good example of why a Form D should be read field by field rather than treated as a perfectly clean company profile.
THE BIGGEST IDENTITY QUESTION IS THE PUBLIC WEBSITE, NOT THE SEC SERIES
A current Form D aggregation service associates REA CAPITAL III LTD with ReaCapitalInc.com, and that website describes "Rea Capital Inc" as a real-estate investment company founded by Joseph Rea. The site claims approximately $4.4 billion of AUM, $1.2 billion raised, more than 14,000 investors, 39 multifamily properties and a 35-year investment history. Those are substantial claims—but the indexed website pages reviewed do not identify Justin Spillers, do not show the Piqua 1268 East Ash Street office as the management center, and do not explain how Joseph Rea or Rea Capital Inc legally connects to REA Capital Ltd, REA Capital II Ltd or REA CAPITAL III LTD.
That distinction is critical. The SEC series is built around Justin Spillers and newly organized Ohio entities dating from 2024, 2025 and 2026. The public website presents a much older platform centered on Joseph Rea with billions of dollars in claimed AUM and extensive multifamily holdings. The similarity of the REA Capital name is not enough by itself to merge those records. Unless an offering memorandum, Ohio corporate record, website legal disclosure or issuer statement directly connects Justin Spillers' three SEC entities to Joseph Rea's operating platform, FilingDossier does not import the website's $4.4 billion AUM, $1.2 billion raised, 14,483 investors or property portfolio into REA Capital III's profile. This unresolved entity match is the single most important website-penetration finding in the case.
WHAT THE PUBLIC RECORD STILL DOES NOT TELL INVESTORS
The filing gives no description of what the $50 million will finance. It does not select Commercial Real Estate, Residential Real Estate, REITs & Finance, Investing, Private Equity Fund or another specific investment classification. It does not identify properties, portfolio companies, debt instruments, acquisition targets, geographic markets, leverage policy, management fees, distributions, preferred returns, exit strategy, auditor, administrator, custodian or independent valuation provider. It also does not disclose an investment adviser CRD or SEC Form ADV identity. That information gap is particularly significant because the offering target has expanded from $10 million in the first two REA vehicles to $50 million in Fund III before the latter has reported its first investor.
The most useful next evidence would therefore be the Fund III private placement memorandum and operating agreement, together with documentation showing the relationship among REA Capital Ltd, REA Capital II Ltd, REA CAPITAL III LTD and any Rea Capital Inc operating company. Those documents should explain whether the three issuers are sequential investment programs, operating-company capital raises, property-specific holding vehicles or something else entirely; whether investors participate in a common asset platform; and why the third issuer requires five times the capital of its predecessors. Until then, REA Capital III can be verified as part of a recurring Justin Spillers-controlled SEC filing family, but its underlying business cannot responsibly be equated with the much larger real-estate platform described on ReaCapitalInc.com.
SEC SNAPSHOT
Legal Name: REA CAPITAL III LTD CIK: 0002154823 Filing Date: September 14, 2026 Jurisdiction: Ohio Year Organized: 2026 Entity Type: Limited Liability Company Principal Address as Filed: 1268 E. Ash St., Suite 108, Piqua, Ohio 45256 Related-Person Address ZIP: 45356 Phone: 419-305-3732 Executive Officer: Justin Randall Spillers Signer: Justin Spillers Signer Capacity: Member & Manager Industry: Other Security Type: Equity Federal Exemption: Rule 506(c) Investment Company Act Exclusion: None selected Offering Target: $50,000,000 Amount Sold: $0 Amount Remaining: $50,000,000 Minimum Investment: $50,000 First Sale: Yet to occur Total Investors: 0 Non-Accredited Investors: 0 Form D Non-Accredited-Sales Box: Selected Sales Commissions: $0 Finders' Fees: $0 Broker-Dealer / Placement Agent: None disclosed Offering Duration: More than one year
REA SEC LINEAGE
REA Capital Ltd CIK: 0002045915 Organized: 2024 Filing Date: November 22, 2024 Offering Target: $10,000,000 Exemption: Rule 506(b) Minimum: $10,000 Amount Sold at Filing: $0 First Sale: Yet to occur Issuer Size: No Revenues Signer: Justin Spillers, President Address: 1268 East Ash Street, Suite 108, Piqua, Ohio 45356 Phone: 419-305-3732
REA Capital II Ltd CIK: 0002063080 Organized: 2025 Filing Date: March 24, 2025 Offering Target: $10,000,000 Exemption: Rule 506(c) Minimum: $50,000 Amount Sold at Filing: $0 First Sale: Yet to occur Signer: Justin Spillers, Member & Manager Address: 1268 E Ash St., Suite 108, Piqua, Ohio 45356 Phone: 419-305-3732
REA CAPITAL III LTD CIK: 0002154823 Organized: 2026 Offering Target: $50,000,000 Exemption: Rule 506(c) Minimum: $50,000 Amount Sold at Filing: $0 First Sale: Yet to occur Signer: Justin Spillers, Member & Manager Address: Same Piqua operating location, with ZIP discrepancy in current filing
Series-Level Change: Fund I target: $10M Fund II target: $10M Fund III target: $50M
Increase From Fund II to Fund III: 5x target size
WEBSITE / ENTITY PENETRATION
Website Associated by Third-Party Form D Index: reacapitalinc.com
Website Brand: Rea Capital Inc
Website Founder / CEO: Joseph Rea
Website-Claimed AUM: Approximately $4.4 billion
Website-Claimed Funds Raised: Approximately $1.2 billion
Website-Claimed Investors: 14,483
Website-Claimed Investor Distributions: Approximately $311 million
Website-Claimed Portfolio: 12,718 apartment units 39 multifamily properties More than 500,000 square feet of commercial office space
Justin Spillers Visible on Reviewed Website Pages: Not confirmed
Piqua 1268 E. Ash Street Connection Visible on Reviewed Website Pages: Not confirmed
Direct Legal Connection Between Rea Capital Inc Website and REA CAPITAL III LTD: Not confirmed
FilingDossier Treatment: Do not attribute the website's platform AUM, investor count, property portfolio or historical performance claims to REA CAPITAL III LTD until a direct legal/entity connection is established.
INDEPENDENT CONCLUSION
REA CAPITAL III LTD has a real and traceable SEC lineage: three Ohio issuers formed in successive years, the same Justin Spillers management identity, the same Piqua location and telephone number, and a progression from two $10 million offerings to a new $50 million target. That continuity is stronger evidence than the Fund III name alone. At the same time, the current filing contains an unusual Rule 506(c) / non-accredited-investor checkbox mismatch and a ZIP-code inconsistency, while the underlying investment strategy remains undisclosed.
The most important unresolved issue is the relationship between the Justin Spillers-controlled SEC series and the Rea Capital Inc website centered on Joseph Rea. Until that link is documented, the website's multibillion-dollar AUM and long real-estate track record should not be used to validate Fund III. The SEC filing verifies the issuer and planned offering; it does not verify the website identity, the assets that will be acquired, or the economic rationale for expanding the target from $10 million to $50 million.
Form D is a notice of an exempt securities offering and does not constitute SEC approval, endorsement or verification of REA CAPITAL III LTD, Justin Spillers, Rea Capital Inc or any investment strategy or performance claim.