Unfortunately, your offering will not accommodate 506(c), either. Under 506(b) your investors can self-certify as accredited investors, but under 506(c) you need to take reasonable steps to verify that they are qualified as accredited investors. This means collecting personal information to verify identity as well as supporting documents that prove a net worth over $1m USD or earned income exceeding $200k for each of the past two years.
Yes, in order to comply with 506(c) we'd have to go through another avenue that has a proper verification process for it's accredited investors.
And buy orders of those 31 shares are in the order book to refund investors.
God Bless the USA