Will the offering need to be registered with the securities Exchange Commission (SEC) under the securities Act of 1933?

Rule 507 seems like 1-5 million dollars would be an incredible number of $500 certificates in order to exclude either college/university from qualifying by rule 507. Do you know of any other examples of securities within a university or learning non-profit that would contribute to the total annual amount? I had a hard time looking up this information and upon reading in addition to the certificates what else would be a part of this total?

Reference:

Seaquist, G. (2012). Business law for managers[Electronic version]. Retrieved fromhttps://content.ashford.edu/book