Dear Fellow EFPA members, I'm trying to find out what the exact criteria is under MiFID for an individual to be considered an accredited investor in the EU (more specifically, Germany) in order to invest in venture capital-related projects and funds.
Any information on this would be greatly appreciated!
Another detail: if your customer exceeds a particular share in the startup's capital, he or she must be registered as a beneficial owner in the national register where the company is based. This must be done by the start-up.
EFPA Luxembourg
A private equity or venture capital fund is typically open only to accredited investors and qualified clients.
Accredited investors and qualified clients include institutional investors, such as insurance companies, university endowments and pension funds, and can also include high income and net worth individuals.
For this population, MiFID II rules will require the client assessment questionnaire to allow investment in these asset classes. The client's investor profile will therefore have to allow investment in such products.
Secondly, it is your firm's distribution policy that will have to allow this asset class in your client's investment profile.Normally it should aligned with the client assessment process.
Finally, the AIFM rules will impose a minimum investment of €125,000, which is found in all private equity fund prospectuses.
The Asset Manager of the fund, or its Management Company (ManCo) must probably confirm they accept the subscription of your client. For this, they will probably ask for documentation, also for AML issues.
EFPA Luxembourg