Open funds for US GV investors


I’m currently looking to invest in open funds. My definition of an open fund is a fund that is traded in stock market and we can exit when we need (of course you will abandon GV if you do so).

I spoke to BPI Portugal FIAA fund. Looks like some non US investors have done GV using the fund. But they don’t support FATCA or PFIC.

I’m eyeing “IMGA Ações Portugal A” next from Bison bank. Has anyone from US got approved for GV process using any open fund? Please share your experiences here


I have just invested through the BPI FIAA fund route for pre-approval. It definitely is a no brainer compared to IMGA given lower management fee (1%) and no subscription fee.
Sorry to hear about the FATCA non-compliance.

As far as approvals go, the SEF mostly relies on the letter provided by a “competent” authority to say that the fund is eligible of PGV. In this case, a letter from the bank generally goes a long way.


Hi Ravi,

Here’s the BPI Fund: BPI Portugal - Fundo de Investimento Aberto de Ações, PTYPIGLM0000:EUR summary -

I’m in the process of investing through this

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Would you have any contact number or email address to initiate the account opening with BPI bank and invest in this fund?


Hi Aditya, I would be glad if could you share the contact number or email address to initiate the account opening with BPI bank and investing in this fund?


Will PM you shortly.

How is your approval coming along? A fund manager said there were recent changes in regulations and investing in open-ended funds were not approved because management could close anytime. Is there truth in this statement?
Also, can you also share the contact details for the bank? Thank you!

If anything, I would be worried about losing management in a private fund!
BPI FIAA has been up and running since 1994, and IMGA since 1995, so I would not be worried about it.
I have not seen any changes to the rules that impacts the investment in (retail) investment funds.

The only thing you need to be scrutinising is the volatility in these funds (as they track PSI20 index and its composition). They are mainly constituted by manufacturing, logistics and utility companies, which IMHO are still underweight on valuation (vs. underlying performance), especially as these countries recover from COVID.

Have PM-ed you the details of the RM I worked with to invest.

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I think the point is that the fund may choose to close up shop at any time, not that you might lose the management. An open-ended fund likely has no definitive term, whereas the average private fund at least in .pt has a defined lifetime, generally 10 years.

Hi, I am also looking at investing in open end funds. Would you mind sharing with me the contact for the BPI FIAA fund? Many thanks!

Beware that as far as we know, at the moment there hasn’t been any pre-approval from SEF for applicants investing in open-ended funds.
The laws explicitly says: Fundos de capital de risco → i.e. Alternative funds (PE/VC).

There is at least one on this board who was approved:

The IMGA fund is also on Bison Bank’s list of recommended funds and I have been told there have been several others who have used the IMGA fund successfully.

Yes. Correct. My family was approved using an open-ended fund.

Hi there @ravi, I represent a fund called Pela Terra Farmland.

We have both US and non-US investors, as we’re FATCA compliant and will be PFIC compliant when the time comes (at the end of each year).

I wish you the best of luck with your application. Please do let me know if you have further questions I might be able to help with, about our fund or the market in general.

Hi Aditya

Could you please share the contact details for the RM?

And how is your process?

Thank you!

Sure, will PM you shortly.

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Hello. FYI. I invested in IMGA. My lawyer opened my and my wife’s applications with SEF in June, with partial documents. My lawyer completed our applications with remaining documents about the first week of July. We were pre-approved on August 9 and August 11. Based on that, IMGA appears to be confirmed as an approved investment. I considered BPI but IMGA was easier, because I had already opened my bank account with Bison Bank. Investing in IMGA through Bison Bank was reasonably easier. I monitor my NAV frequently through which makes the investment transparent, which I find comforting.


We also were approved in July using the IMGA Ações fund.

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This community is awesome. Has anyone been able to determine if the open-ended IMGA fund is FATCA compliant and PFIC compliant? Trying to figure out if the IRS reporting requirements would be any different (more onerous) for the open-ended IMGA vs. a more traditional VC/PE fund like Explorer.

Separately, in the unlikely event a fund like IMGA were to shut down during the 5yr GV investment period, then is there any reason you couldn’t just sell out of the fund (convert to EUR cash) and quickly reinvest it in a similar fund (like BPI FIAA), or even into a new VC fund? So long as the investment was still >350k?


Please I would very much appreciate your help sharing contact information for bpi fund and if possible the same for the legal firm handling golden visa application.

Thank you so much