So what is the latest consensus on BlueCrow Growth Fund I?
Thanks so much for the feedback @cynthiaweissasher and apologies for the delayed response. Iām still getting used to the platform 
How is your GV fund research going?
Do people recommend splitting funds generally, or does it depend on the situation?
Yes mine shows the same. The detail shows the value, the nominal amount per share and number of shares
Had a good call today with a lawyer who said he has several clients applying using the IMGA fund and that it definitely qualified. Honestly itās looking more and more attractive.
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Isnāt it too interesting no one ever came up with the idea of publicly traded equity funds before @joseph.c.lapierre ? This topic started almost one year ago.
And I think there should be several other equity funds that qualifies. I do not think there is only one equity fund investing on Portuguese stocks.
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I am sure there are others out there. They have been there for awhile, but most seem to push real estate as the mechanism for qualifying.
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If you like the IMGA Acoes Portugal index tracker that Millenium work with then youāll REALLY like the BPI Portugal FIAA Fund (also tracks the PSI 20 index) that Banco BPI offer - it charges much lower fees (1.3% compared to 2.3%, saving over ā¬20,000 over 6 years). They assure me it is approved by SEF for GV purposes. And that they will do all the certifications for SEF that Iām going to need. Thatās the one Iām planning to invest in once I get my paperwork lined up.
Like you, I also heard about the Millenium/IMGA arrangement first and I opened an account with Millenium bank, but I was appalled at the high fees (for an index tracker) and so I did some more research on other index trackers, wrote to a few of them and this one came up trumps. So now Iāve got an account with Banco BPI (which they did remotely) and Iāll probably close the Millennium account.
For completeness, Iām chasing down one other idea but it feels like a long shot. Global X (the massive fund manager based in New York) also do a PSI 20 index tracker and it has even lower fees (0.65%). But they arenāt based in Portugal and I suspect that they wonāt be able to help with the GV confirmations that SEF require. Iāve written to them and am waiting to hear back - will update this forum if the news is positive. This would really be perfect for me because at least one of the U.K. pension providers have it on their list and so I could invest my SIPP pension fund in it AND get a GV (!).
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Keep in mind that the whole fund route thing is new as of 2018(?) legislation. You donāt figure all this stuff out overnight. Consider the length of this topic and all of the discussion thatās been had trying to figure out whatās even possible with the funds we knew about, and then some more show up.
There arenāt a lot of information sources on the matter either. Most of us have either been getting information from the internet, or from folks like magwind or GCS (who may have a specific axe to grind because they get a cut), or from immigration lawyers who simply arenāt investment experts to have any idea one way or the other. (My lawyer just had that conversation with me today - āweāll evaluate whether an investment is legal but we arenāt investment expertsā.)
So that is the exact point of this thread - to collect peopleās experience and knowledge. Right?
So, I was talking about investments with my lawyer today, and she said that while splitting works, she advised against more than a two way split - not that itās not legal, or that you wonāt get approved, but it gums up the works; itās somehow out of the normal workflow and your application will take a lot longer to process. Why? Who knows. She just said that was the view of everyone she knew in the biz.
Bummer because I was counting on three. But.
YMMV/EUR0.02.
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Thanks for posting about the BPI Portugal FIAA Fund. That is the first I have heard of this fund.
As for Global X, I have been looking at this one also and the same thought, but I do not believe that it will qualify. Even if they were willing to make the certifications that more than 60% of the investments are in PT companies (which would be easy given the fundās investments/purpose), my reading of the law is that the Fund itself must be āconstituted under Portuguese legislationā (i.e. subject to CMVM regulation).
From SEF: https://www.sef.pt/pt/pages/conteudo-detalhe.aspx?nID=62
vii) TransferĆŖncia de capitais no montante igual ou superior a ā¬ 350 000, destinados Ć aquisiĆ§Ć£o de unidades de participaĆ§Ć£o em fundos de investimento ou fundos de capitais de risco vocacionados para a capitalizaĆ§Ć£o de empresas, que sejam constituĆdos ao abrigo da legislaĆ§Ć£o portuguesa, cuja maturidade, no momento do investimento, seja de, pelo menos, cinco anos e, pelo menos, 60 % do valor dos investimentos seja concretizado em sociedades comerciais sediadas em territĆ³rio nacional;
Google Translation:
vii) Transfer of capital in an amount equal to or greater than ā¬ 350,000, intended for the acquisition of units in investment funds or venture capital funds dedicated to the capitalization of companies, which are constituted under Portuguese legislation, whose maturity , at the time of the investment, be at least five years and at least 60% of the value of the investments be made in commercial companies based in the national territory.
Obviously, something to check with your PT lawyer who would know better. I suspect that this legal requirement will be an even larger roadblock than convincing Global X to make a certification.
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Honestly I would go with IMGA AƧoes or a similar publicly traded fund but I am quite skeptic about the acceptance of those funds. Because the law says:
vii. Capital transfer of the amount of 350 thousand Euros, or higher, for the acquisition of units of investment funds or venture capital fund of funds dedicated to the capitalisation of companies, capital injected under the Portuguese legislation, whose maturity, at the moment of the investment, is, at least, of five years and, at least, 60% of the investments is realized in commercial companies with head office in national territory;
But practically those funds does not capitalize any company, they are buying someone elseās share. VC funds are really injecting capital to the companies and increasing their capital. So I wonder why should Portuguese state accept this?
I asked my lawyer about it and he claimed he had not had any rejections yet in the 6-7 he had done with IMGA. That doesnāt mean of course that they got an approved GV yet.
By that vein though how would all the VC funds doing real estate rehab qualify? Iām honestly askingā¦
My understanding is that the real estate venture funds typically are buying into/capitalizing special purpose vehicles (SPVs) who buy/develop/own the underlying real estateāi.e. the funds do not simply own the real estate directly like a REIT. I had always assumed this was at least in part to make sure it satisfies the ācapitalization of companiesā requirement, but others may know better.
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Ah ok thanks
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The wording of the legislation is capable of various interpretations. Maybe the ācapitalisation of companiesā requirement is for venture capital fund of funds but not for investment funds. That would give hope to tbe Global X route. Or maybe capitalisation is widely interpreted. The 5 year maturity requirement isnāt clear to me either - I can think of a variety of ways to read that. Lawyers have given me different interpretations of these provisions and I donāt think SEF gives guidance. Ultimately what matters is what SEF approves in practice and probably they like it that way. Iāve been told by the legal department of BPI clearly in writing that SEF is fine with their BPI Portugal FIAA fund for GV purposes and that they will help me with the certificates, just as they have done for other clients in the past. Thatās all that I need to know, so Iām not going to second guess SEFās interpretation.
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The ācapitalization of companiesā language is a different issue from the āconstituted under Portuguese legislationā issue.
I think the issue with Global X PGAL fund is that it is a US company and not āconstituted under Portuguese legislationā which is required of all qualifying funds. The unfortunate part of this if you are a US citizen is that if PGAL satisfied SEFās requirements, you may avoid PFIC issues since PGAL is not a PFIC (i.e. itās fails the āFā part of PFIC since it is not foreign). If you go with the IMGA or the BPI funds, you have the PFIC issue, which isnāt the end of the world but you will probably end up with a less desirable tax treatment in the US (or at least more complicated tax filings).
As for the ācapitalization of companiesā language, it is a bit ambiguous as to whether it applies to both investment funds and venture funds, or just to venture funds. That said, Iām not sure it matters. Buying shares in a ETF/mutual fund who then buys shares in a listed company is capitalizing the listed company much the same way as buying shares in a venture fund who then buys shares in an unlisted company to capitalize the unlisted company. Iām not sure I follow ZYās comment about why this language would be an issue.
Anyway, as you said, at the end of the day, what ultimately matters is whatever SEF decides and it seems like IMGA and BPI funds are both being accepted . It just would have been nice if Global X PGAL was too, but doesnāt seem likely.
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I just wish either one made a decent return 
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Yup, and as an āunsophisticated investorā Iāve learned soooo much from discussions on this thread - for which grateful thanks to all the investment-savvier posters for sharing thoughts & discoveries.
The frustrating thing is thereās no centralized source of authoritative info (SEF & CMVM donāt answer emails), no official directory of lawyers dealing with GV, no comprehensive list of GV-qualifying funds (apart from Nomad Gateās partial list), no list of GV-eligible āculturalā investmentsā¦ which means months & months of exploration & research sorting out (sometimes contradictory) answers to questions.