Hi all. I’ve not seen anyone answer this question although I believe it has been raised previously. If we have completed the entire process except for the SEF in-person appointment, will we be considered using 2021 investment rules (i.e., Euro 350k fund investment)? Given what I’ve seen here, our SEF appointment may not happen until January or later. As long as we’ve done everything else, will their consider our application under 2021 rules? Thanks.
The cut-off point for applicable rule is the submission for pre-approval: as long as pre-approval is submitted by 31 Dec 2021, old rule applies.
Thank you, @rogergan68. Our attorney has said as much as well, but wasn’t able to show us any formal declaration from SEF or other government entity. Do you know if there’s some formal memo or declaration from the Portuguese government which confirms this rule?
any bets on SEF slowing down pre-approvals as the year comes to an end?
Lets hope that wouldnt be the case. Having said that, i would NOT want to be in the position of just submitting an application now, or even 2 weeks ago. It was taking 3 months a year ago. I can only imagine that there is some truth to your suggestion and I would not count on anything getting done the last week of the year. So at this point there is only 2.5 months left. Way too risky… I personally would just assume the 2022 standards if I were applying now so that either way I would be covered.
After the treatment my wife got from her SEF clerk, yeah, I wouldn’t be the least surprised that there’s some SEF clerks just sitting on people’s files - yeah I’ll do these 10 D7s first sort of thing. It’s just not hard for the staff to gum up the works, esp for folks who don’t have lawyers who have SEF managers on speed-dial. Meanwhile the industry’s going all great-guns about “get your applications in before the deadline!” which is no doubt adding to the load. I wonder how many of those investments are offering a guarantee or easy-out if they don’t get in before the deadline…
none of this will end well.
Thanks, @rogergan68 .