Additional Investor Policies
POLICY ON DE MINIMIS DISTRIBUTIONS
Alumni Ventures Group, LLC, and Alumni Ventures’ affiliated investment funds (“AV Funds”), occasionally accrue de minmis distributions payable to investors. Administration of these small distributions to investors generates costs and other burdens. To reduce these burdens, those entities will accrue and withhold distributions otherwise payable to investors until the soonest of:
1. The aggregate amount payable to the investor by Alumni Ventures Group, or by all AV Funds in which the investor holds investments, is at least $250.
2. The end of the calendar year, at which all distributions will be paid to all investors irrespective of amount.
3. The investor contacts Alumni Ventures, LLC and requests in writing that one or more de minimis distributions payable to them by an AV Fund be paid notwithstanding this Policy.
4. An AV Fund is about to wind up and dissolve, in which case all its distributions will be paid to all its investors irrespective of this Policy.
Distributions accrued or withheld under the Policy will not accrue or pay interest. Distributions accrued or withheld under this Policy, when paid by one or more AV Funds, may be aggregated into a single payment accompanied by a statement itemizing the payment. However, distributions from Alumni Ventures Group, LLC will not be aggregated with distributions from one or more AV Funds.
POLICY ON DISTRIBUTION OF FORMS K-1 AND IRA INVESTORS
All Forms K-1, regardless of the method or vehicle of investment, are available for download in investor portals.
If you prefer for your Form K-1 to be delivered electronically only, you can select that option within the “Settings” of your investor portal.
For investments made through Individual Retirement Accounts (IRA), Forms K-1 are made available to the IRA custodian. Alumni Ventures provides a valuation statement to IRA custodians on a yearly basis to facilitate certain tax reporting. This valuation statement is provided in accordance with Alumni Ventures’ valuation policy.
To request that a paper copy of a Form K-1 be sent to your IRA custodian, please contact [email protected].
QUARTERLY DISTRIBUTION AND PORTAL UPDATE POLICY
In general, and subject to its Policy on De Minimis Distributions above, Alumni Ventures endeavors in good faith to pay distributions to investors in Alumni Ventures Group, LLC and AV investment funds within 45 days of quarter-end. These payments typically take the same form as the payment used to fund the investment. For example, an investor funding an investment by ACH will receive distribution payments by ACH.
In general, Alumni Ventures endeavors in good faith to provide updates on its funds and certain of their underlying holdings on a quarterly basis.
For each investor, Alumni Ventures will publish updated valuations for AV funds and their underlying portfolio company investments, to which the investor has exposure. These updates will be made in accordance with Alumni Ventures’ valuation policy.
In addition, Alumni Ventures will make good faith efforts to provide news updates on individual portfolio company holdings for the affiliated investment funds in which an investor has invested. These updates are generally limited to information provided by management, and notable media reports. However, given the volume of Alumni Ventures’ venture investing, it is not possible to guarantee comprehensive updates for all holdings. Updates will not be available every quarter for every portfolio company.
Alumni Ventures reserves the right to withhold material, nonpublic information from news updates where it determines a risk of liability under the securities laws exists for portfolio company management, investors, or itself.
LOYALTY REWARDS PROGRAM POLICY
To reward investor loyalty and timely decisions on investment, Alumni Ventures has developed a Loyalty Rewards Program Policy. The basics of this policy are accessible here.
The investment deadlines for Timing Rewards are intended to be hard and fast. In general, Alumni Ventures must receive executed subscription agreements by the applicable First Close or Second Close date, and must receive all investment funds within thirty days thereafter, for an investor to be eligible for Timing Rewards. Outside of extraordinary circumstances, such as a delay caused by Alumni Ventures itself, investors should not typically expect these deadlines to be extended.
Senior Partners and Managing Partners do not have authority to extend Timing Rewards deadlines or change investment minimums for Committed Capital Rewards.
ALUMNI VENTURES AML/KYC AND ACCREDITATION VERIFICATION PROCEDURE
Alumni Ventures is subject to certain Anti-Money Laundering and Know Your Customer (“AML/KYC”) obligations. AV relies on a third party vendor, Parallel Markets, to conduct certain procedures to satisfy these obligations. In general, AV is not in a position to accept requests to vary Parallel Markets’ procedures or to create exceptions for individual investors. In limited cases, AV may be able to assist an investor with the process of providing documentation to Parallel Markets.
Alumni Ventures’ investment offerings are subject to certain requirements under the U.S. securities laws, including 17 CFR 230.506. Typically, these requirements limit eligibility to invest to “accredited investors” as defined in 17 CFR 230.501. Parallel Markets conducts verification procedures to confirm accredited investor status. In most cases, accreditation must be verified for each legally distinct investor, such as an individual, a trust, and an LLC, even if they are under common control or benefit the same person.
In general, an investor that has participated in verifying its accredited investor status with Parallel Markets need not do so again for subsequent investments made within a year of verification. However, investors with highly significant investments with Alumni Ventures may be eligible for a longer period before they are required to verify accredited investor status again.
Alumni Ventures reserves the right, in its sole and absolute discretion, to decline investments it deems inappropriate, and/or to require a prospective investor or actual investor to cooperate in additional AML/KYC or accredited investor status verification where it deems such additional procedures appropriate.