Yes, almost always. Club deals are private placements exempt from public registration (e.g., Reg D in the US), meaning they are legally restricted to sophisticated investors.

  • Accredited Investor: ~$1M+ net worth or $200k+ income.

  • Qualified Purchaser (QP): $5M+ in investments (individuals) or $25M+ (entities).

  • Why it matters: Many top-tier club deals require “QP” status to avoid capping the number of investors at 99.

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