PORTUGAL GOLDEN INCOME FUND

Everything You Need to Know

Golden Visa

What is the minimum subscription amount for the Portugal Golden Income Fund?

The minimum subscription for the 3CC Portugal Golden Income Fund is €10,000 for Category B and €100,000 for Category A.

What is the minimum amount required to qualify for the Golden Visa program (ARI) through fund investment?

The minimum initial investment is €500,000.

How can I apply for a Golden Visa by investing in funds?

To apply, you must first obtain a Portuguese tax identification number as a non-resident and open a bank account in Portugal. After this, submit the account opening form along with the necessary personal documentation. Transfer the required amount from your foreign bank account to your Portuguese account, then submit the subscription form and arrange for the investment transfer to the 3CC Portugal Golden Income Fund bank account.

What documents are required for the Golden Visa application?

You will need a declaration from your bank confirming the transfer of funds in an amount equal to or greater than the legal minimum, and a declaration from 3 Comma Capital confirming your investment in the 3CC Portugal Golden Income Fund.

As a Portuguese investor, can I invest in the fund, or is it exclusively for the Golden Visa program?

The fund is open to any investor, including those who wish to gain exposure to Portuguese Corporate Debt (Investment Grade), U.S. Equities, and Alternative Assets, not exclusively for Golden Visa applicants.

Can I contact someone at 3 Comma Capital to help with the account opening process?

Yes, you can request assistance by completing the contact form available below, by calling +351 213 622 464, or by emailing hello@3commafunds.com.

If there is an issue with the custodian bank or 3 Comma Capital, will the Fund be affected?

No. The assets of the Investment Fund are autonomous, meaning they are owned by the participants. In the event of insolvency of either the custodian or 3 Comma Capital, the Fund's assets will remain unaffected, and the CMVM (Portuguese Securities Market Commission) will appoint another entity to manage the Fund.

Where can I obtain more detailed information about the Fund?

Additional information, including key documents like the KIID and Prospectus, can be found at 3commacapital.com/open-ended-funds/Portugal-golden-income/. These documents are also available on the regulator’s website (CMVM).

Management Company and the Portugal Golden Income Fund

3 Comma Capital was launched in 2022. Can you provide a track record for funds managed by Patrick Hable and Nuno Serafim?

Yes. The 3 Comma Capital I, Private Equity Fund, launched in September 2023, has achieved a 73% return since inception, as of 30/06/2024.

Why allocate 65% of the portfolio to Portuguese Corporate Debt?

The Portuguese equity market has historically underperformed. For example, the PSI20, the Portuguese Stock Index, is roughly at the same level it was 20 years ago. The PGI Fund focuses on Investment-Grade bonds (70%), which are liquid and offer a favorable risk-return profile. We complement this with U.S. Equities and Digital Assets, targeting better risk premiums. As a daily liquidity Fund, this structure allows for more flexibility, which is key for investors

3 Comma Capital specializes in modern asset allocation, combining traditional and digital assets. Can you elaborate?

Our team integrates traditional investments, such as bonds and equities, with digital assets to optimize portfolio performance. This strategy aims to balance the relative stability of traditional investments with the high-growth potential of digital assets, diversifying and enhancing returns while managing risk.

Does the Fund have a dividend distribution policy?

No, the Fund does not currently offer income distribution. We may consider creating a new share class for income distribution in the future, but this is not planned in the near term.

Are there any voting rights or differences between Category A and B shareholders?

There are no differences in voting rights. The main distinction between Category A and B is the minimum investment required and the management fees associated with each category.

Can you explain the redemption fee, which starts at 5% in year 1 and reduces to 1% by year 5? Is there any difference between Category A and B?

The redemption fee structure is designed to encourage long-term investment. It decreases from 5% in the first year to 1% by year five. There is no difference in the redemption fee between Category A and B shareholders.

Does the Fund invest directly in corporate bonds, U.S. equities, and digital assets, or are ETFs used?

The Fund invests directly in Bonds, while U.S. Equities and Cryptocurrency exposure is gained through ETFs or Funds.

Which ETFs or mutual funds are used for digital asset exposure?

We utilize recently launched ETFs, as well as our own Global Crypto Fund, depending on the market conditions. A combination of both may be employed simultaneously.

Why does the Portugal Golden income Fund operate as a capitalization fund, instead of distributing income?

The Portugal Golden Income Fund is structured as a capitalization fund to maximize compounding growth. By reinvesting all earnings, the fund avoids interrupting the compounding effect and eliminates the tax liabilities typically incurred from distributed income.
After 5 years and 1 day (following the application for citizenship), Golden Visa investors can choose whether to interrupt the compounding by selling all or part of their shares or continue benefiting from ongoing growth opportunities without the need to seek new investments.

Why focus on U.S. equities instead of other assets?

Historically, U.S. equities have been the best-performing equity market. We do not foresee this trend changing significantly in the future.

Can the Fund provide a declaration confirming its eligibility for the Golden Visa?

Yes, we can provide a standard declaration from the management company confirming that the Fund meets all AIMA guidelines, including the allocation of a minimum of 60% of its assets to Portuguese-based corporate debt, making it eligible for the ARI (Golden Visa) program.

Which digital assets does the Fund invest in? Bitcoin? Ethereum? Others?

The Fund invests in Bitcoin, Ethereum, and Solana—projects we understand, believe in, and are confident will remain relevant over the next decade.

Why is raising the Sharpe ratio to 1 through a 10% allocation to Bitcoin important?

Increasing the Sharpe ratio to 1 improves the risk-adjusted returns, which is the most reliable measure of investment success.

How do you manage risk given that the cryptocurrency market operates 24/7?

We manage risk by limiting our exposure to digital assets to 15%, which is carefully monitored.

According to your simulations, there is a 90.8% probability of positive returns after 2 years, rising to 100% after 3 years. Does this mean you recommend a minimum 3-year investment?

We recommend a 5-year investment horizon. Our back-tested model, based on historical performance and volatility, suggests a very low likelihood of losses after 2 years, and that probability decreases as time passes.

Are there any special KYC requirements or investor profile conditions?

No. The Fund is available to retail investors. However, we conduct a KYC process as required by regulations to ensure that there is no mismatch between the client's risk profile and the Fund’s expected returns and volatility.

What are the legal regulations regarding cryptocurrency in Portugal, and why should investors subscribe to the Fund rather than directly own crypto?

By subscribing to the Fund, investors can gain access to the Golden Visa program, expert advice on allocation strategies, and professional asset custody services—benefits not available through direct ownership of cryptocurrency.

Can investors subscribe to the Fund using Bitcoin?

No. All subscriptions to the Portugal Golden Income Fund must be made in Euros.