Under Rule 506(c) of the United State Securities and Exchange Commission (SEC), of which the Creative RE Capital Fund operates, fund subscribers must be able to demonstrate, and provide evidence that they are accredited before a fund may accept them as a fund subscriber.

Individuals (i.e., natural persons) may qualify as accredited investors if they meet any of the following wealth, income, or financial sophistication criteria:

Individual Investor Financial Criteria

Net worth over $1 million, excluding primary residence (individually or with spouse or partner).

Income over $200,000 (individually) or $300,000 (with spouse or partner) in each of the prior two years, and reasonably expects the same for the current year.

Professional Criteria

Investment professionals in good standing holding the general securities representative license (Series 7), the investment adviser .representative license (Series 65), or the private securities offerings representative license (Series 82).

Directors, executive officers, or general partners (GP) of the company selling the securities (or of a GP of that company).

Any “family client” of a “family office” that qualifies as an accredited investor.

For investments in a private fund, “knowledgeable employees” of the fund.

More information on how the SEC defines "accredited investors" can be found here: https://www.sec.gov/resources-small-businesses/capital-raising-building-blocks/accredited-investors

Open-end, evergreen Delaware LLC offered under Rule 506(c)

Target raise: $25 M (up to $50 M at Manager’s discretion)

Strategy: short-term, first-position hard-money loans (6–12 mo., ≤75% ARV) plus second-lien creative finance (≤25% AUM; combined CLTV ≤85%)

Focus on fix-and-flip, value-add multifamily, and light commercial in high-growth Midwest markets

Management fee: 2% AUM, paid monthly

Distributions: 100% of net income (after fees/expenses) is paid pro rata to Members quarterly

Carry or Performance Fee: None—no waterfall or profit split beyond AUM fee

Minimum subscription: $50,000 (waivable by Manager)

Accredited investors only (506(c) verification required)

Subscription funds held in a non-interest–bearing account until deployed

Lock-Up: 24 months (hardship exceptions may apply with Manager approval)

Post-lock-up: 90 days’ written notice per redemption request

Quarterly redemptions capped at 25% of an individual’s capital and 10% of total fund capital per fiscal year

Frequency: Quarterly, within 30 days after quarter-end

Reinvestment Option: Members may elect to auto-reinvest distributions at the current NAV

Manager may adjust or suspend reinvestment at its discretion

Initial Unit Price: $1,000

NAV Updates: Monthly, based on the stated value of assets and loan performance

Full transparency with monthly NAV and portfolio metrics

Conservative LTV/CLTV: First-lien ≤75% ARV; combined ≤85% CLTV for seconds

Due Diligence: BPO/appraisals, sponsor track records, site inspections

Ongoing Oversight: Draw monitoring, property reviews, and loss reserves

Sponsor co-investment aligns interests

Quarterly Reports: Performance, asset-level updates via secure portal

Annual Financials: Prepared by an independent accountant (audits at Manager’s discretion)

Governance: Manager-managed with limited Member votes (e.g., removal for cause, major amendments)

Updates on committed vs. deployed capital

Key pipeline metrics: number of loans in underwriting, average hold period, weighted average coupon

Case studies of closed transactions available on request