SPV Investor Onboarding Checklist

An SPV investor onboarding checklist is the pre-wire sequence that makes the subscription, KYC/AML file, tax form, accreditation path, and bank name match the same human or entity. Collect the pack before you publish wire instructions. A signed-but-unfunded subscription is cheaper to unwind than a funded mismatch on close day.

General information only - not legal advice, not AML program design, and not investment advice. Counsel owns the offering; the bank owns its CIP. Product surface: SPV. Banking path: /banking. Deep dive: KYC/AML investor onboarding for SPVs.

Master checklist (print this)

Formation context around this list: How to set up an SPV. Bank file: How to open an SPV bank account; SPV bank account, EIN, KYC. Admin scope: What SPV administration includes.

Individual LP pack

Collect before the wire:

• Full legal name, date of birth, residential street address (not PO-box-only when the bank rejects it).

• Identification number (SSN/ITIN for US persons; passport or other government ID for non-US persons).

• Copy of unexpired government-issued photo ID.

• Signed subscription (and any required questionnaires).

• W-9 or correct W-8.

• Accreditation representation or 506(c) verification evidence.

• Source-of-funds answers your procedure actually requires.

Common fails: expired passport, nickname on the sub, middle initial only on the tax form, joint subscriptions with one W-9 for two people.

Entity LP pack

• Formation document, good standing (or equivalent), EIN or foreign equivalent.

• Authorized-signer ID and authority (resolution, OA excerpt, or POA).

• Beneficial owners / control person as your bank and AML procedure require.

• W-9 or W-8BEN-E / W-8IMY - not a W-8BEN in the entity's own name.

• Look-through answers for pooled vehicles when the procedure asks.

Non-US investor ops: Can I have non-U.S. investors?. FATCA/CRS education: FATCA and CRS for SPVs. IRA / custodian quirks belong in the same folder as identity - custodian is often the subscriber of record.

Accreditation is not AML

AML / KYC answers 'who is this person and are they sanctioned?' Accreditation answers 'may this person buy this private security under the exemption path you chose?'

• 506(b) vs 506(c) solicitation and verification depth: Comparing 506(b) vs 506(c).

• 506(c) verification mechanics: 506(c) accredited investor verification for SPVs.

Do not treat a brokerage letter as a sanctions screen. Do not treat a passport as 506(c) verification.

Wire and name-match rules

Publish instructions only when:

1. The SPV bank account is open in the exact legal name.

2. Subscriptions are signed (or soft-circle policy counsel accepts - most GPs want signed).

3. Screens are clean or escalations resolved.

4. Tax forms are on file for everyone you will accept.

Match four strings: ID name = subscription name = tax-form name = wire originator name (or document the third-party wire). Capital call / notice hygiene for later calls: Capital call notice explained.

Roles when money moves: Custodian vs administrator vs bank.

Capacity, closes, and fees (ops constraints)

Onboarding volume must fit the vehicle SKU and OA. Allocations publishes (fetched 8 Sep 2026 from /fees):

• Standard SPV $9,950 - up to 35 investors included; one close; US startup/VC types; 0% platform carry.

• Premium SPV $19,500 - up to 50 investors; multi-close support (1 included); any asset type; 0% platform carry.

• Extra investors +$100 each; Premium extra closes $2,000 each. Additional fees may apply.

• Off-platform LP onboarding add-ons appear on the live schedule - confirm before you promise a custom path.

Fee explainers: SPV fees explained; How SPV pricing works on Allocations. After close, Form D / blue sky: Form D & blue sky.

Post-onboarding handoff

When the close sheet is final:

1. Freeze the ownership ledger (subscriptions + accepted amounts).

2. Archive ID / tax / accreditation / screen results per counsel and bank clocks.

3. Issue any welcome / capital account confirmation your process uses (Capital account in a private fund).

4. Queue tax ops for K-1 season (SPV K-1s and taxes).

ERISA plan-asset awareness if benefit plans appear: ERISA 25% test for SPVs.

Side letters and exceptions (keep them boring)

Side letters belong in the same close folder as the subscription - not in a private inbox the administrator never sees. If an LP gets fee, information, or transfer language that differs from the form OA, version it, log it on the close sheet, and make sure capital-account coding can honor it later. Unlogged exceptions are how distribution notices and K-1 footnotes disagree.

Club vs syndicate process differences do not change the checklist order - they change how large the invite list is: Club deal vs syndicate SPV. Family-office co-invest packs still need entity KYC: Family office co-invest SPV.

Day-of-close war room (short)

On close day, run one reconciliation pass:

1. Accepted list - every row has signed sub + tax + screen + accreditation status.

2. Money list - cleared wires by originator name and amount.

3. Reject / pending list - incomplete files do not silently become 'in.'

4. Asset wire readiness - outbound instructions match company/seller docs only after inbound cleared funds are real.

If you are still chasing passports at the same hour you are wiring the company, you inverted the checklist. Admin vs accounting ownership after the war room: Fund accounting vs fund administration.

What this page is not

• Not a bank CIP policy or FinCEN filing workshop.

• Not tax advice on W-8 classification.

• Not investment advice or a returns claim.

• Not a competitor onboarding comparison.

FAQ

What belongs on an SPV investor onboarding checklist?

Identity/KYC, sanctions screen, tax form, accreditation path, signed subscription, source-of-funds answers, and a wire name-match - completed before you publish instructions or accept the close.

Is accreditation the same as KYC?

No. Accreditation is a securities-offering fact. KYC/AML is identity, beneficial ownership, and sanctions. They share a folder; they are not substitutes.

When should I send wire instructions?

Only after the SPV account is live in the correct legal name and the investor file (ID, tax, screen, sub) is complete enough that a funded mismatch is unlikely.

How many investors can a Standard SPV onboard on Allocations?

Published Standard SPV includes up to 35 investors; extras are +$100 each on /fees (fetched 8 Sep 2026). Premium includes up to 50. Confirm live numbers before you invite.

Where do non-U.S. investors add friction?

Tax forms (W-8 series), banking KYC, and sometimes FATCA/CRS reporting - see Allocations education on non-U.S. investors and FATCA/CRS. Build extra time into the checklist.