Capital Green III – Fundo Fechado de Crédito

Capital Green III is the third vintage in Finprop Capital's series of closed-end Portuguese credit funds: senior, collateral-backed loans to small and mid-sized companies, wrapped in a 10-year vehicle with fixed-return classes targeting 6-8%. For Golden Visa investors who prefer a bond-like income profile over equity risk, that is the appeal. The trade-off sits in the paperwork: several commercial terms are inferred from series documents rather than CG III filings, and the exit mechanics before year ten are genuinely unclear.

What does the fund actually invest in?

The strategy is private debt in its plainest form: senior, collateral-backed loans to small and medium-sized companies operating in Portugal, with loan maturities of roughly two to four years, per the manager's fund page and the series teaser. The lending guidelines target creditworthy borrowers with good growth prospects, favour energy-efficiency projects and positive community impact, and exclude ethically conflicted projects.

Two structural points follow from that. First, there is no stated real-estate exposure, which matters because the post-October 2023 Golden Visa rules exclude funds with direct or indirect real-estate holdings. Second, short loan maturities inside a 10-year fund mean the manager expects to recycle capital through several lending cycles before winding up.

The wrapper, according to the series teaser, uses fixed-return participation classes, with both distributing and accumulating options. CG III's own class documents are not published, so this description carries over from the series rather than from fund-specific filings. The stated range of 6% to 8% appears on the manager's fund page, and in the series structure the fixed-return classes step up from 6% toward 8% in later years.

Finprop Capital itself is a Porto-based fund manager affiliated with the Hipoges asset-management group, run by managing partners Ricardo Pereira and Hugo Velez with Nuno Godinho as director of investments. The firm operates several near-identical vehicles, from the original Capital Green through CG IV. That repetition reads as a production-line lending model rather than a one-off fund, which cuts both ways: repeatable process on one hand, less vintage-specific disclosure on the other.

What do the fees cost you over a Golden Visa hold?

Here the honest answer starts with a caveat. No CG III-specific fee schedule is publicly available. The 1% management fee comes from the Capital Green series teaser, which describes the original fund in the series and which the manager links from the CG III page. Performance, subscription and redemption fees are simply not published for this vintage.

Taking the reported 1% at face value, the arithmetic on a €500,000 Golden Visa subscription is straightforward. Management fees run about €5,000 per year, roughly €30,000 over six years and €35,000 over seven. Held to the full 10-year maturity, the same rate would total around €50,000. If accurate, that sits below the 1.5-2% band typical of Portuguese Golden Visa funds, and a fixed-return class structure blunts the usual worry about performance fees eating upside.

The service providers carry the same qualifier. Bison Bank as custodian and Ernst & Young as auditor both come from the series teaser and are not separately confirmed for CG III. None of this is unusual for a private credit vehicle, but it does mean the subscription documents you are eventually shown are the numbers that count. Compare them line by line against the teaser before signing.

Liquidity, lock-up and the citizenship timeline

This is a hold-to-maturity product. The fund is closed-end with a 10-year term and no interim investor redemptions; capital returns through distributions and at liquidation, per both the manager's page and directory records. There is no NAV-based exit window to plan around.

One data conflict deserves attention. Directory data lists a 60-month lock-up for the fund, yet nothing published explains what happens at month 61 in a vehicle that does not mature until year ten. It may reflect a class-level feature, a secondary-transfer provision, or simply a data-entry convention. No public document resolves it.

Distributions soften this somewhat. Fixed-return classes are designed to pay out along the way, so the position is not entirely frozen cash. But the principal itself has no published route out before term, and a private secondary sale of closed-end fund units is never something to count on.

What should US citizens know?

For US persons, the file is thin. Nothing is published about whether the fund accepts US investors, whether it provides QEF annual information statements, or whether IRA or SDIRA money can subscribe. As a non-US pooled credit fund, PFIC treatment should be assumed.

That assumption has teeth. Under the default PFIC regime, distributions and gains can be taxed at top ordinary rates plus an interest charge. A QEF election converts that into annual pass-through taxation, but it requires the fund to issue annual information statements, and there is no indication either way that Finprop does. In our experience, this single question often moves the net outcome more than headline fees do.

The practical path: ask the manager in writing whether US persons are accepted, whether PFIC annual information statements are provided, and whether the fund has taken US tax advice on its class structure. Forms 8621 and 8938 will apply regardless. Model the after-tax result with a US adviser before wiring anything.

How does it compare with other Golden Visa funds?

Within our database, CG III sits in the small credit category, where most Golden Visa capital chases equity strategies instead. Its €200,000 minimum is double the €100,000 ticket typical of the segment, though the distinction matters little to visa applicants, who must subscribe €500,000 either way. The reported 1% management fee, if confirmed, would undercut the usual 1.5-2% range.

The natural comparison is its own sibling. Capital Green IV runs the same strategy, minimum and 10-year term in a fresher vintage, but its Golden Visa eligibility is not yet confirmed, whereas CG III carries an eligible flag on its verified directory profile. Vintage and verification status are the real differences between the two. Investors who want credit exposure with actual liquidity should look at open-ended alternatives such as the 3CC Portugal Golden Income Fund, which trades a fixed-return profile for daily dealing. The wider set is in our fund database.

What CG III offers that many peers do not is simplicity: a lending book, collateral, fixed-return classes, and a manager backed by a large servicing group repeating the same model across vintages.

What the fund has not published

For completeness, the gaps, whose weight depends on your own situation rather than on any judgment of ours. The inception date and capital raised to date are not published. No CG III-specific fee schedule exists publicly, so performance, subscription and redemption fees are unknown, and the 1% management fee, custodian and auditor are inferred from series documents. US investor acceptance and PFIC/QEF reporting are unconfirmed. And the exact lock-up and early-exit mechanics remain unclear, with directory data showing 60 months against a 10-year maturity.

None of these gaps is unusual for a private Portuguese credit fund. All of them are answerable by the manager during subscription diligence, and each answer belongs in writing.

Next step

If a fixed-return, hold-to-maturity credit profile matches your Golden Visa plan, the sensible next move is a document-level walkthrough rather than a decision from headline terms. Roots can take you through CG III's subscription materials alongside comparable funds, independently and without a sales agenda. This is information, not investment, tax or immigration advice; capital is at risk, and targeted returns are not guaranteed.