Definition
Qualified Purchaser
An investor with at least $5 million in investments, a higher bar than accredited investor.
A qualified purchaser is defined in section 2(a)(51) of the Investment Company Act, generally as an individual holding at least $5 million in investments, or an entity holding at least $25 million in investments for itself or others. The status matters because of the exemption it unlocks: a fund whose investors are all qualified purchasers can rely on section 3(c)(7) and admit far more than the 100 beneficial owners that section 3(c)(1) permits. For a single-asset SPV raising from accredited investors, qualified purchaser status is usually irrelevant. It becomes relevant at scale, when a sponsor's investor count approaches the 3(c)(1) ceiling and the choice is between a second vehicle and a higher-net-worth investor base.