b'4.To avoid having to register as an investment adviser, no person can be paid a fee in connection with any investment, nor should any one person select investments for the club. However, you can have club dues that people pay to club organizers to market the group; remind people to attend, or to provide refreshments for live meetings, etc. You could also have some criteria, such as a minimum amount that each member must invest in club offerings each year to maintain their membership, and to prevent the club from turning into a social gathering. 5.The club should be limited to accredited investors so that it meets the definition of an accredited investor (i.e., any entity in which all members are accredited investors) so that it can invest in any offering that allows accredited investors.a.If the club has non-accredited investors, they would only be able to invest in Rule 506(b) offerings, and the issuer in which the club invests might have to count your non-accredited investors toward its 35-person limit.Why Start an Investment Club? An investment club could be a good choice if you want to help your friendsandcolleaguesbeexposedtomoreinvestmentopportunities, withouthavingtheminvestpassivelyinagroupyouorganize(i.e., syndicate). It could also work for situations where you want to offer club members the ability to invest less than the required minimum investment ($50k-$100k) that most syndicates or funds require.150'