Can I warehouse an investment in another fund?

You may be able to, however, please note in practice transferring the warehoused investment to your fund would be difficult because you would have to obtain consent from the fund you invested in to transfer your ownership to your own fund. If you are still actively fundraising, you will not know your fund's final underlying ownership count and this may cause the fund you invested in to blow its securities exemption. In addition if you do transfer this interest to your fund, the investment would count towards your fund's 20% non-qualifying investment bucket.