General Investor Questions

What is Eastview Capital?

Eastview Capital is an online platform offering curated investments to accredited investors, family offices, and investment funds. We aggregate investor capital and make debt & equity investments in entities that own real estate assets. Technology enhances every element of our Mission.

What is eastview capital's mission?

Our mission features 3 primary components:
   Identify:      Curate compelling investment offerings 
   Offer:           Maintain an active online marketplace with concise offering presentations
   Manage:      Timely distributions, relevant project updates, & building trust with investors & owners

What type of Real Estate?

We define Commercial Real Estate as “income-producing properties operated to generate a profit via rental income, capital improvements, and/or appreciation” and focus primarily on these asset types: 

Apartments (or “multifamily”)
Self Storage 
Industrial / Warehouse 
Hospitality (hotels)


Across the United States, with a focus on the Top 50 metro areas & premium locations in all metro areas.

Why Commercial Real Estate?

Three key reasons:

  1. It is who and what we know: our relationships with owners, lenders, & investors and expertise with investment structuring, underwriting, and access to reliable market intelligence are potent ingredients for our dynamic platform.
  2. Online-compatibility:
    1. websites clearly convey complex offerings using images, maps, videos, and reports
    2. investors can securely execute transactions, sign documents, & manage distributions
    3. digital tracking is conducive to multi-party record keeping & compliance
  3. Market Size: Commercial Real estate is among the top asset classes, with an estimated valuation of $16 trillion in the United States in 2018.



What type of investments do you offer?

We offer a range of investment types. In ascending order of yield / risk objectives:



Risk / Yield Objective

Senior Debt

senior lien on collateral


Mezz / Subordinate debt

Lien & agreement with senior lender


Preferred Equity

equity with priority to Sponsor equity


Joint Venture Equity

equity with equivalent risk to Sponsor


 Disclosure: Actual returns may vary from the yield objective and there can be no assurance that an investment’s actual performance will lead to the targeted results or perform in any predictable manner.

What is the minimum investment amount?

Many invest above the minimum, with an average investment of approximately $35,000 – $40,000.

How long is the typical investment horizon objective?

We target 1 – 3 years and some of offerings have a five-year investment objective.  Value-add and opportunistic strategies are well-suited for a 1 to 3-year investment horizon, with a recapitalization or sale of the stabilized asset to exit the investment.

 Disclosure: These are illiquid securities and investors may be required to hold the investment longer than the objective, or even indefinitely.

How can I review details on Eastview Capital's offerings?

Create an Eastview Capital account and you will immediately be able to review and invest in all available offerings. We encourage investors to arrange a call to learn about our platform and to quickly and effectively discuss the nuances of our offerings.

Once I have an account, what is the online experience like?

The website is a secure interface designed to facilitate these services for investors:

  • review offerings: images, summaries, maps, market data, owner background, drone video, etc
  • provide easy access to due diligence files (financials, appraisals, market reports, etc)
  • execute investments: submit funds, complete investor profile, sign documents
  • manage & review open investments: monitor distributions, review updates, and access relevant documents including tax forms and subscription documents

What does the investment process consist of?

When logged-in, use the “Invest” button to be prompted through the following steps:

  1. investment amount
  2. bank information – funds can be submitted via ACH (up to $100,000) or wire (any amount)
  3. select Individual (using SSN) or Entity (EIN)
  4. Complete a suitability questionnaire (roughly 10 questions ranking risk tolerance, investment experience, and investment goals)
  5. Electronic Signature of Investor Package (Subscription Agreement & Operating Agreement)
  6. Accreditation verification – confirm you meet accreditation requirements 

Do I have to be an accredited investor to participate in Eastview Capital offerings?

Yes. Each investor must be accredited and provide supporting documentation.

What is an Accredited Investor?

Accreditation requires meeting at least one of these criteria:

  Individual:      a) annual income greater than $200,000, or
                           b) net worth greater than $1,000,000 (excluding primary residence).

  Entity:             a) total assets greater than $5,000,000, or 
                           b) a registered bank, insurance company, investment company or
                           c) 100% ownership by accredited individuals, or
                           d) a trust with assets of $5 million+ not formed only to acquire the securities offered, and whose purchases are directed by a person capable of evaluating the merits and risks of the prospective investment.

For a comprehensive definition of an accredited investor, see: SEC Accredited Investor Definition

Can I use an entity to make an Investment?

Yes. Investments can be made as individual or an entity in the same Eastview Capital account. Entity formation & organizational documents must also be submitted to confirm the individual making the investment is authorized to invest on behalf of the entity. We can rely on the accreditation status of the individual using an entity to invest, not the entity.

What is “third party confirmation” of accreditation?

A document from an independent third party that an Investor meets the accreditation requirements.

Most frequently, investors submit account statements that indicate current assets of $1 million or greater. Some additional options for third party verification include:
    Tax documents from prior two years confirming annul income (W-2, K-1, etc)
    Letter from licensed CPA, attorney, broker-dealer, or registered investment advisor confirming accredited status
    A Certificate granted by third party, e.g. www.accredited.am or www.investready.com

Can I "self-certify" that I am an accredited investor?

No. All of Eastview Capital’s offerings require that investors provide 3rd party verification.

We acknowledge that other offering types permit self-certification, with an “existing relationship” as a prerequisite. To eliminate any uncertainty, Eastview Capital has elected to exclusively issue offerings that require each investor to verify their accredited status.

Advanced Investor Questions

What is "suitability" & How does Eastview Capital assess It?

FINRA’s suitability assessment incorporates an investor’s age, investment portfolio, financial situation (income & net worth), investment experience, time horizon, and risk tolerance. We rely on a suitability questionnaire & Investor Profile (both part of your Eastview Capital Account) to gather & asses these data.

The suitability form allows an investor to rank their risk appetite & investment experience as well as estimate their current portfolio allocation (real estate, illiquid & private securities). Your Eastview Capital Profile includes self-reported annual income, net worth, and employment information. Note: phone calls with registered representatives at Eastview Capital may also be used as part of a suitability assessment.

Our goal is to make a reasonable effort to asses if an investor is capable of evaluating the merits & risks of each investment offering. Eastview Capital reserves the right, and has an obligation, to refuse any and all investors that do not meet suitability or accreditation standards.

Why go through the Accreditation & Suitability process?

Issuers of Reg D offerings are required by FINRA to make “reasonable efforts” to confirm that investments are suitable for investors. The suitability assessment is a tool to protect investors from making investments that are not suitable based on their age, risk tolerance, investing experience, income or net worth (among other factors).

What is an Issuer?<br />

An Issuer is an entity that sells securities. Eastview Capital creates a new Single Purpose Entity (“SPE”) to be the Issuer of each offering. The stated purpose of each entity is to issue securities and make the proposed investment. Each entity is managed by Eastview Capital (or an Eastview affiliate designated as Manager). Investors have an ownership interest in these single purpose Issuer entities.

How does Eastview Capital select offerings to put onto the platform?

Our primary underwriting process incorporates a 10-point scoring system based on the following 5 key factors:

  1. Location metro area, neighborhood, market fundamentals
  2. Sponsor background experience, equity contributions, competitive advantages
  3. Property conservative underwriting & valuation assumptions, asset quality
  4. Invest Terms investment time, yield or interest rate, downside protection
  5. Marketability sufficient diligence materials, images, drone, compelling business plan

What is Regulation D? What is an exempt transaction?

Regulation D (Reg D) is a Securities & Exchange Commission (SEC) regulation governing exempt securities & offerings. Reg D offerings are “exempt” from the comprehensive reporting requirements of traditional public offerings. Therefore, Reg D offerings are a faster & more cost-effective avenue to access accredited investor capital than IPOs. SEC’s antifraud, civil liability, and other securities laws still apply to Reg D securities.

While Reg D offerings are more efficient for the issuer, there are restrictions. Specifically, they can’t be resold and are generally illiquid.

There are a few types of Reg D offerings:
   Rule 504: permits up to $5 million of securities in any 12-month period
   Rule 506:  permits an unlimited amount of securities offerings
        506(b): marketing restricted to pre-existing relationships, self-accreditation permitted
        506(c): general solicitation permitted, 3rd Party accreditation verification required

 Eastview Capital offerings are exempt under Reg D, Rule 506(c).

How does the funding process typically progress?

  • Pledge – an initial stage, collecting non-binding indications of interest. This step minimizes investments idle time in escrow – we intend for your investment to begin accruing interest promptly. As a general benchmark, once pledges exceed 50% of the target raise amount, the offering converts to “invest.”
  • Invest – investors execute the required investment documents and submit funds. Certain offerings may skip the pledge step.
  • Close – Issuer funds the loan/investment to Borrower / Sponsor
  • Asset Management – cash distributions (when applicable) and property updates sent to investors.
  • Return of Capital – successful exit includes repayment of principal and any accrued returns owed to investors.

How & when do Investors submit funds?

Investors submit funds as part of the secure online investment process. Investors can opt to fund via ACH or Wire. For ACH investments, funds are drawn once your investment process is complete, including electronic signature of the offering documents). 

Where does the investment go?

Investments are initially held in an escrow account where North Capital is the escrow agent.

What happens if the investment offering doesn't achieve 100% funding?

Typically, there will be an investment with a partial funding. Most of our offerings are not contingent on reaching 100% of the target funding amount, and Sponsors can accept a partial investment and fund any balance themselves. Some offerings may have an initial closing with a follow-on closing. Specific closing/interest accrual dates apply.

 In the event the Sponsor or borrower elects not to accept a reduced funding amount, all investor funds are returned and there are no fees charged.

Does Eastview Capital charge fees?

Yes. Eastview’s origination fee to owners is typically 2% – 3% of the amount raised for equity and 1% – 2% for debt, payable upon funding. There are no up-front fees to investors to make an investment, the target yield represented to Investors is always after any and all fees, which are disclosed.

Eastview Capital may also charge a servicing fee and an exit/success fee; each of these is a spread between what the owners pay and the investors receive. Servicing / Asset Management fees range from 0.25% – 1.0% annually, and exit/success fees range from 0 – 2% (paid upon successful return of capital and subordinate to any principal and accrued interest to investors.

Who uses "crowdfunded" capital?

A growing universe of real estate owners are realizing that accessing accredited investor capital via private placement is a compelling source of capital. Owners that have successful raises are frequently in expansion or growth phase, have outgrown existing sources of capital, and are comfortable with total transparency. 

What kind of Background check do you run on Borrowers / Sponsors?

We run a comprehensive background and credit check on all individuals with
   1) 20% or greater ownership interest in Sponsor / Borrower Entity and
   2) Any individual represented as a control person, managing member, or executive

The SEC specifically requires a “Bad Actor” check, which is run by a 3rd Party to identify any disqualifying events. Individuals with any disqualifying events* are prohibited from participating in a securities offering, and therefore rejected by Eastview Capital.

 *Disqualifying events include criminal convictions, court injunctions and restraining orders, SEC disciplinary or cease-and-desist orders, suspension or expulsion from membership in a self-regulatory organization (SRO) such as FINRA, and US Postal Service false representation orders.

What rights do investors have in offerings?

Individual investors typically do not have any voting rights. Eastview Capital (or a direct affiliate) manages the entities and may retain certain “major decision” rights with a Sponsor.

Individual investors may have certain voting rights within the Eastview Capital affiliate entity, but typically will not have any voting rights on the property.

How & when do Investors receive distribution payments?

Eastview Capital offerings generally target quarterly distributions. Distributions are made via ACH to an account designated in your Eastview Capital profile.

How often are Project updates?

Project updates are typically made in conjunction with quarterly distributions. Updates may occur for major milestones for value-add or opportunistic investments, including pictures. Updates for stabilized, cash-flowing assets may simply contain standardized performance metrics such as occupancy and performance relative to the local market.

Broker Dealer / Compliance Questions

Is Eastview Capital a broker-dealer or investment advisor?

No. All securities are offered through our partner North Capital, a registered broker-dealer and member of FINRA and SIPC. A broker dealer is a company that engages in the business of trading or offering securities. Eastview Capital does not provide investment advice and makes no recommendations about any particular investment.

What specifically does North Capital do for these offerings?

North Capital is involved from start to finish, providing comprehensive compliance with SEC & FINRA requirements. Some of the specific contributions include:

  • Advertising Approval – review & approval of e-mail & advertising for compliance with FINRA Rule 2210 – “Communications with the Public”
  • Underwriting Approval – confirming that Offering Materials use acceptable language and representations are verified by due diligence documents
  • Investor Approval – confirm suitability and accreditation for each investor
  • Entity Investments – reviewing Organizational document to confirm individual control
  • Background Checks – Know Your Customer (“KYC”) & Anti-Money Laundering (“AML”) checks for every investment
  • Escrow Agent – as agent, North Capital approves final investment distributions

Does Eastview Capital offer Funding Commitments to Sponsors / Borrowers?

No. We do not currently pre-fund our offerings. Eastview Capital’s loans or equity investments are contingent on investor funding. Part of Eastview Capital’s mission is to present offerings with terms that are compelling to our investors. In other words, we expect the offerings that are selected to fund.

What are the potential risks to investors?

Each offering includes a comprehensive set of risks, some are specific to the offering type, asset class, or development plan. No guarantees are made with respect to return, and investors should be prepared for the potential of a loss of the entire amount of the principal investment.

What is a private placement "Issuer"?

An issuer is a legal entity that sells securities. Eastview Capital creates a new Single Purpose Entity (“SPE”) that is the Issuer for each offering. Each entity is managed by Eastview Capital (or an affiliate designated as Manager). Investors have an ownership interest in these Single Purpose, Issuer entities.

Does Eastview Use Single Purpose Entities for each offering?

Yes. We create an entity for each offering, typically a Delaware LLC. This is designed for investor protection – the risks to investors are restricted to the real estate offering by creating a single purpose, bankruptcy-remote entity. Management of that entity can be transferred, and your investment is not contingent of the overall performance of Eastview Capital.

Who Manages/controls the entities created for each offering?

Eastview Capital is the manager for each entity. Management of each entity can be transferred to another entity, platform, or manager.

Is the offering information presented on your platform confidential?

Yes. We provided access to every possible due diligence document: market reports, appraisals, third party reports, historical and proforma financial statements, as well as ownership plans & structure. Providing access to these documents is consistent with our commitment to transparency, they support the offering materials, and in certain instances may be most relevant for advanced Commercial Real Estate professionals. These documents are confidential, and Eastview Capital’s account creation process requires that each investor acknowledge that all of the offering materials and due diligence information is confidential.

Can I resell an investment in Eastview Capital offerings?

No. Regulation D offerings are restricted securities, which are highly illiquid due to restrictions and lack of a secondary market. Our private placement securities are meant exclusively for investment purposes, and investors should expect to hold the securities until a capital event such as property sale or recapitalization.

Specifically, The SEC’s Regulation D is generally interpreted as providing “transactional” exemptions, which means the initial transaction is exempt from Registration, not the Security. An investor therefore must establish an independent basis of exemption to resell securities.

Can non-US citizens invest in offerings on Eastview Capital?

Non-US citizens can use a US entity to make investments.

Are additional capital calls expected as part of an investment?

No. Eastview Capital’s operating agreements do not require additional capital. In rare instances, additional capital may be requested but there is no obligation to participate.

Raising Capital – Sponsors & Borrowers

How can we raise Capital on your platform?

Simply submit an executive summary to raise@eastviewcap.com and we’ll be in touch.

It is worth noting that our selection process takes into consideration that your project will be presented to a large universe of investors. You may have a great deal, but not all are appropriate for our platform.

What parties are involved?

  • Owner:               the borrower or Sponsor (or Lender, if debt syndication)
  • Issuer:                an Eastview-created single-purpose entity issuing securities via North Capital
  • North Capital:   broker-dealer
  • Investors:          the “Crowd”    

Is the Crowd Sophisticated?

Absolutely. The “Wisdom of the Crowd” is applicable (and impressive to witness). The aggregate knowledge and experience of the crowd is immense, and investors enjoy participating with interesting and qualified owners. Many investors have participated in dozens of private placement offerings and have developed advanced investment criteria.

 Sponsors & Borrowers should consider the Crowd the largest, most informed investment or loan committee ever presented to. Errors are always promptly noted. Assume some are long-term residents of your local market that intimately know the history and trends.

What diligence information do we need to provide?

For an initial review, owners should focus on these exhibits:

  1. Sources & Uses
  2. Proforma NOI with assumptions
  3. Pictures / Renderings, Map
  4. Valuation Summary (with comps)
  5. Sponsor/Borrower Background & Experience

What are the most important characteristics for a successful raise?

  1. Sponsor Equity – a material amount of sponsor equity is a must.
  2. Compelling Story – conservative forecast assumptions that are readily supported by comps & market trends
  3. Visual Presentation – quality images and/or renderings, drone footage
  4. Proper Structure – fair investment terms, including target yield & fees, downside protection when available
  5. Sponsor experience – exploit competitive advantages (previous experience), a capital stack that minimizes overall cost of capital.

What is the typical raise amount?

We target $500,000 – $2,500,000 Capital raises (as of 3Q 2019). 

How long does a raise take?

About 2 – 4 weeks is an approximate benchmark, subject to size & offering terms. We won’t put an offering on the platform that we don’t expect investors to be interested in. Some may fund (much) faster, some may take longer.

Should we have a conference call?

Yes! We can provide immediate, real-time feedback on your capital raise request. We encourage owners to submit a request and arrange a call. If a capital request isn’t a good fit (e.g. long investment horizon, too large, too conservative, or too risky) but you are a qualified sponsor interested in accessing a new source of capital on our platform, a conversation may provide worthwhile insight for future requests. Addressing an actual transaction is frequently the most effective way to learn what works and what doesn’t.

How can owners help during the raise?

Webinar! We’ll host a live webinar during the capital raise with investors invite to submit live questions. Your participation helps Investors learn about where you’ve been and where you are going.

Any examples of offerings that aren't a good fit for Eastview Capital?

Any projects with highly sensitive information or an aspect that prevents total transparency with investors are a bad fit. All information presented in offering materials is confidential to the public, but there will be hundreds of investors reviewing the offering materials.

Who's in the Crowd?

We have more than 25,000 investors that will receive notification of your offering. Our “crowd” consists of high net worth investors (there are more than 10 million accredited households in the US), family offices, and investment funds. The group of high net worth investors is diverse: active & retired real estate executives, doctors, developers seeking geographic diversification, entrepreneurs, accountants, and small business owners.

Who creates the offering materials?

It’s a team effort, but Eastview Capital is ultimately responsible for creating the offering materials (with owner review and comments). We are familiar with language requirements and restrictions with respect to SEC & FINRA communication requirements and will create materials consistent with our offering templates that investors are familiar reviewing.

Where does the Crowd come-from?

Our core foundation of investors comes from existing relationships with our management team, personal referrals, online reviews, speaking engagements, national press coverage, industry conferences, and strategic online advertising.

The emergence of online funding platforms and accelerating growth since 2012 is a function of both real estate owners learning about this universe of capital in conjunction with investors becoming familiar with the risks & opportunities.

Will my project and background information be kept confidential?

Yes. Our account creation process requires that each investor confirm the materials on our website are confidential. In certain instances, if helpful, we’ll provide notice that more sensitive material is available by request, as an extra layer of security.

What type of Investment Structure do you recommend?

1) Simplicity:  we encourage simple structures when possible. Advanced structures with IRR hurdles and lookbacks are fine, but a simple structure (i.e. current pay with accrual) makes the process easier.

2) Downside Protection: we’ll structure a maximum yield to Eastview’s investors in exchange for a preferred or secured position (via preferred equity or subordinate debt).

Who is responsible for SEC & FINRA compliance?

Eastview Capital is entirely responsible for SEC & FINRA compliance. Our securities are offered through North Capital. Some employees of Eastview Capital are Registered Representatives of North Capital.

Who Handles questions from Investors and Investor Documentation?

Eastview Capital will handle most investor questions, especially those related to our platform. If there is any uncertainty, we pass along questions for your response.

How is the actual investment made?

Eastview Capital creates an entity to make the investment or loan – this entity will be the sole investor or lender to your project. The entity represents the aggregate ownership interest of Eastview Capital’s investors and is managed by Eastview Capital (or a manager-specific affiliate).

For Equity Investments, does Eastview Capital require control provisions?

No, but we typically require approval rights for certain major decisions and require control/transfer rights in event of any “bad-acts” by the Sponsor.

Will you participate in larger Debt or Equity Syndications?

Yes. Eastview Capital will participate with bridge lenders or sponsors syndicating larger investment positions, generally $3 million or larger. Eastview’s target investment parameters remain unchanged, and lenders with servicing teams and standardized loan documents are preferred. Note – Eastview Capital won’t make a simultaneous Reg D offering with another issuer.

Are there any up-front Fees to Owners?

Yes. Eastview typically charges an upfront, non-refundable diligence fee, which covers our costs to create offering materials and get a listing approved. This financially aligns interests until closing and prevents losses if an owner elects to not make an offering to the crowd after costs have been incurred by Eastview Capital.

What about the Operating Agreement (Equity) or Loan Docs?

We can provide templates, or work from your template.

What are an owner’s ongoing obligations during the investment period?

Quarterly asset management updates with pictures, timely cash distributions (if not from escrow), and tax documents.  

Can you raise capital for projects that are already in our portfolio?

Yes. Our capital raises on not exclusive to acquisitions. In fact, we are comfortable with raises that have flexible timing and raise amounts. We can do incremental closings for extended raises.

What about Interest Reserves to cover distributions to Investors?

Yes. For projects that don’t generate sufficient cash flow, we typically require that sufficient cash to meet minimum yield targets are held in escrow at closing.

Eastview Capital – Entity Level Questions

Where did the Eastview name come from?

Eastview is our founder’s childhood home street. 

Can I be an Investor in your company?

Maybe. We are extremely selective, but expect may be open to new investors at certain high-growth stages. If interested, you can contact our CEO at ddrew@eastviewcap.com

What happens if a Borrower or Sponsor Defaults?

Eastview Capital, as Manager of the issuer, will work to identify an expedient resolution to maximize investment recovery that considers issuer rights, market conditions, estimated costs of resolution, and timing of recovery. The recovery strategy will be determined by Eastview Capital, with ongoing status updates and correspondence with Investors.

Debt Default: Debt investment positions typically have the benefit of a recorded lien on the collateral. The lien provides the right to foreclose, and in certain circumstances that right may be best leveraged as negotiation to achieve a deed-in-lieu (transfer of ownership). In recovery efforts that require legal costs, recovery of those costs may be repaid prior to investor interest and/or principal.

Personal Recourse obligations are nice to have, and effective negotiating tools in the event of default, but recovery via personal assets is historical a long-term and low-yield endeavor. 

Equity: A broad range of potential resolutions may be pursued, but generally Eastview Capital will exercise any rights to seize control of a property. The rights granted to Eastview Capital are negotiated in the Operating Agreement at the time of investment and may represent a critical phase in the investment process. In the event another entity holds a financial interest in the capital stack (i.e. Senior Lender), Eastview Capital may appoint or transfer control to a qualified, well-capitalized owner to protect the value of the collateral and the equity position.

What happens if Eastview Capital goes out of business?

Offerings are specifically designed to protect investors from platform risk. Each offering features a separate, bankruptcy-remote, single-purpose entity that is legally the “Issuer.” That entity will continue to exist independently, regardless of the status of Eastview Capital, and Investors would continue to retain their ownership interest in that Issuer entity.

In the event of Eastview’s failure, Manager responsibilities (& the corresponding rights to Fees) would be transferred to a qualified manager.

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© 2021 Eastview Capital, Inc. All rights reserved.

NOTICE: This site is operated by Eastview Capital, Inc (“Eastview”).

Eastview Capital is not a registered broker-dealer. Eastview Capital does not give investment advice, endorsement, analysis or recommendations with respect to any securities. All securities on this site are being offered by, and all information included in this communication is the responsibility of, the applicable issuer of such securities. Eastview Capital has not taken steps to verify the adequacy, accuracy, or completeness of such information. Neither Eastview Capital nor any of its officers, directors, agents and employees makes any warranty, express or implied, of any kind related to the adequacy, accuracy or completeness of any such information on this site or the use of such information on this site. This website is only suitable, intended and available for residents of the US who are familiar with and willing to accept the risks associated with private investments and able to bear the loss of their entire investment.

The offerings on this site are conducted by North Capital Private Securities Corporation, Member FINRA/SIPC located at 623 East Ft. Union Blvd., Suite 101, Salt Lake City, UT 84047. NCPS does not make investment recommendations and no communication should be construed as a recommendation for any security offered. You can review the brokercheck for NCPS here and here is a link to North Capital’s Form CRS.

By accessing this site and any pages thereof, you agree to be bound by the Privacy Policy and Terms of Use.

All prospective investors must certify that they meet the suitability standards and must acknowledge that they have received and read all investment materials. The securities offerings made by Eastview Capital are speculative. There is a potential for loss of part or ALL of investment capital. Neither the SEC nor any federal or state securities commission or regulatory authority has recommended or approved any investment or reviewed the accuracy or completeness of any of the information or materials in this communication. Prior results are not indicative of future performance and any “forward looking statements” or returns shown on the website are illustrative examples only and actual results may vary materially. All investors must make their own determination of whether or not to make any investment, based on their own independent evaluation of the investment and their risk tolerance.