INDEPENDENT VERDICT
CI-0613 Fund I, a series of NDSPV Investments, LP is a verifiable Delaware venture-capital vehicle, but the Form D provides substantially more information about its platform infrastructure than about the actual investment sitting underneath the fund. The October 6, 2026 filing reports that the entire $119,004 offering had already been sold to 21 investors following an October 1 first sale, with a $1,000 minimum investment, no sales commissions and no finder fees. Fund GP, LLC is identified as General Partner and Belltower Fund Group, Ltd. as agent of the General Partner. What the filing does not disclose is more important for investment analysis: there is no portfolio-company name, no security type at the underlying company level, no acquisition price, no valuation, no ownership percentage and no named individual investment lead. The coded "CI-0613" designation therefore allows investors to verify that the SPV exists while revealing almost nothing publicly about what the SPV was actually formed to purchase.
THE $8,000 ADMINISTRATIVE PAYMENT IS MATERIAL RELATIVE TO THE FUND SIZE
Item 16 creates the clearest economic concern. The Form D estimates that $8,000 of gross proceeds will be used for a one-time fee paid to the fund administrator and/or its affiliates to cover administrative expenses for the life of the fund. Against the fully subscribed $119,004 offering, that represents approximately 6.7% of the entire reported capital base. Unlike a vehicle that is still far below its target, CI-0613 had already sold the full offering when the notice was filed, so the comparison is against actual reported capital rather than an aspirational maximum. The filing does not establish that $8,000 is the complete lifetime expense burden, nor does it disclose whether legal, tax, underlying transaction costs, management fees or carried interest are charged separately under the partnership documents. Investors therefore need to determine the true net amount that reaches the underlying startup, because a 6.7% disclosed administrative allocation creates a meaningful hurdle before considering venture-company failure risk, dilution and illiquidity.
NDSPV HAS A LONG SERIES HISTORY, BUT THAT DOES NOT IDENTIFY WHO SELECTED THIS DEAL
The broader legal wrapper is not new. SEC records show NDSPV Investments, LP being used for numerous separately named series over several years, including AR Fund I, YU Fund I, LI Fund I, TA-0524, TE-0418 and TA-0519 vehicles. Earlier filings repeatedly identify Fund GP and Belltower-related entities in legal or administrative roles. Belltower itself is a real venture-fund administrator with a substantial operating footprint and publicly explains that it originated as AngelList's native fund administrator before becoming an independent entity. AngelList also publicly describes platform-advised funds where Fund GP, LLC can act as legal general partner while a different fund lead or sub-adviser actually makes investment decisions. That history helps explain the infrastructure, but it creates an important diligence limitation: neither Belltower's administrative role nor Fund GP's legal GP status tells an investor who sourced CI-0613, who negotiated the underlying investment or who has discretionary authority over the asset. The CI-0613 Form D does not name that person, and no CI-0613-specific adviser match was identified in the public fund-disclosure material reviewed.
FINAL ASSESSMENT
CI-0613 is therefore better viewed as a platform-administered micro venture vehicle than as a transparently disclosed standalone venture fund. The offering is real, the reported $119,004 is fully subscribed and 21 investors provide a broader LP base than many single-investor SPVs, but the public record leaves the underlying investment almost completely opaque. Investors cannot tell from EDGAR whether CI-0613 purchased preferred stock, common stock, a SAFE, a convertible instrument or an indirect interest through another vehicle. They also cannot determine the startup valuation, liquidation preference, dilution protection, follow-on rights, transfer restrictions or exit assumptions. Before investing, an LP should obtain the exact portfolio-company identity, executed investment documentation, capitalization evidence, purchase price and valuation, identity and regulatory role of the fund lead or adviser, partnership agreement, complete fee and carry schedule, administrator agreement and confirmation of the amount actually deployed after the disclosed $8,000 administrative payment. The Form D confirms a Rule 506(b) and Section 3(c)(1) exempt offering; it does not constitute SEC approval and does not independently validate the underlying investment or its economics.