Not entirely. The investor must be engaged in the enterprise through policy formulation or day-to-day managerial control. Pooled structures address this through the rights attaching to a partnership or membership interest, so the question is what those rights actually are.
Read what the agreement lets you vote on
Hypothetical example: the couple are handed a subscription package and told to sign. Before doing so, ask for the limited partnership or operating agreement and find the section listing the investor's rights. Typically those include voting on significant matters such as the removal of a general partner, the sale of the enterprise's assets or amendments to the agreement, and rights to receive financial information.
Ask counsel — counsel of your own, not the sponsor's — whether those rights are of the kind ordinarily relied upon to satisfy the engagement requirement. The other elements do not change: qualifying capital at risk in a new commercial enterprise, at least ten full-time jobs for qualifying U.S. workers under the applicable counting method, and a lawful source and traceable path for every dollar.
Verify the current capital amounts against official material.