What OZ Funds Should Do in 2026 to Prepare for OZ 2.0
With OZ 2.0 set to take full effect on January 1, 2027, the year ahead is shaping up to be a pivotal transition period for Opportunity Zone fund sponsors looking to raise capital. While some QOF managers may be tempted to treat 2026 as a slowdown year, there’s an opportunity to do just the opposite, using this year to build momentum through education, visibility, and strategic positioning ahead of the next wave of capital as the OZ 2.0 era kicks off in 2027.
Angela Hwang of RevGen Consulting joins the show to discuss how Opportunity Zone fund sponsors should be thinking about marketing and investor education in 2026, why the year should not be viewed as a “dead zone,” and how thought leadership, organic content, and trust-building can help funds stand out as OZ 2.0 approaches.
Guest: Angela Hwang
Featured On This Episode
About The Opportunity Zones Podcast
Hosted by OpportunityZones.com founder Jimmy Atkinson, The Opportunity Zones Podcast features guest interviews from fund managers, advisors, policymakers, tax professionals, and other foremost experts in the Opportunity Zones industry.
Episode Summary
In this episode of The Opportunity Zones Podcast, host Jimmy Atkinson is joined on-site at the Novogradac 2025 Opportunity Zones Summit in Las Vegas by Angela Hwang, founder and principal consultant of RevGen Consulting. The discussion centers on how Qualified Opportunity Fund sponsors should be thinking about marketing, education, and positioning during 2026 as OZ 2.0 approaches its January 1, 2027 effective date.
2026 Is Not a “Dead Zone” for Opportunity Zone Funds
Jimmy opens by framing 2026 as a critical transition year rather than a period to go quiet. While OZ 2.0 does not take effect until 2027, he emphasizes that fund managers should not treat 2026 as a year to pause activity. Angela agrees and explains that she has heard many people refer to 2026 as a “dead zone,” but she strongly disagrees with that characterization.
Angela encourages sponsors to continue building momentum throughout 2026 by creating materials that explain why OZ 1.0 investments remain relevant for investors with current capital gains. She notes that OZ investing is still a compelling investment vehicle for investors who experienced gains in 2025 or 2026, and that the first half of the year is an ideal time to focus on that message. Rather than waiting until 2027, she advises sponsors to stay active and visible.
Jimmy adds that many fund managers expect a slowdown in equity raising during parts of 2026, particularly in the second half of the year, with a significant ramp-up anticipated in 2027. However, he stresses that even if fundraising slows, marketing and relationship-building should not. He shares that many sophisticated sponsors are already planning to market their 2027 funds during 2026 so they are well positioned when capital flows resume.
Education and Thought Leadership as a Differentiator
A major theme of the conversation is education. Angela explains that RevGen Consulting works closely with real estate fund managers, particularly Opportunity Zone sponsors, to help them create educational materials for investors. She notes that even institutional investors and family offices often still need basic education about Opportunity Zones.
Angela emphasizes that sponsors should prioritize organic, educational content rather than paid advertising. She cautions against spending heavily on Google ads or paid campaigns and instead recommends investing in thought leadership, educational articles, and other long-term content assets. Building a trusted reputation, she explains, is more valuable than short-term exposure from paid ads.
Jimmy observes that education was a recurring theme throughout the Novogradac summit panels. He notes that there is still a need to educate advisors, investors, developers, and community stakeholders not only about OZ 2.0, but also about how the Opportunity Zone program works today. Investors with gains in 2025 or 2026 cannot defer those gains into 2027 to access OZ 2.0 benefits, meaning they must invest through an OZ 1.0 structure if they want to participate.
Angela adds that there is still a surprising lack of high-quality educational material available about Opportunity Zones. She encourages sponsors to use 2026 to invest in creating valuable content, including videos, white papers, and blog posts, rather than pausing outreach.
Building Trust Through Story, Track Record, and Visibility
The conversation turns to what investors are really looking for when evaluating Opportunity Zone investments. Jimmy breaks education into two categories. The first is general education about the Opportunity Zone program itself, including how it works, its benefits, and how it fits into a diversified portfolio. He notes that OZ investments can offer diversification for investors who are heavily concentrated in traditional stock and bond portfolios.
The second category, he explains, is education about the sponsor’s specific strategy and story. This includes the sponsor’s asset class focus, markets, investment approach, and overall narrative. Angela agrees and expands on this point by emphasizing the importance of educating investors about the sponsor’s team and track record.
Angela shares a conversation she had with an advisor at the summit who works with high-net-worth investors. When asked what her clients care about most, the advisor said it was not returns, but trust. Investors want to invest with people they trust, and brand visibility, reputation, and demonstrated track record all play a major role in building that trust.
Jimmy agrees, noting that while IRRs and projected returns matter, they are often secondary to who the sponsor is and how clearly they can articulate their strategy. Angela adds that marketing and public relations are critical because investors research sponsors online before committing capital.
Where Investors Are Finding Information Today
Jimmy points out that investor discovery has evolved beyond traditional search engines. Investors are not just Googling sponsors anymore; they are also using AI tools like ChatGPT and Grok. He shares that OpportunityZones.com has received OZ Pitch Day registrations through ChatGPT referrals, which he attributes to years of consistently publishing high-quality educational content.
Angela agrees and explains that this reinforces the importance of creating value-driven content that can be discovered through both search engines and AI tools. She also encourages sponsors to think carefully about where potential investors consume information. Many capital gains investors, including crypto investors and tech executives, may not be familiar with Opportunity Zones at all, even though they regularly experience qualifying capital gains.
She suggests that sponsors consider reaching these audiences through the platforms, media outlets, and channels where they already spend time, rather than assuming traditional real estate or finance outlets are sufficient.
Closing Thoughts and Where to Learn More
Jimmy wraps up by thanking Angela for joining him at the Novogradac OZ Summit and for attending the OZ Insiders dinner. He notes that OpportunityZones.com plans to continue hosting OZ Pitch Day events and in-person gatherings throughout 2026 as sponsors prepare for 2027.
Angela shares where listeners can learn more about RevGen Consulting and invites fund managers to reach out for marketing strategy conversations. Jimmy closes the episode by encouraging listeners to subscribe and follow The Opportunity Zones Podcast to stay up to date on future episodes.
Opportunity Zones (2026). What OZ funds should do in 2026 to prepare for OZ 2.0. https://opportunityzones.com/