The investor limit that you’re mentioning is Section 3(c)(1) of the Investment Company Act of 1940, which limits the number of investors that a company can have to less than 100 before it is considered to be an “investment company” and would be subject to strict regulation by the SEC.
Creating multiple Special Purpose Vehicles (SPVs) in order to circumvent the Section 3(c)(1) investor limit, is a strategy sometimes used by companies. However, the SEC may take a close look into the situation to confirm if the SPVs are really separate entities and not just an attempt to circumvent the limit.
If the SEC determines that the SPVs are not truly separate entities, but rather an attempt to avoid regulation, it could consider them to be a single entity for regulatory purposes, and the investors limit would still apply.