No. The investor must be engaged in the enterprise through management or policy formulation, but a limited partner with the rights ordinarily given to limited partners meets that standard. Passive ownership with no rights at all does not.
Engagement is a legal role, not a daily job
The regulation requires the investor to be involved in the new commercial enterprise either through day-to-day management or through policy formulation. USCIS treats a limited partner in a partnership organized under a limited partnership act, holding the rights, powers and duties that such partners ordinarily have, as sufficiently engaged. That is why regional-center investors, who typically hold limited-partner or member interests with voting rights on major decisions, satisfy the requirement without moving to the project's location or working there.
A Lac-Beauport retiree who intends to remain retired can therefore qualify, provided the offering documents grant genuine rights and are not structured to strip the investor of every say. What fails is a structure in which the investor has lent money, receives a fixed return and has no vote. That is a loan, not an investment, and it also fails the at-risk requirement.