First-Time Private Fund Managers (U.S. advisers, per year)

## What this measures

Every adviser that manages a private fund (a pooled vehicle relying on the 3(c)(1) or 3(c)(7) exclusions of the Investment Company Act) describes each fund in Form ADV Schedule D, Section 7.B.(1): its type (hedge, private equity, venture capital, real estate, securitized asset, liquidity or other), gross asset value, number of beneficial owners, auditing firms and, if it filed one, its Form D file number. The SEC releases every Form ADV filing in its FOIA Form ADV data through 2024; filings from 2025 are in the monthly Form ADV filing data files on the SEC's adviser disclosure site (adviserinfo.sec.gov, run by FINRA). Palanor reads every Schedule D from November 2011 to September 2026 and, for each fiscal year, takes each adviser's annual updating amendment for that year (the amendment due within 90 days of the fiscal year end). Schedule D also asks for each fund's Form D file number. Palanor matches those numbers to SEC Form D filings (the notice a fund files when it starts selling interests) and dates each linked fund by its first Form D filing. An adviser counts as a first-time manager in the year its earliest linked fund was first filed on Form D, provided the adviser first appeared on the SEC's monthly adviser lists no earlier than the year before (an older adviser whose earlier funds predate the Form D data is not counted). By year, 2012 to 2025.

## Why it matters

New managers are where new strategies, and new competition for investors' money, come from. Their number is a read on how open the private fund market is to newcomers.

## How to read it

Higher means more new firms raised a first fund. It follows the fundraising climate: easy money brings in more first-time managers, and a tight market keeps them out.

## What it does not say

The last complete fiscal year is 2025: annual amendments are due within 90 days of the fiscal year end, so fiscal 2026 is added once they are filed in 2027. Advisers that registered or withdrew mid-year without an annual amendment for the year are not in that year. A fund advised by two advisers can appear twice. Figures are as the advisers filed them: gross asset values of $1 trillion or more, or of $10 billion or more that are over 1.5 times the adviser's own reported assets or over 20 times the fund's value in its other years, are treated as typing errors and left out. Only funds whose adviser reported a Form D file number, and whose number matches a Form D in the SEC's data sets (2009 onward), are counted; funds launched after an adviser's last Schedule D in the data (through September 2026) are not linked yet, so the series ends in 2025.

## Source

Palanor calculation from the SEC FOIA Form ADV data (www.sec.gov/foia-services/frequently-requested-documents/form-adv-data), Form ADV Part 1A and Schedule D for registered and exempt reporting advisers, filings 2011-11-05 to 2024-12-31 (U.S. government work in the public domain), and the monthly Form ADV filing data files on adviserinfo.sec.gov for filings 2025-01-01 to 2026-09-30, retrieved 2026-10-19: BrokerCheck data (FINRA, brokercheck.finra.org), used for investor protection; use is subject to the BrokerCheck Terms of Use (brokercheck.finra.org/terms). Report errors to support@palanor.com. Reloaded by Palanor once a year. Form D: SEC Form D data sets (public domain).