Sources and methodology

Sources

HedgeFundDB is built on public regulatory filings, as collected and organized in the research data of 9AT, the product behind the site. Guides link directly to the primary sources they rely on.

• Form ADV. Investment advisers use Form ADV to register with the SEC or a state, to amend their registration and to report to the SEC as exempt reporting advisers. Part 1A, including Schedule D, is the source for adviser identity, registration, regulatory assets under management, private funds and the service providers reported for each private fund. The instructions and glossary define its terms. Question numbers on HedgeFundDB follow the paper version SEC 1707 (07-24); the SEC renumbers questions when it amends the form.
• Investment Adviser Public Disclosure (IAPD). IAPD is the SEC's public site for Form ADV filings.
• SEC Investment Adviser Information Reports. The SEC publishes monthly files of SEC-registered advisers and exempt reporting advisers. They contain a subset of Form ADV and do not include advisers registered only with a state.
• Form D. A Form D is a notice of an exempt offering filed by the issuer, such as a private fund. It is not an adviser registration or an SEC approval. Registration categories and dates explains how its dates differ from registration dates.
• Form 13F. Where relevant, HedgeFundDB refers to Form 13F, which institutional investment managers with investment discretion over $100 million or more in Section 13(f) securities file each quarter. The threshold is tested on the last trading day of any month in a calendar year, and each report is due within 45 days after the quarter ends. It reports long positions as of each calendar quarter end. See the SEC's Form 13F FAQ, which sets out SEC staff views, not Commission rules.

Adviser profiles show Form ADV information published through IAPD, as recorded in 9AT's research data. Each profile names that source and gives the date of the latest Form ADV filing recorded for the adviser.

The SEC states that it has not approved Form ADV information and does not guarantee its accuracy. HedgeFundDB shows what was reported; it does not verify filings independently.

Dates, kept separate

Pages on HedgeFundDB carry several different dates. They answer different questions, and one never stands in for another.

A recent data check does not make an old filing current, and a recent editorial review does not update any data. A review that changes nothing, a typo fix or a new version of the site does not change a page's publication or update date. When an adviser's latest recorded filing is old, the profile says so: see Not recently updated profiles.

Identifiers

• Legal name. Profiles show the adviser's legal name, the name reported in Form ADV Item 1.A, as recorded in 9AT's research data. For a sole proprietor, Item 1.A asks for last, first and middle names. The source stores at most 64 characters of a legal name, so a longer name may be shortened; the profile says so where that may have happened, and the adviser's Form ADV shows the full legal name. The name under which an adviser primarily conducts its business, reported in Item 1.B, can differ from its legal name, and 9AT may list the adviser under that business name.
• SEC file number. A number beginning 801- belongs to an SEC-registered investment adviser. One beginning 802- belongs to an adviser reporting to the SEC as an exempt reporting adviser. Where an adviser has no SEC file number, HedgeFundDB does not show a substitute in its place.
• CRD number. Reported in Item 1.E of Form ADV. It is a separate identifier from the SEC file number, and the two are never interchangeable.
• Private fund identification number. Reported for each private fund in Schedule D, Section 7.B.(1), Q1(b). It is generated when the fund is first reported and reused on every later amendment, including by any other adviser that reports the same fund.
• Form D file number. Begins 021-. A private fund's Form ADV section records it in Q22 when the fund relied on Regulation D.

HedgeFundDB never matches entities by display name alone when more than one could fit.

Registration categories and dates

An adviser's registration category decides which filing starts that status and what its dates can show. The rules below come from the Form ADV instructions, the SEC's Form ADV FAQ and its page on how to register or report as an adviser.

Exempt reporting advisers rely on the exemption for advisers solely to venture capital funds or the exemption for advisers solely to private funds with less than $150 million of assets under management in the United States.

Only some of the bases for SEC registration listed in Form ADV Item 2.A depend on regulatory assets under management (RAUM). Under Item 2.A.(1), an adviser may register with the SEC once it has $100 million or more, must apply at $110 million or more, and may remain SEC-registered down to $90 million. Mid-sized advisers, with $25 million to under $100 million, register with the SEC only in specific cases. Other bases, such as a principal office outside the United States (Item 2.A.(4)) or the 120-day rule described below, do not depend on RAUM.

SEC review and effective dates

• An application date is not a registration date. The SEC generally has 45 days to act on an initial application. It either grants registration by order or begins proceedings to decide whether registration should be denied. If the application lacks necessary information, a new 45-day period begins when the adviser resubmits it.
• Effective dates can bunch together. The SEC announced that applications for SEC registration filed on or after November 19, 2025 would not be declared effective before January 2, 2026 unless the filer asked otherwise. That notice covers applications filed in that period, so check the SEC's announcements for the period you are researching before reading anything into a cluster of effective dates.

Why a new registration is not always a new firm

An adviser that appears as newly SEC-registered may be any of these, among other cases:

• A state-registered adviser moving to the SEC. An adviser that qualifies for SEC registration at its annual updating amendment must apply within 90 days after filing that amendment (General Instruction 11).
• An exempt reporting adviser that has outgrown its exemption. An adviser relying on the private fund adviser exemption that reports $150 million or more of private fund assets files its final exempt reporting adviser report and its SEC application in the same filing, generally within 90 days after its annual updating amendment (General Instruction 15).
• A successor to an SEC-registered adviser. A firm that is not SEC-registered and takes over substantially all of an SEC-registered adviser's advisory business files a new application and receives new registration numbers. It reports the succession in Item 4, and Schedule D, Section 4, gives the acquired firm's name, SEC file number and CRD number (Part 1A Instruction 4.a.(1)).
• A newly formed adviser. An adviser that expects to become eligible for SEC registration within 120 days may register with the SEC (Item 2.A.(9)).
• A genuinely new business. This is only one of the possibilities, and the registration data alone does not say which one applies.

To follow a firm through a change of status, compare its CRD number (Item 1.E) as well as its SEC file number, and confirm the history on IAPD.

The reverse movement needs the same care. Form ADV-W withdraws a registration. An adviser files it when it is no longer eligible for SEC registration, when it switches from registration to exempt reporting, or, as a partial withdrawal, to leave only some of the jurisdictions where it is registered. A Form ADV-W does not by itself mean that the firm has closed.

Form D is a different event

For a private fund, the Form D filer is the fund itself, not its adviser.

• A new Form D is due no later than 15 calendar days after the date of first sale, which is the date the first investor is irrevocably contractually committed to invest. A notice can also be filed before any sale has taken place. See filing a Form D notice.
• While the offering continues, an annual amendment is due by the anniversary of the last notice.
• In Item 4, a pooled investment fund can identify itself as a hedge fund, private equity fund, venture capital fund or other investment fund. Item 5 lets a hedge fund give an aggregate net asset value range or decline to disclose it. See the Form D form and instructions.
• The fund's Form D file number (021-), recorded in its Form ADV section, can connect the two filings; see Identifiers.

A Form D date is therefore neither a fund launch date nor evidence that the adviser is newly registered.

Registration dates are not founding or launch dates

An SEC registration, a first exempt report, any other Form ADV filing, a fund's first appearance in an adviser's Section 7.B.(1), a Form D filing and the date a record first appears in a database such as 9AT each have their own date and source, and none of them is a firm's founding date or a fund's launch date. Fund-level answers can lag behind events (Coverage and its limits), and a database's first-seen date reflects when the data was collected, not a regulatory event. A list of recent registrations describes registrations, not new hedge fund launches.

Asset measures

Several different figures can all be described as "assets". HedgeFundDB labels each one and does not substitute one for another.

• Regulatory assets under management (RAUM) is an adviser-level figure reported in Form ADV Item 5.F.(2), in U.S. dollars, as discretionary, non-discretionary and total amounts. It is gross: liabilities are not deducted, all assets of a private fund count and uncalled commitments are included. It is therefore not net assets, net asset value or "money invested" (Part 1A Instruction 5.b of the Form ADV instructions). Exempt reporting advisers that are not also registering with a state do not complete Item 5 and have no RAUM figure. Those relying on the private fund adviser exemption report "private fund assets" in Schedule D, Section 2.B, instead. That is a different figure: label it as private fund assets, never as RAUM.
• Private fund gross asset value is a fund-level figure reported in Schedule D, Section 7.B.(1), Q11, as the fund's current gross asset value. The form does not state a specific as-of date rule for it. A total of these values is not the adviser's RAUM and need not match it: RAUM also covers accounts that are not private funds, a fund reported by another adviser has no Q11 value in this adviser's filing, and master and feeder values overlap when the funds are reported separately.
• Form 13F holdings are long positions in Section 13(f) securities, mainly U.S. exchange-traded stocks, closed-end fund shares and ETF shares, plus certain convertible debt, equity options and warrants, as of a quarter end. Short positions are neither reported nor netted against long positions, and most debt, cash and other assets are left out, so 13F holdings are not a measure of assets under management. Values have been reported to the nearest dollar since January 3, 2023, and to the nearest thousand dollars before that; convert before comparing values from either side of that date. A filing can be a Holdings Report, a Combination Report, in which some holdings are reported by another manager, or a Notice, in which all of them are; a Notice does not mean that the manager holds nothing.

Every figure shown on HedgeFundDB carries its definition, unit, entity scope, source and as-of date. If those cannot be established, the figure is not shown.

How missing information is shown

HedgeFundDB uses distinct states instead of leaving a blank or showing a zero.

"Reported none" is always read against the exact question. A "No" to Q26(a) means the fund uses no administrator other than the adviser's own firm; it does not mean the fund has no administrator.

Some items are left out on purpose. The profile then says why, instead of showing one of the states above.

Why an empty result never means "none"

An empty list or a failed search tells you only that nothing was found in the place you looked. Among other reasons, a fund's providers may be missing because:

• another adviser reports the fund, and this adviser lists it only in Section 7.B.(2), which has no service-provider questions;
• the fund is covered by a master fund's single Section 7.B.(1);
• the fund is a series or class reported as a separate private fund;
• the adviser identified the fund by a code rather than its name, which Form ADV permits to preserve a client's anonymity;
• a non-U.S. adviser left out a fund that had no U.S. connection during its last fiscal year, as the instructions allow;
• the relationship began after the adviser's last annual amendment;
• the information has not been collected or approved for display on HedgeFundDB.

When no provider relationship is recorded for a fund, profiles say "No relationship is recorded in our data for this fund". When relationships are recorded but not yet approved for publication, profiles say they are not shown yet, pending approval. They never say that a fund has no administrator or no auditor. Missing figures are never shown as zero.

Fund-level and adviser-level information

Form ADV reports some information about the adviser and some about each private fund, and HedgeFundDB keeps the two apart.

• Adviser level: legal name, identifiers, registration category and status, and RAUM.
• Fund level: each private fund's type, gross asset value and service providers. Advisers answer the service-provider questions (Q23 to Q28) separately for each private fund; Form ADV service-provider questions explains each one.

A provider reported for one fund is shown with that fund, its role and its source date. HedgeFundDB does not describe a fund's auditor or administrator as the auditor or administrator of the adviser as a whole.

Under an umbrella registration, described in General Instruction 5 of the Form ADV instructions, one filing adviser files a single Form ADV that covers its relying advisers. Except in Items 1, 2, 3 and 10, which describe the filing adviser only, the answers cover the filing adviser and its relying advisers together; that includes regulatory assets under management in Item 5. Relying advisers appear on Schedule R of that filing rather than in a Form ADV of their own. Schedule R gives each relying adviser's legal name and, where it has one, its CRD number, but it has no field for a separate SEC file number. Each relying adviser must be independently eligible for SEC registration, and umbrella registration is not available to exempt reporting advisers. A figure from an umbrella filing and one from a standalone adviser therefore cover different scopes, and any comparison of the two should say so.

Item 7.A of Form ADV asks the adviser to check each type of related person it has, such as another investment adviser, a broker-dealer, a bank or an accountant. Related persons are all of the adviser's advisory affiliates and anyone under common control with it, including foreign affiliates. The term is wider than "subsidiary", so an Item 7.A entry is not a statement of ownership. Relying advisers under an umbrella registration are listed on Schedule R, not in Item 7.A.

Form ADV service-provider questions

Part B of each private fund's Schedule D, Section 7.B.(1), "Service Providers", has six questions, Q23 to Q28. When a fund uses more than one prime broker, custodian, administrator or marketer, the adviser answers the follow-up questions separately for each firm; when it uses more than one auditing firm, Q23(b) to (f) are answered for each. The auditor and the administrator are reported in separate questions, and one never stands in for the other.

The Form ADV instructions and glossary and the SEC's Form ADV FAQ explain how advisers are expected to answer. When the SEC adopted these questions in 2011, it described auditors, prime brokers, custodians, administrators and marketers as "gatekeepers" and said the answers would be public so that investors could compare them with a fund's offering documents, noting that administrators and auditors could use them to detect false claims about who a fund's providers are (adopting release IA-3221). Part B does not ask which law firm or technology provider a fund uses.

Auditor answers (Q23)

• Not every private fund is audited. Q23(a)(1) asks whether the fund's financial statements are subject to an annual audit, and it can be answered "No"; the auditing firm questions, Q23(b) to (h), follow only a "Yes". The SEC's 2023 private fund adviser rules, which included a private fund audit rule, were vacated by the Fifth Circuit on June 5, 2024.
• Registration is not inspection. Q23(e) asks whether the auditing firm is registered with the PCAOB, and Q23(f) whether it is subject to regular PCAOB inspection. They are separate answers.
• Distribution to investors is a separate answer. Only a "Yes" to Q23(g) reports that the audited financial statements for the most recently completed fiscal year are distributed to the fund's investors. In the SEC staff's view, set out in the Form ADV FAQ, an adviser may answer "Yes" before the distribution deadline has passed if it has engaged an auditor and the statements will be distributed as required.
• Opinion status is a reported status. Q23(h) asks whether all audit reports since the last annual updating amendment contain unqualified opinions. It can be answered "Yes", "No" or "Report Not Yet Received", and the last obliges the adviser to amend its Form ADV promptly once the report is available. Neither "No" nor "Report Not Yet Received" is, on its own, evidence of wrongdoing.

Administrator and valuation answers (Q26 and Q27)

• Only administrators other than the adviser's own firm. Q26(a) asks whether the fund uses an administrator other than the adviser's own firm; read a "No" as explained under How missing information is shown. After a "Yes", Q26(b) to (d) give each administrator's name, location and whether it is a related person of the adviser.
• Investor account statements. Q26(e) asks whether the administrator prepares and sends investor account statements to all of the fund's investors ("Yes"), to some ("Some") or to none ("No"). After "Some" or "No", Q26(f) asks who sends statements to the rest of the investors, or "not applicable" if nobody does.
• Valuation is not attributed to a named provider. Q27 gives the percentage of the fund's assets, by value, that were valued during the adviser's last fiscal year by a person that is not a related person of the adviser, "such as an administrator". It counts only assets for which that person carried out the valuation procedure and its valuation was the one used for investor subscriptions, redemptions or distributions and for fee calculations. Q27 does not say who did the valuing, so a percentage there does not show that the administrator did it.
• Wider duties are not reported. Form ADV does not list an administrator's wider duties, so do not infer services beyond what Q26 reports.

Prime broker, custodian and marketer answers (Q24, Q25 and Q28)

• Treat a prime broker as a custodian only where the filing says so. Q24(e) asks whether each prime broker acts as custodian for some or all of the fund's assets, and Q25 lists the fund's custodians, including any of those prime brokers.
• Marketers include placement agents and finders. Q28 covers anyone other than the adviser or its employees who markets the fund, whether as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor.

Coverage and its limits

• Which advisers are listed. The profile index lists advisers with an SEC file number, 801- for SEC-registered investment advisers and 802- for exempt reporting advisers, that are still in the current Form ADV data and have a Form ADV filing recorded in 9AT's research data in the last 18 months. The adviser profiles page also shows a short list selected by the editors. Neither list is a ranking.
• Profiles that are not listed. Historical records, advisers registered only with a state and profiles marked "Not recently updated" can still be opened at their own addresses. Unless the editors select them, they are not listed in the profile index or the sitemap, and search engines are asked not to index them. HedgeFundDB is therefore not a complete directory of every adviser that has filed Form ADV.
• Only as current as the filing. Advisers must file an annual updating amendment within 90 days after the end of their fiscal year, but they need not update private fund and service-provider answers in other amendments. A change may therefore not appear until the next annual updating amendment.
• State-registered advisers are not included in the SEC's monthly adviser files, and HedgeFundDB does not show their state registrations.
• Provider names are reported by each adviser. The same provider can appear under different spellings or entity names in different filings. Where a filing gives other details, such as the provider's location or registration numbers, check them before treating two entries as the same firm.
• Temporary outages. If 9AT's research data cannot be reached, an adviser profile may show a previously retrieved copy with a notice saying when the data was last checked, or a message that the page is temporarily unavailable. The original filing and as-of dates are kept either way.

Not recently updated profiles

SEC-registered advisers and exempt reporting advisers must file an annual updating amendment to Form ADV within 90 days after the end of each fiscal year, so an adviser that is still registered, or still reporting, files at least once a year. When no Form ADV filing has been recorded for an adviser in 9AT's research data for more than 18 months, its profile is marked "Not recently updated" and gives the date of the latest recorded filing. The profile, including the registration status, shows the adviser as recorded with that filing and may no longer be current.

A missing recent filing does not by itself show that an adviser has closed, stopped advising or withdrawn its registration. Check the adviser's current record on IAPD.

These profiles, like historical records, are not listed in the profile index. Coverage and its limits explains which profiles are listed.

Historical information

A profile is marked as a historical record when the adviser is no longer in the current Form ADV data. The page says so at the top, in its page title and description, and in any adviser list that includes it. It describes the adviser as of the date shown; where the date the record was last current is not known, no date is given rather than an estimated one. A historical record does not show a registration status or website, because the values currently recorded for the firm may belong to a newer registration.

Every figure keeps its own as-of and source dates. Figures are never re-dated to look current, and a recent data check does not make an older figure current.

Adviser contact details

HedgeFundDB publishes no personal contact details. It does not list an adviser's owners, officers or employees, or give their email addresses or phone numbers. The one exception is a sole proprietor, whose legal name, shown on its profile as for any adviser (Identifiers), is the owner's own name. Profiles also leave out the adviser's own street address and phone number; they show its broad location and, where available, its official website.

An adviser profile with a matching 9AT record links to that adviser's free summary in 9AT. Business contacts in 9AT are not part of the free summary: access to them is arranged with the 9AT team, starting with a demo, and existing 9AT customers sign in. Availability varies by adviser. 9AT's FAQ says that some contacts lack email addresses and that 9AT provides LinkedIn profile links for many contacts. It defines a contact's added or edited date as the date the contact was added to its database or the contact's details were changed, so the date describes the database record, not a guarantee that the person's role was recently verified. Unless a profile says otherwise, its contact section is a route to 9AT, not a sign that 9AT holds contacts for that adviser. Where a profile states a number of business contacts, it counts the people that 9AT's research data links to that adviser's own record as current, leaving out removed, merged and hidden entries, on the date shown beside it. They are not classified as decision-makers, and the count does not mean each contact was recently verified. The preview under the number shows at most three locked rows, marking only whether a verified email address and a role are recorded; the names, roles and addresses themselves never reach HedgeFundDB's pages.

Examples in guides

Guides use a worked example to show the method. Published guides use verified, sourced examples, each with its source and date. A synthetic example, with fictional names and dates, is labeled synthetic wherever it appears and is never used in a published guide.

Corrections

To request a correction, use the contact page on the 9AT website, 9AT's general contact form, and say that your message is a HedgeFundDB correction request. The About page says what to include. Where information comes from an adviser's filing, the filing remains the source of record, and the adviser changes it by amending its Form ADV. When a correction changes the substance of a guide, or of the About or methodology page, the page then shows the date of that update as "Updated".

Not investment advice

HedgeFundDB pages are for research and information only. They are not investment advice, and nothing on the site is a recommendation to invest with, hire or avoid any adviser, fund or service provider. Figures describe what was reported, as of the dates shown.