Who administers, audits and custodies a private fund? Reading Form ADV Schedule D 7.B.(1)

Ask a fund administrator which funds a competitor serves and they will guess. The answer is public. Every investment adviser registered with the SEC, and every exempt reporting adviser, files Form ADV, and Schedule D of Part 1A carries a section — 7.B.(1), Private Fund Reporting — that names, for each private fund the adviser manages, who audits it, who administers it, who holds custody and who acts as prime broker. It is updated at least annually, more often when something material changes, and it is the only public record of fund-services market share.

What Section 7.B.(1) contains

• Question 1–3: the fund's name, its 805- identification number, the state or country it is organised in, and the general partner, manager, trustee or directors.
• Questions 6–7: whether the fund is a master or a feeder, and the names of the related vehicles.
• Questions 11–16: current gross asset value, minimum investment, approximate number of beneficial owners, and the shares owned by the adviser, by funds of funds and by non-US persons.
• Questions 21–22: whether the fund has relied on Regulation D, and its Form D file number — the link back to the fund launches feed.
• Question 23: the auditing firm, its office, whether it is PCAOB-registered and inspected, and whether the last opinion was unqualified.
• Question 24: each prime broker and whether it also custodies assets.
• Question 25: each custodian, with its SEC number or legal entity identifier.
• Question 26: the administrator, its office, and whether it sends investor statements and for what share of the fund.
• Question 28: any marketer or placement agent used for the fund.

Fund type and the 3(c)(1)/3(c)(7) election are also on the form, as checkboxes. They survive on the IAPD page but not in every machine-readable copy.

Where to read it

The section is on each adviser's public page on IAPD (adviserinfo.sec.gov), under Part 1A → Schedule D → Section 7.B.(1), and in the full ADV PDF that page offers. The SEC's compilation feeds, which many data vendors rely on, carry Item 7.B only as a yes/no — they tell you an adviser has private funds, not who serves them. The SEC's bulk Schedule D tables were published monthly until the end of 2024. For anything current, the adviser's own ADV is the source.

A fund that filed a Form D last week is usually not on its adviser's Schedule D yet; the adviser adds it at its next amendment, often the annual update in the first quarter. What is already there is the adviser's existing funds, and that is the useful part.

How fund-services firms use it

• Displacement or greenfield: when a sponsor files a new fund, the question is whether its earlier funds have an administrator, an auditor and a custodian, and who they are. An adviser whose three existing funds are administered by one firm will, by default, give the fourth to the same firm — unless something changed. An adviser with no outside administrator on any fund is choosing one for the first time.
• Competitor maps: every fund a given administrator or auditor serves, with the adviser behind each, is one query away. The provider pages list them, with the new launches by each provider's clients in the last year.
• Timing: the quarter after a first close is when administrators are appointed and the first audit is engaged; an amendment showing a jump in capital sold marks the moment. The funds closing now list is exactly those amendments.
• Qualification: gross asset value and investor count per fund tell you whether a mandate is worth a call before you make it.

Reading it alongside Form D

Form D names the fund; Form ADV names the manager. Joining them is a name-matching exercise: the sponsor part of the fund's name, the sponsor the lead card inferred, or a general-partner entity listed among the related persons, matched against the adviser's business and legal names with generic words removed. FormDSignal does this on every fund filing and shows the match tier (exact, probable, brand-level) so you can judge it; about three in ten fund filings link to a registered adviser, and the rest are sponsors with no registered adviser, exempt advisers filing under a different name, or names too generic to trust. The methodology has the rules.

Limits

• The data is as filed: an adviser that has not amended its ADV since a provider change still shows the old provider.
• Provider names are free text. The same firm appears under several legal entities and spellings; counts per entity understate a brand.
• Exempt reporting advisers file a shorter ADV, but Section 7.B.(1) is required of them too.
• State-registered advisers do not file Schedule D 7.B.(1).