Hedge Fund LawIn development
The first fund is the hardest one.
Measured analysis of how private funds actually get formed — read from every Form D filed with the SEC since 2016, not from commentary about them.
The Emerging Manager Index
Every pooled fund filing a Form D, filtered to genuine first-time managers — the ones whose principals have never appeared on an earlier filing. Roughly one a business day out of about 190 filings. Each entry shows its basis and links to the filing it came from.
What the record actually shows
Hedge funds were 51% of new fund formation in 2016 and are 27% now; venture went from 6% to 23%. Findings like these are computed from 505,780 filings, so they can be checked rather than believed.
Reference for people raising a first fund
506(b) against 506(c). 3(c)(1) against 3(c)(7). Blue sky, state by state. What a first fund costs and how long it takes. Written once and kept current, for founders and the advisers around them.
One message when there is something real to look at. Nothing else, and no list.
info@goettelmanlaw.comPublished
Everything on this site is computed from the SEC filing record and links to the filings it came from.
- The Emerging Manager IndexEvery genuine first-time manager filing a Form D, refreshed nightly.
- Most new venture funds are not funds56% of 2025 venture filings are single-deal vehicles. What that does to the numbers.
- Hedge funds didn't shrink. Everything else grew.What 290,471 Form D filings say about a decade of fund formation.
- 506(b) or 506(c)Which exemption a first fund actually uses.
- 3(c)(1) or 3(c)(7)The hundred-investor cap, and what it costs to escape it.
- The Form D deadlineFifteen days from first sale, and what the record shows about compliance.
- When you must register as an adviserThe $150m exemption and the line it draws.
- Blue sky notice filingsWhy Rule 506 preempts the states and Rule 504 does not.
- Accredited investor or qualified purchaserA $1m test and a $5m test, and why the gap decides your structure.
- What a first fund costsWhat is actually measured, what the filings show, and what nobody has data on.
- Management fee and carry normsTwo and twenty is still the median. The tails are the negotiation.
- The compliance calendarFour recurring dates. The record shows most funds miss the cheapest one.
- Bad actor disqualificationOne covered person with the wrong history removes the exemption entirely.
- Side lettersNegotiated once, complied with for a decade. What belongs in the LPA instead.
- Delaware, Cayman, or somewhere elseThree quarters of US private funds pick one place. What the second is for.