FAQ·1 min read

Do SPVs Count as Separate Funds in Schedule D?

Yes. Each SPV requires its own Schedule D entry, regardless of size. The same applies to co-investment vehicles, parallel funds, feeder structures, and any other pooled investment vehicle you advise.

This is one of the most common sources of filing complexity for emerging managers. A single fund platform with a main fund, two SPVs, and a co-invest vehicle means four separate Schedule D entries, each with its own fund type, asset values, investor count, and service provider information. If you launch a new SPV mid-year, you add its Schedule D entry in your next filing (either an other-than-annual amendment or your annual amendment, depending on timing).

Keep a running list of every entity you advise and its key data points. Managers who track this throughout the year file their annual amendments quickly. Those who try to reconstruct it from scratch each March face delays and errors that can result in inaccurate public filings.

See Schedule D: Private Fund Reporting.

This content is for informational purposes only and does not constitute legal, tax, or compliance advice. Consult qualified counsel for guidance specific to your situation. Capital Company is not a law firm and does not provide legal advice.

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