What Is Regulatory AUM? How SEC Form ADV Measures a Fund Manager's Size
The lists on this site rank fund managers by regulatory assets under management. That is the figure an adviser reports to the SEC on Form ADV, Part 1A, Item 5.F. It is a defined calculation: gross, inclusive of capital investors have promised and not yet paid, and tied to the legal entity that files. The legal entity is often not the name on the door. The instructions are public. Here is what they count, and what that does to the names on these lists.
Nothing below is a view on how any firm has invested. A larger filing is a larger reported total under these rules. It is not a performance record, and the order of a list is not a recommendation.
What the form counts
Item 5.F asks for the securities portfolios for which the adviser provides continuous and regular supervisory or management services. Ongoing discretionary management qualifies. So does a non-discretionary arrangement where the adviser has an ongoing duty to recommend specific securities and, if the client accepts, to arrange the trade. A one-time allocation, a market newsletter, or advice given only when a client calls does not.
An ordinary account has a second test. It counts as a securities portfolio if at least half its value is securities. Cash and cash equivalents may be treated as securities for that test. Family accounts, proprietary accounts, accounts managed for no fee, and accounts of clients outside the United States stay in.
A private fund skips the half-securities test. The instructions say to treat all of the assets of a private fund as a securities portfolio, whatever those assets are. If the adviser continuously manages the fund, the fund's assets come onto Item 5.F.
The adviser counts the portion it manages. Money run by someone else stays out. So does a property or a business the adviser operates for a client as an operator, rather than holding it as an investment. A sub-adviser reports its slice, not the whole fund.
Gross, with uncalled capital included
The valuation rules are the part that separates this number from the one in a pitch book.
The adviser uses current market value, struck within 90 days before the filing, and the same method it uses to report values to clients or to calculate fees. For a private fund, the instructions call for market value or fair value, plus the contractual amount of any uncalled commitment. An uncalled commitment is capital a person is obligated to contribute and that the fund has not called. Promised money counts. It does not have to have arrived.
One sentence then does a lot of work. Do not deduct outstanding indebtedness or other accrued but unpaid liabilities. Item 5.F is gross. Borrowings stay in the total.
A drawdown fund shows why the two numbers diverge. Capital investors have pledged, and not yet wired, is part of regulatory assets. Debt inside the fund is not a subtraction. Set Item 5.F next to a net asset value, or next to capital already invested, and it answers a different question. The ranking prints the form.
SEC rule 204-1, which is 17 CFR 275.204-1, is what forces the form to be refreshed. The form's own general instructions say the same thing in plainer language.
How old the figure can be
The form is not a live feed. A registered adviser files an annual updating amendment within 90 days after its fiscal year ends. That amendment has to refresh the answers in Part 1A, and Item 5 is one of those answers, so the regulatory asset figure is recomputed then. The value inside the filing still has to come from within the 90 days before the filing date.
During the rest of the year the adviser files other amendments when certain items change. Item 5 is on the list of items those interim filings do not have to touch. The instructions say that if you are submitting an other-than-annual amendment, you are not required to update Item 5 even when the response has become inaccurate. The asset number can stand still while the firm calls capital, sells companies, and borrows.
Two names on the same list can be reporting figures pulled months apart. Fiscal years differ. These pages do not print a filing date, because the figures behind them do not include one. The "Updated" line in the header is the month the pages were published. A rank compares filed adviser-level totals, taken as reported.
How the rankings come out
Seven lists each name ten firms. More firms clear the bar than the ten that are named. The seven qualifying counts add up to 1,031. A firm that qualifies for more than one list is counted once for each list in that total. Sixty-five firms have a profile. Those profiles cover 70 listings, because four firms appear on more than one list. Every list is linked from the rankings page. Who is left off, and why a firm on two lists keeps two figures, is on the methodology page.
The largest filings are on the hedge fund list and the private credit list.
Millennium Management leads the hedge fund list at $720.8 billion. Citadel is second at $570.6 billion. Tenth is Taula Capital Management, at $210.9 billion. 271 hedge fund managers qualify for the list. The tenth published name is still larger than the firm at the top of four other lists: HarbourVest Partners at $190.9 billion on secondaries and fund-of-funds, Brookfield at $152.1 billion on real assets and infrastructure, General Atlantic at $125.3 billion on growth equity, and Andreessen Horowitz at $106.5 billion on venture capital.
The buyout list is the one people reach for first, and it does not hold the biggest number. On the private equity list, KKR is first at $381.6 billion. Carlyle is second at $283.8 billion. Blackstone is third at $183.5 billion. 225 buyout firms qualify. Taula, tenth among hedge funds at $210.9 billion, reports a larger Item 5.F figure than Blackstone's buyout filing.
Venture makes the same comparison as a sum. Andreessen Horowitz at $106.5 billion, Sequoia Capital at $82.2 billion, and Tiger Global Management at $78.0 billion are the first three. OrbiMed is tenth at $20.6 billion. Fifty-three venture firms qualify. The ten named venture filings add up to $527.6 billion. That is smaller than Millennium's single filing of $720.8 billion, and smaller than the leading private credit filing as well. The ten growth equity filings add up to $562.8 billion, which still comes in under Citadel's $570.6 billion.
Private credit is the other place the gross, commitment-inclusive measure produces a number this large. Apollo Global Management reports $718.5 billion, just behind Millennium, on the filing for Apollo Capital Management, L.P. Ares Management reports $458.8 billion. Barings reports $392.8 billion. 180 private credit managers qualify. Tenth on that list, Sixth Street, reports $101.6 billion. Apollo's filing is just over seven times Sixth Street's, on the same definition. The gap is a gap in regulatory assets. Those assets include uncalled commitments, and they do not subtract borrowings.
One name, more than one filing
Item 5.F belongs to the adviser that files it. A brand with several advisory entities produces several numbers. On each list the firm appears once, at its largest filing for that list. The lists do not add filings together. A combined total would be a number no single Form ADV reports, and these pages do not publish one.
KKR is the clearest case. The $381.6 billion private equity figure is the filing for Kohlberg Kravis Roberts & Co. L.P. On the private credit list, KKR is fourth at $270.9 billion, and the name on that filing is KKR Credit Advisors (US) LLC. Both numbers are on the KKR profile. They stay separate.
Blackstone is on three lists, from three filings. The buyout number, $183.5 billion, is Blackstone ISG-I Advisors L.L.C. The real assets number is $130.7 billion, filed as Blackstone Real Estate Advisors L.P., fourth on that list. The secondaries number is $80.4 billion, filed as Strategic Partners Fund Solutions Advisors L.P., seventh on that list. There is no single Blackstone assets figure on this site. There are three, each tied to the adviser that reported it.
Blue Owl Capital follows the same pattern. Blue Owl GPSC Advisors LLC reports $94.7 billion and ranks fifth on the secondaries list. Blue Owl Real Estate Capital LLC reports $67.9 billion and ranks tenth on the real assets list. Brookfield is the fourth firm with more than one listing: $152.1 billion on real assets, where it ranks first, and $107.3 billion on private credit, where it ranks ninth.
The legal name and the public name diverge even when a firm has only one listing. Golub Capital's private credit filing is Gc Advisors LLC, at $177.9 billion, sixth on that list. Insight Partners appears on the growth equity list as Insight Venture Partners, at $92.2 billion, third on that list. Open the profile and both names are there: the name the list uses, and the name on the form.
A flagship fund can be a fraction of Item 5.F, because the line rolls up every portfolio that adviser continuously manages, and because uncalled private-fund commitments are included. Banks, brokerages, index managers, and wealth advisers stay off these lists. Deposits, custody, and mutual-fund holdings are a different measurement, and family offices are left off as well.
For each adviser, Form ADV gives a gross total, refreshed on the annual amendment. Where the firm files more than one adviser, you get more than one total. The firm pages keep those totals next to each other, each one pointed at the list it came from. That is the size measure behind every rank on this site.