One in twelve private funds changes its administrator each year

Where the number comes from

Every investment adviser files a Form ADV, and Schedule D of that form asks, for each private fund the adviser manages, who its administrator, custodian, auditor, prime broker and marketer are. The SEC publishes the history in bulk through 31 December 2024. We took the exempt reporting advisers, the slice that holds most private equity and venture funds, and found 46,143 private funds with an administrator on file. 34,783 of them appear in two or more years, which gives 104,034 year-over-year comparisons.

The rate

In 8.6% of those comparisons the administrator named in one year is not the administrator named in the next. About one fund in twelve, every year. For a firm that sells fund administration, that is the size of the open market, and we have not found it published anywhere.

Almost half of the switches were not switches

Read naively, the diff lies. 43% of the changes were one provider acquiring another and the acquired funds re-filing under the new name. The largest single case moved 2,038 funds from one administrator to another in 2022, and there were thirteen more clusters like it. Publishing the raw list would print thousands of wins that never happened and tell a vendor it had lost clients it still has.

The filter is cheap and automatic: fifteen or more funds moving between the same two providers in the same year is an acquisition, not a market. After removing those clusters, 5,121 competitive changes remain across the history, about 426 a year in this slice alone. Rebrands need the same care. One administrator appears under three successive names, and one filer typed its auditor as "ERNEST & YOUNG". We key on the provider's legal entity identifier where one is filed and fall back to a normalised name, never the raw string.

What we left out

Custodians. On the same data, 45% of funds "change" custodian every year, because funds add and drop foreign sub-custodians as their holdings move. That is not a mandate changing hands, and it is excluded outright rather than softened.

Registered funds file a different form, N-CEN, which asks the question outright: was each service provider hired or terminated this year? In a sample of 150 filings, 32% reported at least one change, and across 220 year-over-year pairs, 7% changed administrator. The two forms agree on the order of magnitude. They also show where the market is closed: the five largest auditors hold 81% of registered funds, while the five largest administrators hold 30%. Where the market is concentrated the read is boring, because the vendor already knows.

The limits that travel with the number

The Form ADV history stops at the end of 2024, so it gives a base rate and a history, never this quarter. N-CEN is current but covers registered funds and business development companies, not private equity. A one-sided row, where a provider leaves and nobody arrives, is usually a fund series being added or dropped, not a mandate. And no filing anywhere states when a contract expires, so "out of contract" is not a fact any of this can support. It survives only as an inference: held longer than the market average for that role.

What we do with this

For a vendor to funds, this is the base rate an outbound programme is built on: hundreds of open administrator mandates a year in one slice of the market, each with a filing behind it and a date on it. The Desk reads these filings, and an engagement gets the named changes with their documents. What we do for the firms that sell to capital sets out the rest.