The Institutional Limited Partners Association released updates to its ILPA Reporting Template and a new ILPA Performance Template. The goal is to enhance standardization, transparency and comparability in reporting across geographies for private funds.
ILPA hosted a webinar discussing the templates and these are my notes.
ILPA is setting a January 1, 2026 date as the opening quarter for using these templates. Surprisingly, half of the people on the call are already working on implementation.
This is the first update on the fee and expense templates since 2016. Do the templates provide a needed level of transparency?
This release is a response to the failure of the Private Fund Rules that the Securities and Exchange Commission enacted, but got overturned in court. The failure of those Rules also gave ILPA more freedom to craft the templates, switching from the top-down SEC regulatory approach, to a bottom-up consensus building approach for adoption.
The focus of the templates is targeted to traditional closed-end funds for private equity funds. The performance template works for a broader swath of closed-end funds, including real estate funds, venture capital funds, and private credit funds.
Some changes and more granularity in the current template. There is more detail on external partnership expenses such as valuations and subscription facility. There is more information on internal chargebacks for internal staff reimbursements by the fund.
For performance reporting, ILPA is proposing two versions. One versions itemizes each capital for its use, called the “Granular Methodology.” The other version does not and just gross them all together, called the “Gross Up Methodology.”
The performance reporting takes into account the Marketing Rule requirement that performance includes net returns. It has IRR and MOIC results calculated with and without the use of a subscription facility.
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