Open work in progress, published as it is done

Public disclosure of private-fund data — a jurisdiction survey

What it is

Private funds — private equity, private credit, infrastructure, real estate — are among the least visible parts of the capital markets. But the public pension plans that invest in them are public bodies, and in many places the law requires them to disclose what they hold.

This survey works out where that is true, and exactly what each place requires. One jurisdiction at a time: every US state, then the United Kingdom, then other countries. Seventy-one in all.

Why it matters

“Is this state open?” is not a usable question. A state can require a plan to publish a fund’s name, its returns and the fees paid, and in the same sentence exempt the partnership agreement that governs it. California does exactly that. So the survey resolves seven kinds of information separately for every jurisdiction — who the fund is, how much was committed, the cash in and out, the returns, the fees and carried interest, who is allowed to invest, and the documents — and records a separate answer for each.

How it is done

Four rules do most of the work.

Primary sources only. A legal conclusion cites the instrument itself — the statute, the regulation, the regulator’s opinion, or the plan’s own published data. Law-firm alerts and news summaries can suggest where to look. They are never the citation behind a finding.

“We didn’t look” and “there is nothing there” are different answers. Every finding is one of four: the law compels disclosure, the law exempts it, we searched properly and found no instrument, or we have not looked yet. Collapsing the last two would make the survey read as more complete than it is.

How the duty arrives is recorded too. California requires plans to publish; Texas instead makes sixteen categories impossible to withhold when asked. Both are guarantees. Only one is a web page.

Nothing is deleted. A jurisdiction that turns out to require nothing is a result, and it stays in the record with its citations so it is not surveyed twice.

Where it has got to

Figures as at 2 September 2026. Updated as the survey advances.

Five jurisdictions resolved. Sixty-six in the queue.

• California — requires publication of fund identity, commitments, cash flows, net returns, fees and carried interest. Exempts the partnership agreements by name. 577 funds published by CalPERS alone.
• Texas — sixteen categories of investment information cannot be withheld, including internal rate of return, remaining value, total fees and cash-on-cash return. Everything else a fund supplied is confidential. The data is guaranteed but not published, so it has to be asked for.
• New York — requires nothing at fund level, and exempts nothing either. The New York City Comptroller publishes a richer fund table than California compels — 185 partnerships, $22.3bn of commitments — entirely voluntarily.
• Florida — publishes 434 funds, and does so voluntarily. Published is not the same as guaranteed: what a comptroller chooses to post, a comptroller can stop posting.
• Georgia — compels four classes of information and yields no usable fund-level data. The statute lets a plan withhold everything about an alternative investment, then carves back six items — of which only a fund’s name and first-investment date are per fund. Returns are published for the asset class as a whole. The survey’s first case of compelled but useless.

Across the five, 1,196 funds have per-fund data published in the open. The pattern so far: what is open is fund identity and performance; what is closed is the documents. Three of the five states put the documents out of reach — California by name, Texas by complement, Florida by category. Five jurisdictions is not yet a pattern, and the survey says so.

How we ask, and what we do not ask for

Where a jurisdiction publishes, we read the published data and ask nobody for anything.

Where the law guarantees information but no one has published it, we make a public-records request. Those requests ask only for items the statute itself names as public; we do not ask for anything a statute exempts, because the answer is already known and the question would only cost someone their time. We say what the data is for, we ask what a request will cost before it is incurred, and we offer to narrow it.

We do not resell public-records responses, and we do not use them to solicit the plan or its managers.

Who

The survey is carried out by Kazuhiko Yasuda at Stargira Advisors Ltd. Correspondence: kyasuda@stargira.com.