--- title: "Bridgewater’s Form D sales versus ADV assets | Altss Blog" description: "Bridgewater’s 2026 filings connect fund disclosures without reconciling financial scope or conflicting jurisdiction details." canonical: "https://altss.com/blog/adv-form-d-private-fund-identity-bridgewater-example" --- [Altss Research](https://www.linkedin.com/company/altss) 3 min read Updated Nov 14, 2026 Share # Bridgewater’s Form D sales versus ADV assets Bridgewater’s 2026 filings connect fund disclosures without reconciling financial scope or conflicting jurisdiction details. [Back to blog](https://altss.com/blog) Share [LinkedIn](https://www.linkedin.com/sharing/share-offsite/?url=) [X](https://x.com/intent/tweet?url=&text=Bridgewater%E2%80%99s%20Form%20D%20sales%20versus%20ADV%20assets) Copy link Bridgewater’s [August 18, 2026 ADV](https://reports.adviserinfo.sec.gov/reports/ADV/105129/PDF/105129.pdf) links its Pure Alpha Trading Company master section to file 021-170522. That section reports $6,323,550,512 gross assets. The [July 30 notice](https://www.sec.gov/Archives/edgar/data/1536984/0000905148-26-003393.txt) names Bridgewater Pure Alpha Funds Ltd., CIK 1536984, and reports $12,145,413,803 sold, with first sale in 2000. The separate Fund II arrangement references 021-170521. Its [July 30 notice](https://www.sec.gov/Archives/edgar/data/1536983/0000905148-26-003392.txt) names Bridgewater Pure Alpha Fund II, Ltd., CIK 1536983, and reports $27,268,321,522 sold, with first sale in 2005. Another ADV reference, 021-170520, remains unmatched here. Both named Ltd feeders have British Virgin Islands organization answers in ADV, versus Cayman incorporation in the notices. The difference remains unresolved. The reference connects disclosures without reconciling jurisdiction or making issuer sales comparable to the master section’s assets. ## What the sales field measures The SEC’s [Form D interpretation 130.07](https://www.sec.gov/rules-regulations/staff-guidance/corporation-finance-interpretations/securities-act-forms), dated February 2009, requires amounts accumulated since an offering began. An amendment therefore does not reset the sales counter. A [recent filing date](https://altss.com/blog/october-2026-form-d-private-fund-notices-filing-first-sale-parallel-vehicles) can accompany a long operating history; treating the reported total as that quarter’s fundraising would assign earlier activity to the wrong period. There is a second distinction before cash reaches the portfolio. [Item 13’s instructions](https://www.sec.gov/about/forms/formd.pdf) include consideration payable later under binding capital commitments. The reported sales field can therefore exceed money already received without describing an accounting error. It is not, on its own, a bank-balance measure or a statement that the proceeds remain available to invest. The [SEC’s ADV guidance](https://www.sec.gov/about/divisions-offices/division-investment-management/electronic-filing-investment-advisers-iard/frequently-asked-questions-form-adv-iard) permits using balance-sheet gross assets for question 11. Its example includes short-sale proceeds as an asset without subtracting the corresponding liability. Gross assets consequently should not be silently relabelled investor equity. That guidance explains the measurement category; it does not reconstruct this manager’s balance sheet or verify a combined master-feeder calculation. ## A cash bridge the identifiers cannot supply Consider a wholly fictional vehicle with $20 million of binding subscriptions, of which investors have paid $8 million. It has distributed $2 million, earned $3 million of investment gains, and now holds $9 million of assets. Assume no borrowing, other assets, liabilities, fees or subsequent subscriptions. The arithmetic is $8 million received, minus $2 million returned, plus $3 million gained. The $20 million subscription measure and $9 million asset balance coexist without an $11 million investment loss. Now change the fictional history while retaining those two headline figures. All $20 million was paid, investments lost $11 million, and nothing was distributed. Assets again end at $9 million. The same subscription total and asset balance now accompany a materially different outcome. Identifying the vehicle correctly would not distinguish these histories; the missing evidence concerns contributions, distributions and investment results. Before any new call, the first vehicle still has $12 million of unpaid commitments. Collecting them would increase its assets without creating an investment gain; treating that increase as performance would confuse financing with return. Replacing subscriptions with paid-in capital is only a partial repair. In the first history, subtracting $8 million received from the $9 million balance produces $1 million, missing the $2 million already returned. Including that distribution reconciles the stipulated $3 million gain. The second history has no corresponding distribution, so its $11 million loss remains. The missing cash history changes the investment conclusion. Share this article Share ## Related articles [Image: Top 6 Private-Company Deal-Sourcing Databases Used by PE & VC Firms (2026)](https://altss.com/blog/top-6-private-company-deal-sourcing-databases-used-by-pe-and-vc-firms-2025) Private Markets 18 min read ### [Top 6 Private-Company Deal-Sourcing Databases Used by PE & VC Firms (2026)](https://altss.com/blog/top-6-private-company-deal-sourcing-databases-used-by-pe-and-vc-firms-2025) Updated for 2026: the six platforms buy-side teams actually use—PitchBook, S&P Capital IQ Pro, SourceScrub, Grata, CB Insights, and Altss—with ownership ch [Altss Research](https://www.linkedin.com/company/altss) Oct 6, 2025 [Image: A removable report face for Citadel and a separate reveal shield for HBK illustrate restatement versus later disclosure of historical holdings.](https://altss.com/blog/13f-amendments-restatement-new-holdings-citadel-hbk) Private Markets 4 min read ### [13F amendments: replacing a report or adding previously omitted holdings](https://altss.com/blog/13f-amendments-restatement-new-holdings-citadel-hbk) 13F restatements and additions need different dataset operations. Exact Citadel and HBK filings show reporting-period and entry-count boundaries. [Altss Research](https://www.linkedin.com/company/altss) Oct 15, 2026 [Image: A three-date comparison instrument separates June30 holdings, August14 filing and October15 observation,107days after the holdings date.](https://altss.com/blog/13f-october-2026-june-holdings-q3-reporting-deadline) Private Markets 6 min read ### [13F dates in October 2026: June holdings and the Q3 deadline](https://altss.com/blog/13f-october-2026-june-holdings-q3-reporting-deadline) Original Q2 filings and current SEC guidance explain holdings dates, filing dates, the Q3 deadline and what an October 13F observation can establish. [Altss Research](https://www.linkedin.com/company/altss) Oct 15, 2026 ## Canonical URL https://altss.com/blog/adv-form-d-private-fund-identity-bridgewater-example