Q3 Form D first-sale dates: a six-day median in a defined sample

Seventeen dated pooled-fund notices in a fixed Q3 2026 sample had a median interval of six calendar days between the reported first sale and the official filing date. The range was one to 5,857 days. Six of the 17 first-sale dates preceded July 1, even though every notice was filed during the quarter.

Those results come from 30 selected original Form D notices. Twenty-four reported their industry as Pooled Investment Fund; seven of those 24 said the first sale had yet to occur, leaving 17 numerical observations. Six notices reported other industries and were excluded before calculating intervals. All 30 selected records were obtained, with no replacements.

For a researcher building a fundraising pipeline, the six earlier dates matter. A notice entering the Q3 filing stream can describe an offering whose first investor commitment occurred in a previous quarter or year. The filing date locates the public record; the reported first sale adds a different point in the offering’s history.

A long-lived offering in the Q3 filing stream#

ARGA International Fund, a series of ARGA Funds Trust reported July 1, 2010 as its first-sale date in a notice filed July 14, 2026. The submission identifies itself as an original D, with the amendment flag set to false. The resulting 5,857-day interval is retained in the sample. The notice does not establish why an original filing reports that historical date, so the interval supports neither a new-2026-launch label nor a finding about filing compliance.

The other observation above 90 days was Privcorp Ventures Master Fund LLC—Series 5: April 9 to July 31, or 113 days. Global Fund LLC/PR reported June 1 before its August 28 filing, an 88-day interval. The 17-record sample combines this long tail with a six-day median.

Ten of the dated notices fell within 15 days#

The 17 observed calendar-day intervals divide as follows:

• Same day: zero notices.
• One to 15 days: ten notices.
• 16 to 90 days: five notices.
• More than 90 days: two notices.

At the short end, RE-0418 Fund II, a series of Roll Up Vehicles reported August 10 before its August 11 filing, a one-day interval. Standard Fund Series II reported June 18 before a July 6 filing, producing 18 days across the quarter boundary.

The seven pooled notices reporting yet-to-occur sales include Third Moment Capital Fund and Bessemer Venture Partners Century Fund III. They contribute to the sample’s coverage count but have no numerical interval. Treating them as zero-day observations would change the question being measured.

The SEC’s Form D instructions define the first sale by the first investor becoming irrevocably contractually committed to invest. Depending on the agreement, that can be when a subscription agreement or check is received. These dates therefore do not measure the time taken to collect cash, complete fundraising or reach a final close.

A defined sample, with a limited denominator#

The selection began with a retained Q3 index of 2,801 fund-name candidate rows, reduced to 2,766 unique accessions. A fixed accession-based selection rule was frozen before acquisition and did not use first-sale outcomes. Actual submission headers and XML then determined original-notice status, filed-date membership and issuer-reported industry.

Calendar days equal the official filed date minus the explicit first-sale date. The acceptance timestamp was retained separately. No selected record was replaced because of its industry or date response. This fixed study sample comes from a candidate frame that was not a verified universe or a probability sample of private funds. Related series can also share a manager.

The median describes these 17 records. It is not a market estimate of fundraising speed or a deadline test. For subsequent reported-sales changes, Altss’s paired-amendment analysis addresses a separate comparison: the same offering across notices, rather than first-sale-to-filing intervals.