--- title: "Assets Under Management (AUM) | Altss Glossary" description: "Assets under management (AUM) is the value of assets a manager manages for clients; its measurement depends on purpose, and in private markets it usually…" canonical: "https://altss.com/glossary/assets-under-management" --- Glossary · Performance & benchmarking # Assets Under Management (AUM) Assets under management (AUM) is the value of assets a manager manages for clients; its measurement depends on purpose, and in private markets it usually counts uncalled capital commitments as well as invested value. Publisher: Altss LLCPublished 2025-12-29Content modified 2026-10-02 ALTSS-PERF-053 AUM sounds like one number but is several. Regulators define it one way to decide which rules apply to an adviser. Private-markets firms commonly add the value of their funds' investments to the capital investors have committed but not yet paid in. Fee-earning AUM counts only the assets on which fees are charged. Family-office "AUM" is often an estimate that may mean investable assets, total family wealth or something in between. Two AUM figures are comparable only if their definitions match. ### Formal definition US regulatory assets under management (RAUM) is reported in Form ADV Part 1A, Item 5.F. Under the Form ADV instructions it covers securities portfolios for which the adviser provides continuous and regular supervisory or management services, is calculated without deducting outstanding indebtedness or other accrued but unpaid liabilities, and for private funds includes uncalled capital commitments. ## Formula ### Common private-markets convention ``` AUM = sum of fund NAVs + sum of unfunded (uncalled) commitments ``` `NAV_j` net asset value of fund or account j `U_j` uncalled capital commitments to fund j (dry powder) Market practice, not a standard. Firms differ on whether they include GP commitments, co-investment vehicles, fund-level borrowing, asset-level leverage (real estate firms often quote gross asset value) and committed but not yet closed capital. Regulatory measures use their own rules (see sections). ## Jurisdiction and status (US) Advisers report regulatory assets under management (RAUM) in [Form ADV](https://altss.com/glossary/form-adv). Three features distinguish RAUM from marketing AUM: it is gross (borrowings are not deducted), it includes uncalled commitments to private funds, and it covers only portfolios that receive continuous and regular supervisory or management services. RAUM and the related "private fund assets" measure drive regulatory status. An adviser with its principal office in the US that acts solely as an adviser to qualifying private funds and manages private fund assets of less than $150 million is exempt from registration under Advisers Act section 203(m) and Rule 203(m)-1(a); an adviser with its principal office outside the US is exempt if its only US-person clients are qualifying private funds and all assets it manages at a US place of business are private fund assets totalling less than $150 million (Rule 203(m)-1(b)). Either way it still reports to the Securities and Exchange Commission (SEC) as an exempt reporting adviser. An adviser registered or required to be registered with the SEC that advises private funds and managed at least $150 million of private fund assets at the end of its most recently completed fiscal year must file [Form PF](https://altss.com/glossary/form-pf). The compliance date for the 2024 Form PF amendments has been moved several times and, after the SEC and CFTC extension of 31 August 2026, stands at 1 July 2027. The calculation is set by Part 1A Instruction 5.b of the Form ADV instructions. An account is a securities portfolio if at least 50% of its value is securities (cash and cash equivalents may be counted as securities), and all of a private fund's assets are treated as a securities portfolio. Assets are taken at current market value determined within 90 days before the filing; for a private fund, the market value or fair value of its assets plus the contractual amount of any uncalled commitment. Outstanding indebtedness and accrued but unpaid liabilities are not deducted. RAUM also decides which regulator an adviser registers with. Under Advisers Act section 203A and Rule 203A-1, an adviser may register with the SEC once its RAUM reaches $100 million and must apply at $110 million, and an SEC-registered adviser may stay registered until RAUM falls below $90 million. Smaller advisers generally register with their home state; the bar on SEC registration does not apply to an adviser to a registered investment company (section 203A(a)(1)(B)). ## Jurisdiction and status (EU) Under the [AIFMD](https://altss.com/glossary/aifmd), assets under management determine whether an alternative investment fund manager (AIFM) falls under the full regime or the lighter sub-threshold regime. The thresholds in Article 3(2) are EUR 100 million including assets acquired through leverage, or EUR 500 million for managers of alternative investment funds (AIFs) that are unleveraged and have no redemption rights exercisable for five years after initial investment. The Directive as amended by AIFMD II (Directive (EU) 2024/927) was due for national transposition by 16 April 2026; transposition status varies by Member State. Commission Delegated Regulation (EU) No 231/2013, Article 2, sets the method for the threshold test. The manager identifies every AIF it manages, values each portfolio under the applicable valuation rules including assets acquired through leverage, converts each derivative position into its equivalent position in the underlying assets and takes the absolute value, and aggregates the results. UCITS that it manages are excluded, as are portfolios it manages under delegation for another manager. ## Market practice: total, fee-earning and perpetual AUM Private-markets managers commonly report total AUM as NAV plus uncalled commitments, so a newly closed fund adds its full size before any capital is invested. Fee-earning AUM is the base on which [management fees](https://altss.com/glossary/management-fee) are charged: commitments during the investment period, then invested capital or NAV. Some firms also report perpetual-capital AUM from evergreen vehicles. Each firm defines these terms in its own reports; figures from different firms, or from data providers, are not comparable without the definitions. ## Family office AUM and net worth For a [family office](https://altss.com/glossary/family-office), "AUM" may mean the investable assets the office manages directly, all assets it oversees including external managers, or the family's total wealth. Net worth also includes operating businesses, real estate and trust assets held outside the office. Published family-office figures are often estimates; treat them as approximate unless the office discloses them, record the source and date, and do not equate AUM with net worth or either with likely ticket size. ## Assets under advisement Assets under advisement (AUA) are assets on which a firm gives advice without discretion over the investment decisions: typical of [investment consultants](https://altss.com/glossary/investment-consultant). AUA is not AUM and is not included in RAUM unless the regulatory criteria are met. ## Worked example ### Illustrative manager with three funds ($ millions): three AUM figures Fund I is in harvest: NAV 300, fee charged on invested capital of 250. Fund II: NAV 600, unfunded commitments 200, fee on commitments of 1,000, and 150 drawn on a subscription line. Fund III has closed 500 of commitments and called nothing. | Measure | Fund I | Fund II | Fund III | Total | | --- | --- | --- | --- | --- | | NAV + unfunded (market convention) | 300 | 800 | 500 | **1,600** | | Fee-earning AUM | 250 | 1,000 | 500 | **1,750** | | Gross of borrowing + uncalled (RAUM-style) | 300 | 950 | 500 | **1,750** | Fee-earning AUM exceeds NAV plus unfunded because Fund II charges fees on commitments while its NAV is below cost. The RAUM-style figure adds back the 150 of borrowing. Examples are illustrative; figures are not market data. ## Not the same as - [Net Asset Value (NAV)](https://altss.com/glossary/net-asset-value): NAV is the value of a fund's net assets; private-markets AUM usually adds uncalled commitments, and regulatory AUM is measured gross of borrowing. - [Dry Powder](https://altss.com/glossary/dry-powder): Dry powder is the uncalled commitment component; AUM includes it plus invested value. - [Strategy Capacity](https://altss.com/glossary/capacity): Capacity is how much a strategy can absorb without harming returns; AUM is how much is currently managed. ## Common mistakes - Comparing two managers' AUM without checking whether both include uncalled commitments, leverage and co-investment vehicles. - Reading RAUM as net assets; it is gross of borrowings. - Treating fee-earning AUM as a measure of size rather than of the fee base. - Equating family-office AUM with family net worth. ## Edge cases - A fund holding its first close adds its full commitments to market-convention AUM before investing anything. - Fee-earning AUM can exceed NAV plus unfunded when fees are charged on commitments and NAV is below cost. - Real estate managers that quote gross asset value include property-level debt, so their AUM is not comparable with equity-based figures. ## Questions ### Does AUM include uncalled capital? In private markets it usually does, by convention, and US regulatory AUM includes uncalled commitments to private funds under the Form ADV instructions. Always check the definition. ### What is the difference between AUM and fee-earning AUM? AUM measures the assets managed; fee-earning AUM is the base on which management fees are charged, which can be larger or smaller depending on the fee terms. ## External standards | Standard | Relation | Note | | --- | --- | --- | | SEC Form ADV (Part 1A Item 5.F (regulatory assets under management) and Instructions to Part 1A) | narrower | | | AIFMD (Directive 2011/61/EU) (Article 3(2) thresholds) | related | | ## Sources - [Form ADV (Uniform Application for Investment Adviser Registration and Report by Exempt Reporting Advisers) - SEC form cover and index](https://www.sec.gov/about/forms/formadv.pdf). U.S. Securities and Exchange Commission, OMB No. 3235-0049; expires 2027-07-31. Status: in force (checked 2026-10-01). Form cover and index (OMB 3235-0049) — supports: Form ADV is filed by SEC-registered advisers and exempt reporting advisers and amended annually - [15 U.S.C. 80b-3 - Registration of investment advisers (Advisers Act sec. 203, incl. 203(l) and 203(m))](https://www.law.cornell.edu/uscode/text/15/80b-3). U.S. Congress (United States Code; LII mirror), Current US Code text as published by LII (accessed 2026-10-01). Status: in force (checked 2026-10-01). Advisers Act sec. 203(m)(1)-(2) — supports: Private fund adviser exemption below $150 million AUM in the United States; reporting by exempt advisers - [17 CFR 275.203(m)-1 - Private fund adviser exemption](https://www.law.cornell.edu/cfr/text/17/275.203(m)-1). U.S. Securities and Exchange Commission (CFR text via eCFR; LII mirror), eCFR current as of 2026-09-29; last amended 2018-03-12. Status: in force (checked 2026-10-01). 17 CFR 275.203(m)-1(a), (b), (c) — supports: US adviser: solely qualifying private funds and private fund assets below $150 million; non-US adviser test; annual calculation per Form ADV General Instruction 15 - [17 CFR 275.204(b)-1 - Reporting by investment advisers to private funds (Form PF filing obligation)](https://www.law.cornell.edu/cfr/text/17/275.204(b)-1). U.S. Securities and Exchange Commission (CFR text via eCFR; LII mirror), eCFR current as of 2026-09-29; last amended 2025-03-12. Status: in force (2024 Form PF amendments not yet in compliance) (checked 2026-10-01). 17 CFR 275.204(b)-1(a) — supports: Form PF filing by SEC-registered (or required) private fund advisers with at least $150 million private fund assets at fiscal year end - [Directive 2011/61/EU on Alternative Investment Fund Managers (AIFMD)](https://eur-lex.europa.eu/eli/dir/2011/61/oj/eng). European Parliament and Council, Official Journal of the EU, L 174, 1.7.2011, Adopted 8 June 2011; transposition by 22 July 2013. Status: In force; amended by Directive (EU) 2024/927 (AIFMD II) (checked 2026-10-01). Art. 3(2) — supports: EUR 100m / EUR 500m sub-threshold regime - [Directive (EU) 2024/927 amending Directives 2011/61/EU and 2009/65/EC (AIFMD II)](https://eur-lex.europa.eu/eli/dir/2024/927/oj/eng). European Parliament and Council, Official Journal of the EU, L series, 26.3.2024, Adopted 13 March 2024; Member States to adopt and apply measures by 16 April 2026 (some reporting provisions later). Status: In force; transposition deadline passed 16 April 2026; national transposition status varies by Member State (checked 2026-10-01). Art. 3(1) (transposition by 16 April 2026; certain provisions from 16 April 2027) — supports: AIFMD II transposition by 16 April 2026 - [Form ADV: General Instructions and Instructions for Part 1A](https://www.sec.gov/about/forms/formadv-instructions.pdf). U.S. Securities and Exchange Commission, SEC 1707 (07-24). Status: current (checked 2026-10-01). Part 1A Instruction 5.b ('Item 5.F: Calculating Your Regulatory Assets Under Management') (1)-(4); Part 1A Item 2.A(1)-(2) instructions — supports: RAUM reported in Item 5.F; calculation: 50% securities-portfolio test, private fund assets and uncalled commitments, no deduction of liabilities, 90-day valuation; SEC registration bands - [15 U.S.C. 80b-3a - State and Federal responsibilities (Advisers Act s.203A)](https://www.law.cornell.edu/uscode/text/15/80b-3a). U.S. Congress (US Code via LII), Current US Code text as published by LII (accessed 2026-10-01). Status: in force (checked 2026-10-01). Sec. 203A(a)(1)-(2) — supports: State versus SEC registration; registered investment company adviser carve-out - [17 CFR 275.203A-1 - SEC registration for mid-sized investment advisers](https://www.law.cornell.edu/cfr/text/17/275.203A-1). U.S. Securities and Exchange Commission (CFR text via LII), Current CFR text as published by LII (accessed 2026-10-01); source line 76 FR 43011, July 19, 2011. Status: in force (checked 2026-10-01). 17 CFR 275.203A-1(a)(1) — supports: $100m may register, $110m must apply, $90m may remain - [Commission Delegated Regulation (EU) No 231/2013 (AIFMD Level 2)](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32013R0231). European Commission (Official Journal L 83, 22.3.2013), Adopted 19 December 2012; OJ L 83 of 22.3.2013 (original text). Status: in force (checked 2026-10-01). Art. 2(1)-(3) — supports: AIFMD method for calculating total assets under management - [Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers (rulemaking page, File No. S7-22-22)](https://www.sec.gov/rules-regulations/2026/08/s7-22-22). U.S. Securities and Exchange Commission, Latest action IA-6992 (2026-08-31). Status: adopted; compliance date extended to 2027-07-01 (checked 2026-10-01). Release IA-6992 (joint final rule, 2026-08-31; effective 2026-09-03) — supports: Compliance date for 2024 Form PF amendments extended from 2026-10-01 to 2027-07-01 ## Related terms 10 terms - [Net Asset Value (NAV)](https://altss.com/glossary/net-asset-value) - [Dry Powder](https://altss.com/glossary/dry-powder) - [Unfunded Commitment](https://altss.com/glossary/unfunded-commitment) - [Form ADV](https://altss.com/glossary/form-adv) - [Form PF](https://altss.com/glossary/form-pf) - [Alternative Investment Fund Managers Directive (AIFMD)](https://altss.com/glossary/aifmd) - [Management Fee](https://altss.com/glossary/management-fee) - [Family Office](https://altss.com/glossary/family-office) - [Investment Consultant](https://altss.com/glossary/investment-consultant) - [Strategy Capacity](https://altss.com/glossary/capacity) ## Concept record Concept ID ALTSS-PERF-053 Classification Performance & benchmarking · Legal, regulatory & tax Topics Private markets · Legal, regulatory & tax Jurisdiction US; EU Version 2.0.0 Last reviewed 2026-10-02 Structured data [JSON](https://altss.com/reference/concepts/assets-under-management.json) Source check Legal and regulatory statements checked against the cited primary sources on 2026-10-02 ([how](https://altss.com/methodology)). General information, not advice. ## Canonical URL https://altss.com/glossary/assets-under-management