Fundry is built for venture and private equity managers under $1B. Most of them are much smaller than that, and most of them run finance with a team you could fit in one conference room. Everyone in fund services talks about the "emerging manager." Nobody publishes what that population actually looks like: how many there are, how big they really are, where they sit, or how they're regulated.

The data exists. It's public, it's in Form ADV, and we maintain a copy of it to understand the market we build for. Here's the cut for the lower half of it: every firm under $500M.

Headline: in our dataset there are 775 active US venture capital and private equity advisers reporting under $500M in regulatory AUM. The median manages $103 million. Three out of four are Exempt Reporting Advisers, not registered investment advisers.

Method and limits are at the bottom. Read them before citing any of this — a couple of the numbers mean something narrower than they look.

1. "Sub-$500M" is really "sub-$150M"

The distribution is heavily bottom-weighted:

Regulatory AUM	Firms	Share
Under $100M	377	49%
$100M – $250M	230	30%
$250M – $500M	168	22%

Median: $102.9M
25th percentile: $48.3M
75th percentile: $226.4M
Mean: ~$150M (dragged up by the top of the range)

Nearly half the population is under $100M. When a vendor prices a product for "emerging managers" against a mental model of a $400M firm with a CFO, a controller, and an ops lead, they've designed for the top fifth of the market and mispriced for the rest.

The median firm here is a $103M fund. At a typical 2% management fee that's roughly $2M in annual fee revenue to cover the entire management company — investment team compensation, rent, legal, audit, administration, and whatever's left for finance and operations headcount. That's the budget any tool in this category is actually competing for.

2. Three out of four are ERAs, not registered advisers

This is the finding that surprised us most, and it has more practical consequence than the AUM distribution.

Filer status	Firms	Share
Exempt Reporting Adviser	580	75%
SEC-registered RIA	195	25%

An ERA files a subset of Form ADV Part 1A and is exempt from full registration — typically as a private fund adviser under the $150M threshold, or under the venture capital adviser exemption. Practically, an ERA has meaningfully lighter ongoing obligations than a registered adviser: no Part 2 brochure delivery, no compliance-program requirement under Rule 206(4)-7, no mandated chief compliance officer.

Which means the compliance burden for most of this population isn't the formal program — it's the annual filing plus the standing obligation to know when the rules changed. In our ICP interviews a CFO at an ERA put roughly 10–15 hours a year into the ADV update itself and another 10–20 hours a year simply keeping current with SEC rulemaking. That second number is the interesting one: it's pure vigilance cost, it produces no deliverable, and it's invisible in any budget.

It also means most of this market has no compliance person to sell to. The buyer is the CFO, and if there isn't one, it's the ops lead or the GP.

3. Venture and private equity are near-evenly split

Strategy	Firms
Venture capital only	412
Private equity only	334
Both	29

Slightly more venture than private equity, and very little overlap. Firms doing both are rare — 29 of 775.

Worth noting because the operational profiles genuinely differ. Venture funds carry more portfolio companies at smaller marks with messier valuation inputs. Private equity funds carry fewer, larger positions with heavier debt and more complex waterfalls. Tooling that assumes one shape tends to fit the other badly, and "alternative assets" as a market segment papers over the difference.

4. The geography is more distributed than the narrative

775 firms across 49 states. The top of the list:

State	Firms
New York	64
California	62
Colorado	49
Texas	45
Massachusetts	43
Illinois	41
Florida	37
Connecticut	33
DC	24
Puerto Rico	21
Pennsylvania	21
Washington	19
Maryland	19
Ohio	19
Utah	18
Tennessee	18

Two things stand out.

New York and California together are only 16% of the population. For an asset class whose coverage is overwhelmingly about two metro areas, 84% of sub-$500M managers are somewhere else. Illinois has nearly as many as Massachusetts. Ohio has as many as Maryland.

Colorado is third, ahead of Texas and Massachusetts. We did not expect that, and we want to be careful about it — see the caveat below on business addresses. If it holds, it's a genuinely under-covered concentration.

Puerto Rico at 21 firms is the other anomaly. The straightforward explanation is the territory's tax incentives for relocated investment managers, but we haven't tested that against entity formation or principal-office data, so treat it as an observation rather than a conclusion.

What this implies for anyone selling into this market

The buyer is a team of one or two. At a $103M median with roughly $2M of management fee, there is no finance department. There is a CFO — or an ops lead wearing the CFO hat — plus a managing partner who co-approves spend and doesn't want to be involved past that.

Compliance-led positioning misses three-quarters of the market. Most of these firms are ERAs. They don't have a CCO, they don't have a compliance budget line, and the pain is filings and vigilance, not program administration.

Price for the median, not the top. A tool priced against a $400M firm's budget is unaffordable to half this population and overbuilt for most of the rest. CFOs in this segment have told us plainly: the sweet spot is a few hundred dollars a month, above $1,000 is a hard conversation, and $100 reads as not-serious.

Coverage should not follow the coastal narrative. Denver, Chicago, Columbus, Salt Lake and Nashville collectively hold more sub-$500M managers than New York. They get a fraction of the attention.

Method, and what these numbers don't mean

We maintain a copy of SEC adviser data: 8,472 candidate records from IAPD search and CRD-range scanning.

The filter used for the 775: reported private fund types including venture capital or private equity; adviser scope ACTIVE; regulatory AUM greater than zero and under $500 million.

Data currency: the adviser scan ran 2026-05-06; AUM figures were extracted 2026-07-12. Firms that filed after those dates are stale in this cut.

Five real limitations. Please carry them if you cite this:

This is our dataset, not a certified census. We built it from IAPD search plus a CRD-range scan. We believe coverage of the segment is good; we have not proven it is exhaustive, and you should not read 775 as "there are exactly 775."
Firms reporting zero or no AUM are excluded. That removes some genuinely small and newly-formed managers, which biases the population slightly upward.
State is the reported business address on the filing. For some firms that's a registered agent, a fund administrator, or a formation address rather than where anyone works. This is the specific reason to hold the Colorado and Puerto Rico findings loosely.
Regulatory AUM is not fund size. It's a defined regulatory measure, reported as of the last filing, and it can differ from committed capital or NAV in both directions.
Strategy comes from reported private fund types. A firm managing both a venture fund and an SPV vehicle may report differently than one would categorise it by hand.

If you work with this data and you get a materially different count, we'd genuinely like to know — the methodology matters more to us than the number.

If you run finance at one of these firms, the fastest way to see what Fundry does is the free DDQ tool: bring your hardest questionnaire and get a draft answer to every question, each with a confidence score. No account required.