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Fund expense allocation policy

The rule, applied the same way every time, with a record of each application.

By SRM, Executive Director · Updated October 2026

Why do private funds need an expense allocation policy?

Because expenses shared among funds, co-investors and the manager must be allocated fairly and consistently with the LPA, and expense allocation is a recurring focus of regulatory examinations. A written policy, applied consistently and recorded, is the defence.

What the policy covers

Which expenses the fund bears versus the manager; how shared costs are split across funds and vehicles; how broken-deal costs are allocated to co-investors; and how exceptions are approved.

Applying it

Choose allocation keys (commitments, invested capital, ownership) per expense type and apply them mechanically.

Recording it

Keep each allocation with its key and approval, so an examiner or LP can follow it.

Questions

Does FUN/D enforce the policy?

It stores allocation rules and applies them, with a record of each.

About the author

SRM, Executive Director. Founder and lead designer of FUN/D.

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