SEI Carlyle Private Markets Fund: $1,000 Minimum, 3.65% Cost

What the fund is, and what it is not

The prospectus describes a Delaware statutory trust, organized on April 30, 2026, that is registered under the Investment Company Act of 1940 as a non-diversified, closed-end fund and “is structured as an ‘interval fund.’” Because it is a registered fund, the prospectus sets no accredited-investor test, and holders get a Form 1099 rather than a Schedule K-1. The fund “intends to qualify each year as a RIC.” Our guide to interval funds explains what that structure does and does not promise.

The name suggests a Carlyle product sold through SEI. The legal text says otherwise on three points. First, the adviser is SEI Investments Management Corporation (SIMC), and the distributor is SEI Investments Distribution Co. Second, Carlyle “does not provide investment advice to the Fund, and is not a sponsor, investment adviser, sub-adviser, promoter, principal underwriter or affiliate of the Fund.” Third, SIMC “maintains sole investment discretion as to whether, and to what extent, the Fund will invest in Carlyle Funds.” The risk list names a “Strategic Relationship with Carlyle” and warns that if the two firms “were to alter or terminate the strategic relationship, the Fund might be unable to implement its intended principal investment strategy.”

What the fund actually buys: at least 80% of net assets in private markets instruments, and at least 60% in underlying funds “managed, sponsored or advised by Carlyle Investment Management L.L.C. or one of its affiliates.” The rest goes mainly to SEI-managed registered funds, co-investments or direct instruments such as CLOs. Up to 20% may be outside private markets, including cash and public securities. The adviser will pick from Carlyle and SEI funds “without considering funds with other managers.” It also says it does not expect to invest in Carlyle funds that do not offer periodic repurchases, and that Carlyle, as manager of an underlying fund, “retains the authority to reject purchases by the Fund.”

The prospectus says the fund will have exposure to Carlyle's private equity, credit and AlpInvest platforms. For the Carlyle funds that already sell to individuals, see our pages on Carlyle AlpInvest Private Markets Fund (CAPM) and Carlyle Private Equity Partners Fund (CPEP). Those are Carlyle's own products. For the group's own economics, see our Carlyle Group stock page.

Fees: two layers

The fee table is the fund's own estimate for its first full fiscal year, as a percentage of projected average net assets.

The first layer is the fund's own: 1.30%. The management fee is “calculated and payable monthly in arrears at the annual rate of 0.75%” of average daily net assets, and 0.55% covers everything else the fund pays directly. The administrator and its affiliates have agreed “until October 31, 2027” to keep these direct costs from exceeding 0.70%, which is why the reimbursement is 0.60% (1.30% less 0.70%, our arithmetic).

The second layer is the underlying funds: 2.35%. AFFE “reflects the estimated amount of fees and expenses that will be incurred indirectly by the Fund through its investments in Underlying Funds.” The prospectus describes it as including management fees, performance fees, administration fees and other fixed costs of those funds. The Carlyle funds in which the fund expects to invest charge a management fee of 1.00% to 1.25% and between 10% and 15% of net profits as carried interest. The prospectus adds that the figure is “based on historic returns” and “may change substantially over time,” and that “fees and allocations for a particular period may be unrelated to the cost of investing in the Underlying Funds.” It also excludes any underlying funds that are real estate investment trusts, because they are not treated as acquired funds.

Three things follow, all our arithmetic from the table:

• AFFE is 64.4% of the 3.65% gross total (2.35 divided by 3.65), and 77.0% of the 3.05% net total. The waiver reduces the smaller layer.
• On $10,000 the fund costs about $365 a year gross and $305 net, of which $235 is the underlying funds.
• If the waiver ends on October 31, 2027 and nothing else changes, the net figure goes back to 3.65%. The prospectus says “there is no guarantee that the contractual fee waiver agreement will continue after October 31, 2027.”

The SEC-required example shows what a $1,000 investment costs if it earns 5% a year and expenses stay as shown, “including capped expenses for the period described in the footnote.”

The fee table has no sales load and no early repurchase fee. The prospectus does reserve the right, under an SEC exemptive order, to create other classes with an early withdrawal charge or distribution fees, but it says “the Fund is currently offering only one class of shares.” Brokers can add their own charges: the table does not include commissions in a brokerage account, and the prospectus says the adviser may pay intermediaries from its own resources to promote the fund.

How the fee table changed

The fee table was not complete until October. Each draft filed with the SEC is below.

In the first draft the 0.25% shareholder servicing fee sat inside other expenses. It was removed by August. The 3.65% total and the $31 / $106 / $184 / $387 example appear from October 7, three weeks before the registration went effective on October 30, 2026.

Getting out: quarterly, 5%, and not yet

The fund “will conduct quarterly repurchase offers for a specified percentage (from 5% to 25%)” of its shares at net asset value, in March, June, September and December. “In any given quarterly repurchase offer, it is expected that the Fund will offer to repurchase only the minimum amount of 5%.” That is up to four chances a year, each for about 5% of all shares (20% a year at most, our arithmetic).

The start date is open. The prospectus says the fund “expects to make its initial repurchase offer after two full quarters following commencement of operations,” and the text I read does not give a commencement date. Nothing in the prospectus lets a holder sell before that first offer, and shares cannot be sold to anyone else without the fund's consent.

The mechanics, all from the prospectus: notice goes out 21 to 42 days before the request deadline; the price is the NAV on a pricing date no later than 14 days after the deadline; payment follows within seven days. If holders ask to sell more than the offer, the fund “may, but is not required to,” buy up to 2% more of its shares, and otherwise buys pro rata, so holders “will have to wait until the next repurchase offer.” As an illustration (our arithmetic): if holders tender 10% of the shares in a 5% offer, each is filled about half, and the rest must be re-submitted. A holder tendering part of a position must keep $1,000, and requests made through a broker must reach the fund by the deadline.

The fund says it may finance repurchases with cash, borrowing or sales of portfolio securities, and warns that selling its more liquid holdings to pay sellers raises risk and expense ratios for those who stay. See our evergreen fund redemption comparison for how other funds have handled their offers once running.

Distributions and tax

The fund pays net investment income typically monthly and net capital gains at least annually, with no guarantee, and says distributions may come from offering proceeds or borrowings, which would be a return of capital. Each year holders receive a Form 1099. The prospectus has a long tax section; read it or ask a tax professional about your account type, especially for an IRA.

What a reader can do with this

• Do not read the SEI Carlyle name as access to Carlyle's flagship funds. The fund is limited to Carlyle funds it is eligible for, that offer repurchases and that accept its money.
• Ask for the all-in figure, not 3.05%. Use 3.65% for the cost after the waiver ends and ask the selling firm what it charges on top.
• Compare against Carlyle's own funds for individuals. CAPM and CPEP are the same family reached directly, with their own fee layers, minimums and exit rules.
• Plan around the exit: no sale until the first offer, then about 5% of all shares per quarter, pro rata when oversubscribed.
• Wait for numbers. The fund has no NAV history yet; the first shareholder report and the first repurchase offer notice will show real performance, cost and demand.
• If this would be a large position, a second opinion on how it fits the rest of your portfolio is cheap compared with the lock-up.

This is analysis of public documents, not investment, legal or tax advice.

FAQ

All figures are from the filings of SEI Carlyle Private Markets Fund (CIK 2134782) read on EDGAR on November 5, 2026: the Form 424B3 of November 2, 2026 (accession 0001104659-26-121485, prospectus dated October 30, 2026), the Form N-2 of May 15, 2026 (0001104659-26-062506), the Forms N-2/A of August 13, October 7 and October 28, 2026 (0001104659-26-096046, 0001104659-26-114405 and 0001104659-26-119697) and the EDGAR filing list. The percentage shares of AFFE, the dollar costs on $10,000, the waiver check, the 20% a year ceiling and the proration example are our arithmetic. This is analysis of public documents, not investment, legal or tax advice.