- Om Singh
- Feb 28, 2021
- 6 min read
Updated: Dec 7, 2025
Reg BI and retail Private Equity Pitchbooks - a collision that was a long time coming.
I am going to show you how IRR changes over time and how Reg BI protects you from deceptive numbers.
IRR doesn't mean (Expletive)...I mean it really doesn't mean anything....not until at least 10 years of a funds life (and depending on the fund), it can be meaningless until the end (of the 12+ years) life of the fund......- I don't want the clients to hear this. recorded conversation (05/21) with an experienced Blackstone salesperson. He is selling every day to "sophisticated" QP's.
The pitchbooks don't show IRR over time. You only see IRR at a point in time, so if you don't know how it works, you don't know what you are looking at or if it is meaningful. Take a look!
Reg BI protects you because you can say to your Morgan Stanley or UBS wealth manager, hey, the pitchbook only showed me IRR at a point in time and it was inflated because of how IRR is calculated. I never would have invested if you had shown me IRR over 12 -15 years so I could get my own perspective.
You are required to give me ALL material information, in a "full and fair" manner, that is "sufficiently specific" so that I can make an "informed decision". Showing me fake IRR on the pitchbook and "explaining it" in the fine print is not "fair." I don't read docs, I don't understand the tricks behind IRR and I don't have the time, desire or responsibility to learn them. You are required to get an "informed decision" from me and you failed. The person who defines those terms is me-the retail customer. I am going to ask in Discovery how you upgraded your compliance from "reasonably disclose" to the new disclosure requirements under Reg BI.
Did you train your salesforce in "IRR tricks"- let's see the curriculum. Do you have compliance procedures that govern how my broker told me that IRR was manipulated? Let's see them. Your firm says you only sell "first quartile" funds. Show me how you calculated the first quartile. Show me the 1,000 funds and how you define the top 200? Show me the next 200, etc. Over what time period? with or without the credit line? Funds in their first 3 years or middle 6 years or last 3-5 years? How much capital was called or sold? After all, you must have an easy way to calculate it because you are so sure I purchased a top quartile fund.
The person who is going to define the above terms is me-the retail customer. When the standard was "reasonably disclose", the industry attorneys defined it. This is a huge change and the industry knows it which is why they punted.
This is a Trump rule and is so common sense. A person investing money in a deal from a trusted advisor and a trusted firm believes they are getting all the material information. Reg BI just legally mandated that common sense belief. The dual- hatted advisor is telling him- "you can trust me." In the advisory account, you could always trust him, now you can trust him in the brokerage account as well.
Below is Blackstone Total Alternative Solutions. It includes Real Estate, Private Equity, Lending, etc. The IRR was targeted at 13-15%. As of 11/25, the IRR is 3.4%. The customer invested $215,000 and their is still $33,000 left in the deal. The MOIC is 1.16. The S&P from August 2014 thru April of 2025 was 11.84%
BTAS 2014 | IRR |
8/15/14 | 0.00% |
12/30/15 | 1.31% |
6/30/16 | 5.76% |
12/30/16 | 9.09% |
6/30/17 | 7.80% |
12/31/17 | 10.82% |
6/29/18 | 10.06% |
12/30/18 | 9.67% |
6/30/19 | 7.87% |
12/31/19 | 6.78% |
6/30/20 | 4.39% |
12/31/20 | 4.87% |
3/31/21 | 4.79% |
6/30/21 | 5.18% |
9/30/21 | 5.43 % |
12/31/21 | 5.52 |
6/30/22 | 5.59 |
9/30/22 | 5.19 |
12/30/22 | 4.83 |
3/31/23 | 4.73 |
6/30/23 | 4.31 |
9/30/23 | 3.97 |
12/29/23 | 3.84 |
3/31/24 | 3.79 |
6/30/24 | 3.71 |
9/30/24 | 3.59 |
3/31/25 | 3.51% |
9/30/25 | 3.40% |
10/31/25 | 3.40% |
11/30/25 | 3.40% |
Below is BTAS (Blackstone Total Alternatives Solution ) This was sold as 13-15% Net IRR. In 2015, the IRR got as high as 14% and it appeared to be going higher. However, that is as high as it got and it is currently at 6.91%. The S&P over the same time period is 14.61%. As of 9/30/25 the investor put in
BTAS 2015 | IRR |
12/31/2015 | 0.00% |
3/31/2016 | -39.00% |
6/30/2016 | -28.00% |
9/30/2016 | -5.50% |
12/31/2016 | 2.30% |
3/31/2017 | 3.90% |
6/30/2017 | 5.60% |
9/30/2017 | 6.70% |
12/31/2017 | 7.50% |
3/31/2018 | 5.70% |
6/30/2018 | 14.00% |
9/30/2018 | 12.00% |
12/31/2018 | 13.00% |
3/31/2019 | 10.90% |
6/30/2019 | 10.60% |
9/30/2019 | 10.60% |
12/31/2019 | 9.80% |
3/31/2020 | 9.00% |
6/30/2020 | 4.70% |
9/30/2020 | 5.80% |
12/31/2020 | 6.50% |
3/31/2021 | 6.32% |
6/30/2021 | 7.16% |
9/30/2021 | 8.09% |
12/31/2021 | 8.80% |
3/31/2022 | 8.55% |
6/30/2022 | 8.85% |
9/30/2022 | 8.43% |
12/31/2022 | 8.20% |
3/31/2023 | 7.87% |
6/30/2023 | 7.47% |
9/30/2023 | 7.50% |
12/31/2023 | 7.28% |
3/31/2024 | 7.28% |
6/30/2024 | 7.28% |
9/30/2024 | 7.20% |
3/31/2025 | 7.38% |
6/30/2025 | 6.89% |
9/30/2025 | 6.78% |
Below is Blackstone Tac opps- 2017 Vintage. Take a look at how IRR starts at -62%, gets as high as 7.8% and is currently at 5.14%. S&P over the same time period is 14.64%. As of 11/25, the customer contributed $88,000 and there is $46,800 left in the fund. This fund could get much worse.
Blackstone Tac OPPS 2017 | IRR |
6/30/2017 | 0.00% |
9/30/2017 | -62.00% |
12/31/2017 | -57.00% |
3/31/2018 | -18.00% |
6/30/2018 | -14.00% |
9/30/2018 | -14.60% |
12/31/2018 | -13.70% |
3/31/2019 | -9.00% |
6/30/2019 | -8.00% |
9/30/2019 | -5.50% |
12/31/2019 | -5.80% |
3/31/2020 | -4.30% |
6/30/2020 | -14.70% |
9/30/2020 | -8.70% |
12/31/2020 | -2.65% |
3/31/2021 | -2.17% |
6/30/2021 | 6.31% |
9/30/2021 | 7.75% |
12/31/2021 | 7.30% |
3/31/2022 | 6.82% |
6/30/2022 | 7.80% |
9/30/2022 | 6.84% |
12/31/2022 | 6.12% |
3/31/2023 | 6.12% |
6/30/2023 | 5.69% |
9/30/2023 | 5.60% |
12/31/2023 | 5.49% |
3/31/2024 | 5.53% |
6/30/2024 | 5.61% |
9/30/2024 | 5.30% |
12/31/2024 | 5.30% |
3/31/2025 | 5.05% |
6/30/2025 | 5.85% |
9/30/2025 | 5.14% |
Here is a great example. This is Blackstone flagship Real Estate fund. I have numbers from 2012. BREP (Blackstone Real Estate Partners) was as high as 20.05% IRR. It is around 10.28% in 10/24. The S&P did 14.30%. If an investor was shown the 20%, they would automatically invest, if they were shown 10.28%, they would never invest. PE is putting low confidence (fake) IRR on the pitchbooks. As of 10/24, the client invested $442,500 and $85,422 was in the fun. The MOIC was 1.66.
BREP 2012 | IRR |
12/31/2015 | 20.05% |
3/31/2016 | 16.88% |
6/30/2016 | 15.46% |
9/30/2016 | 14.76% |
12/31/2016 | 14.40% |
3/31/2017 | 13.46% |
6/30/2017 | 13.51% |
9/30/2017 | 13.11% |
12/31/2017 | 13.79% |
3/31/2018 | 14.71% |
6/30/2018 | 14.00% |
9/30/2018 | 13.95% |
12/31/2018 | 13.55% |
3/31/2019 | 12.74% |
6/30/2019 | 12.74% |
9/30/2019 | 12.66% |
12/31/2019 | 12.71% |
3/31/2020 | 12.33% |
6/30/2020 | 11.33% |
9/30/2020 | 10.54% |
12/31/2020 | 10.45% |
3/31/2021 | 10.29% |
6/30/2021 | 10.29% |
9/30/2021 | 10.29% |
12/31/2021 | 10.29% |
3/31/2022 | 10.29% |
6/30/2022 | 10.29% |
9/30/2022 | 10.29% |
12/31/2022 | 10.29% |
3/31/2023 | 10.29% |
6/30/2023 | 10.29% |
9/30/2023 | 10.29% |
12/31/2023 | 10.29% |
3/31/2024 | 10.28% |
6/30/2024 | 10.28% |
8/31/2024 | 10.28% |
Here is Blackstone Real Estate from 2015. The IRR got as high as 14.14% and is now at 8.56%. You only care about the final number. The goal for this fund was high teens. The S&P did 14.49%. The investor (100,000 commitment) put in $89,000 and still has $58,730 in the fund. The MOIC is 1.56. This can go much lower.
BREP 2015 | IRR |
6/30/2016 | 2.15% |
12/30/2016 | 10.04% |
6/30/2017 | 11.17% |
12/31/2017 | 10.14% |
6/29/2018 | 10.40% |
12/30/2018 | 11.27% |
6/30/2019 | 10.88% |
12/31/2019 | 11.23% |
6/30/2020 | 8.55% |
12/31/2020 | 9.55% |
3/31/2021 | 10.12% |
6/30/2021 | 9.64% |
9/30/2021 | 11.16% |
12/31/2021 | 12.72% |
3/31/2022 | 15.12% |
6/30/2022 | 14.97% |
9/30/2022 | 14.50% |
12/30/2022 | 14.14% |
3/31/2023 | 13.23% |
6/30/2023 | 12.70% |
9/29/2023 | 7.50% |
12/29/2023 | 11.74% |
3/31/2024 | 10.95% |
6/30/2024 | 10.77% |
9/30/2024 | 10.77% |
12/31/2024 | 10.42% |
3/31/2025 | 8.69% |
6/30/2025 | 8.69% |
9/30/2025 | 8.69% |
11/30/2025 | 8.53% |
Here is GSO Mezz from 2012. The goal was 13-15% Net of ML fees. The IRR started at 23.30% and was at 6% in 2021. The S&P did 15.58%
GSO MEZZ 2012 | IRR |
12/31/2014 | 23.30% |
3/31/2015 | 23.30% |
6/30/2015 | 16.36% |
9/30/2015 | 16.36% |
12/31/2015 | 14.40% |
3/31/2016 | 14.40% |
6/30/2016 | 8.43% |
9/30/2016 | 9.69% |
12/31/2016 | 10.91% |
3/31/2017 | 9.55% |
6/30/2017 | 9.82% |
9/30/2017 | 9.56% |
12/31/2017 | 9.88% |
3/31/2018 | 9.41% |
6/30/2018 | 10.07% |
9/30/2018 | 10.47% |
12/31/2018 | 9.68% |
3/31/2019 | 9.68% |
6/30/2019 | 9.04% |
9/30/2019 | 8.90% |
12/31/2019 | 8.44% |
3/31/2020 | 8.44% |
6/30/2020 | 6.14% |
9/30/2020 | 6.49% |
12/31/2020 | 6.49% |
3/31/2021 | 6.36% |
2/26/2021 | 6.36% |
Here is another branded real estate company. Lone Star RE Recovery fund from 2017. The IRR is a negative 16%. The S&P did 12.38%. The fund is priced at .56. Investors lost 44% of their money. They invested $34,500 and remaining is $6700.
LS 2017 | IRR |
12/31/2017 | 0.00% |
3/31/2018 | -81.00% |
6/30/2018 | -64.00% |
9/30/2018 | -34.00% |
12/31/2018 | -32.00% |
3/31/2019 | -33.70% |
6/30/2019 | -33.30% |
9/30/2019 | -26.50% |
12/31/2019 | -19.40% |
3/31/2020 | -15.00% |
6/30/2020 | -13.25% |
9/30/2020 | -19.75% |
12/31/2020 | -18.20% |
3/31/2021 | -14.87% |
6/30/2021 | -13.94% |
9/30/2021 | -12.80% |
12/31/2021 | -11.59% |
3/31/2022 | -13.35% |
6/30/2022 | -13.08% |
9/30/2022 | -11.91% |
12/30/2022 | -11.52% |
3/31/2023 | -12.56% |
6/30/2023 | -11.91% |
9/29/2023 | -11.83% |
12/29/2023 | -12.27% |
3/31/2024 | -12.48% |
6/30/2024 | -12.60% |
9/30/2024 | -12.48% |
2/28/2025 | -16.58% |
7/31/2025 | -16.86% |
9/30/2025 | -16.94% |
Here is Carlyle Growth 2015. It has a goal of 20% IRR. It is at 12.02 as of 11/25, the client (committed 150,000) contributed 147,750 and there is still $78,500 let in the fund. The S&P did 15.47%. This is 10 years old and has a good five years left. These funds are not 10 year deals, they last much longer.
Carlyle Growth 2015 | IRR |
12/30/2015 | 0.00% |
6/30/2016 | -31.60% |
12/30/2016 | -13.76% |
6/30/2017 | -5.14% |
12/31/2017 | 0.36% |
6/29/2018 | 1.05% |
12/30/2018 | 1.05% |
6/30/2019 | -4.69% |
12/31/2019 | -3.39% |
6/30/2020 | -8.50% |
12/31/2020 | -4.40% |
3/31/2021 | -0.31% |
6/30/2021 | 2.62% |
9/30/2021 | 8.10% |
12/31/2021 | 8.34% |
3/31/2022 | 9.93% |
6/30/2022 | 9.71% |
9/30/2022 | 10.42% |
12/30/2022 | 10.11% |
3/31/2023 | 10.96% |
6/30/2023 | 11.28% |
9/30/2023 | 11.71% |
12/29/2023 | 11.69% |
3/31/2024 | 11.71% |
6/30/2024 | 11.47% |
9/30/2024 | 11.27% |
10/31/2025 | 12.14% |
11/30/2025 | 12.07% |
