The Fund Administration Checklist for a GP-Led Continuation Vehicle

GP-led continuation vehicles may close on a single date, but their operating models are built well before then. Each LP election changes the records required in the legacy fund and the new vehicle. If those records are not designed together, discrepancies can surface during the first reporting cycle and become difficult to trace. 

This is why continuation fund administration belongs in the transaction plan rather than being treated as a handoff after close. CFA Institute notes that continuation funds can provide liquidity in slower-moving private markets while also creating inherent conflicts of interest because the GP participates on both sides of the transaction.

Once the structure is approved, the administrator must turn it into an operating model that works from the new vehicle’s first day.  

The checklist below focuses on making that transition reliable. 

What is a GP-led Continuation Vehicle

A GP-led continuation vehicle is a newly formed fund that acquires one or more assets from an existing fund managed by the same GP. Existing limited partners (LPs) are typically given the option to sell their interest or roll it into the new structure, while new investors may provide additional capital. Depending on the transaction documents, other election paths may also be available. 

The structure, therefore, creates several investor populations that must be administered under different terms. The Institutional Limited Partners Association (ILPA) notes that continuation vehicle structures vary widely, review periods may be compressed, and conflicts are inherent because the GP is involved on both sides of the transaction.² 

The administrator does not determine whether the transaction is fair or advise an LP whether to sell or roll. Its role is to translate the approved terms into a reliable operating and reporting model. 

Why Fund Administration Needs to be Planned Before Close

The transaction timeline and the administration timeline are closely connected. If the operating model is left until after close, the first reporting cycle can begin with unresolved differences. 

That risk is higher where the legacy fund and continuation vehicle use different service providers or systems. It also increases when the transaction involves a rollover vehicle, parallel entities, or multiple investor classes. Alter Domus’ analysis of liquidity in private markets and secondaries describes the additional reporting and governance demands that continuation funds place on back-office teams. 

As a result, a pre-close work plan is required to administer continuation vehicle funds. The plan should establish clear ownership of the data and decisions needed to convert approved terms into accounting instructions. 

A continuation fund administration plan should also set deadlines for testing those instructions before cash and assets move. 

GP-led Continuation Vehicle Fund Administration Checklist

The eight workstreams below focus on operational implementation.

1. Map the Vehicle Structure and Administrative Responsibilities

Start with an entity map showing how the legacy fund connects to the continuation vehicle and any related structures. Rather than relying on outdated, early structuring diagrams, this map must reflect the final transaction documents and explicitly detail both investor classes and the legal ownership path for the transferred assets. 

Next, clearly assign each operational task. The responsibility map should distinguish between decisions made by the GP and its advisors and the records and approved activities handled by the administrator. Tax and valuation matters should be routed to their respective appointed specialists. 

Where SPVs are part of the structure, corporate services may support their establishment and ongoing administration. 

Key Questions for the CFO:

• Does our entity map reflect the final documents, investor classes, and asset ownership?
• Does each administrative task have a clear owner and approver across both funds?
• Are handoffs between our team, administrators, and specialist advisers clearly defined?

2. Establish the New Entities and Operating Infrastructure

The continuation vehicle should have its own operating environment rather than relying on the legacy fund’s existing setup. Reporting templates and the reporting calendar also need to be configured before the first close output is due. 

The set-up sequence is important. An account cannot be opened before the required entity and onboarding documents are available, and investor records cannot be finalized while elections remain outstanding.  

Alter Domus’ fund formation services can support the setup work required before the vehicle begins operating. The operating plan should connect these activities to the transaction timetable and show any dependencies. 

Key Questions for the CFO:

• Will the entities, bank accounts, and accounting systems be ready for close?
• Which setup dependencies could cause delays, and who will resolve them?
• Have we tested reporting templates and confirmed readiness for the first reporting deadlines?

3. Prepare Investor Data and LP Election Processing

Build one controlled election register for selling, rolling, and new investors. Each record should show how the investor’s election affects its position in the relevant vehicle and whether the required documentation is complete. Where the documents allow more than two outcomes, the register must capture those options without forcing investors into a standard sell-or-roll field. 

Validation is more than checking whether an election form was returned. Investor data in the election register must agree with the onboarding and legacy records. Late changes need an approval trail. Exceptions, including incomplete documentation or an election received after the stated deadline, should be routed to the party authorized to decide how they are treated. 

Key Questions for CFO:

• Can we trace each election from its documentation to the investor’s resulting position?
• Does the election register match legacy and onboarding records and capture every permitted option?
• Who approves late elections or changes, and how are these recorded across systems?

4. Coordinate Valuation Inputs and Transfer Accounting

The administrator records approved conclusions rather than making valuation or accounting decisions for the transaction. Those conclusions are based on the transaction documents and the appointed specialists. 

With finalized inputs, accounting can record the asset transfer and any needed in-kind contributions or distributions. Both funds must use the same approved basis. A schedule linking entries to supporting documents ensures an audit trail to the general ledger. 

The 2025 IPEV Valuation Guidelines set out best-practice recommendations for reporting private capital investments at fair value. Where US GAAP applies, the AICPA PE/VC Accounting and Valuation Guide provides nonauthoritative guidance for accounting and valuing portfolio company investments held by investment companies within FASB ASC 946.  

The appointed specialists remain responsible for applying the relevant framework and approving the conclusions used in the books. 

Key Questions for the CFO:

• Have the responsible parties approved the valuation inputs and transfer accounting treatment?
• Are both administrators using approved inputs, with accounting differences documented and reconciled?
• Can we trace every transfer entry, including in-kind movements, to supporting documents and approvals?

5. Configure Fees, Waterfalls, Carry, and Investor Allocations

Because rollover and new investors may enter on different economic terms, the administrator must translate the final provisions into calculation logic at the correct investor or class level. 

Test the waterfall before live reporting begins. Sample scenarios can confirm that the calculation model responds as intended when cash amounts or timing changes. Alter Domus’ capital administration capabilities can support this calculation and reporting model at both fund and investor level. 

Key Questions for the CFO:

• Do our models reflect agreed fees, waterfalls, and carry for each investor group?
• Have we tested how distribution amounts and timing affect rolling and new investors?
• Who has signed off the calculation logic against the governing documents?

6. Plan Capital Activity and Closing Cash Flows

The closing funds flow should be converted into an administrative schedule that identifies all expected receipts and payments. The schedule should show how cash moves into, out of, and between the legacy and continuation structures at close. 

Each payment instruction should be complete enough to authorize and evidence the movement of cash. The schedule should also state how rejected or delayed payments will be handled. After close, bank activity must be reconciled to the approved transaction and the resulting accounting records. 

Key Questions for the CFO:

• Does the closing schedule capture every expected receipt and payment across both structures?
• Have we verified payment instructions, bank details, and authorization responsibilities?
• How will we handle delayed or failed payments and reconcile closing cash movements?

7. Reconcile the Legacy Fund and Continuation Vehicle

A bridge between the two sets of books is one of the main controls in administering the continuation vehicle fund. The reconciliation should show how the approved transaction moved from the legacy books into the new vehicle. 

The reconciliation should cover transferred asset balances, investor elections, and the related contributions or distributions. Fees and transaction expenses need to be compared separately because they may be borne differently by sellers, rollers, and new investors.  

Any unresolved difference should be formally tracked through to resolution before the first net asset value (NAV) or investor statement is finalized. 

Key Questions for the CFO:

• Do legacy closing entries reconcile to the new vehicle’s opening balances, including investor movements?
• Are fees and expenses allocated to sellers, rollers, and new investors as agreed?
• Who resolves reconciliation differences before the first NAV or investor statements are approved?

8. Establish Post-Close Reporting and Controls

Closing does not end the administration project. It starts the reporting model for the new vehicle. The team needs a calendar for NAV production, capital account statements, financial statements, investor notices, and audit support. Dates should reflect the governing documents and agreed-upon service levels rather than assumptions carried over from the legacy fund. 

Implementation decisions and changes require clear audit trails. Additionally, reviewing access rights during the handoff from the transaction team to ongoing administration prevents temporary files from becoming unofficial permanent records. The Invest Europe Investor Reporting Guidelines provide a broader best-practice framework for producing information that investors can understand and use in a timely manner.

Key Questions for the CFO:

• Does our reporting calendar reflect agreed obligations, deadlines, and preparation and review responsibilities?
• Can the administration team access approved records and audit trails for reporting and audit?
• Have we reviewed access rights and agreed how to approve and record post-close adjustments?

What Changes Once the Continuation Vehicle Closes

Before close, the work centers on building records and converting transaction terms into operating instructions. After close, the emphasis shifts to consistent execution. The administrator moves from transaction setup to the ongoing operation of the new vehicle. 

GP-led continuation vehicles can also continue to affect the legacy fund. Because the transfer impacts both vehicles, audit support must maintain a consistent record of the transaction for each vehicle. 

If adjustments are identified after close, they should be recorded through an agreed-upon process rather than corrected in only one set of books. Successful continuation fund administration preserves that connection without treating the two vehicles as the same fund. 

Prepare the Operating Model Before the First Close

 The clearest test of readiness is whether an investor election can be followed cleanly from the source documents to the first reporting output. If that path breaks, the issue is easier to resolve before close than during the first reporting cycle. 

Alter Domus supports complex private market structures from initial setup through ongoing administration. Bring the administrator into the transaction process early enough to test the data and reporting model.