Commingled Funds: How They Work and Pros & Cons


Commingled funds are investment portfolios that combine assets from multiple accounts to reduce management costs. Unlike mutual funds, they’re not publicly traded and are typically found in institutional accounts. Learn more about these funds, their advantages, disadvantages, and how they compare to mutual funds in this in-depth guide.

Commingled fund definition: a comprehensive guide

If you’ve ever explored investment options, you might have come across the term “commingled fund.” In this guide, we’ll dive deep into what commingled funds are, how they work, their advantages and disadvantages, and provide a comparison with mutual funds. So, let’s begin.

Understanding commingled funds

Commingled funds are investment vehicles where an investment manager pools money from various investors and combines it into a single fund. This strategy aims to streamline the management of assets, reducing costs associated with managing individual accounts separately.

In many ways, commingled funds share similarities with mutual funds. Both are professionally managed by fund managers who invest in a mix of financial instruments such as stocks, bonds, or a combination of both. This professional oversight benefits from economies of scale, leading to lower trading costs per dollar of investment and enhanced diversification, which reduces portfolio risk.

However, one significant distinction is that commingled funds are not regulated by the U.S. Securities and Exchange Commission (SEC), which means they are not obligated to submit extensive disclosures. In contrast, mutual funds must register with the SEC and comply with the Investment Company Act of 1940.

Commingled funds are not entirely free from oversight, as they are subject to review by the United States Office of the Comptroller of the Currency and individual state regulators. While mutual funds issue prospectuses, commingled funds provide a Summary Plan Description (SPD), offering comprehensive details on the fund’s objectives, investment strategy, and the background of its managers. The SPD also outlines the rights and obligations of plan participants and beneficiaries.

Advantages and disadvantages of commingled funds

Commingled funds come with their own set of advantages and disadvantages that investors should consider:


Here is a list of the benefits and drawbacks to consider.

  • Professionally managed
  • Diversified portfolio
  • Lower fees and expenses
  • Economies of scale
  • Illiquid
  • Less transparent/harder to track
  • Not SEC-regulated
  • Limited availability

Explanation of the pros of commingled funds

– Professionally managed: Commingled funds are managed by professionals who have expertise in handling diversified portfolios.

– Diversified portfolio: These funds offer diversification, spreading investments across different asset classes to reduce risk.

– Lower fees and expenses: Due to economies of scale, commingled funds often have lower expenses compared to mutual funds.

– Economies of scale: Larger investments in commingled funds lead to cost savings, which can benefit investors.

Explanation of the cons of commingled funds

– Illiquid: Commingled funds are less liquid than mutual funds, making it harder to access your investments when needed.

– Less transparent/harder to track: They lack ticker symbols and public trading, which can make tracking fund performance challenging.

– Not SEC-regulated: Unlike mutual funds, commingled funds are not regulated by the SEC, which can raise concerns for some investors.

– Limited availability: These funds are typically available only in institutional accounts, limiting access for individual retail investors.

Example of a commingled fund

To provide a real-world perspective, let’s consider the Fidelity Contrafund Commingled Pool. This fund focuses on large-cap growth stocks and publicly discloses information through quarterly reports. It maintains major weightings in information technology, communication services, consumer discretionary, financial companies, and health care.

The Contrafund Commingled Pool boasts a low 0.43% expense ratio, surpassing the average expense ratio of mutual funds, including its mutual fund counterpart, the Fidelity Contrafund, with a 0.86% expense ratio. Since its inception in 2014, the fund has consistently delivered an annualized return of 15.85%, outperforming the 14.12% produced by the S&P 500 index.

Illegal commingling

It’s essential to note that in some cases, commingling of funds may be illegal. This occurs when an investment manager combines client money with their own or their firm’s funds, violating the terms of a contract.

Investment management contracts usually outline the details of asset management, with investment managers having a fiduciary responsibility to manage assets according to specific standards and guidelines. Assets meant to be managed separately should never be commingled by the investment advisor.

Instances of special care in managing contributions can arise in legal cases, corporate client accounts, and real estate transactions.

Comparing commingled funds and mutual funds

Let’s conclude this guide by comparing commingled funds with mutual funds, highlighting their key differences.

Commingled funds are characterized by:

– Lower regulation and disclosure requirements.
– Lower fees and expenses due to economies of scale.
– Limited availability in institutional accounts.
– Lack of ticker symbols and public trading.

On the other hand, mutual funds are known for:

– SEC regulation and disclosure.
– Availability for individual retail investors.
– Public trading with ticker symbols.
– Various investment objectives and strategies.

In summary, commingled funds offer cost-effective investment options, but they come with less transparency and limited availability, making them suitable primarily for institutional investors.

Types of commingled funds

1. Real estate commingled funds

Real estate commingled funds pool investments from various investors to acquire and manage real estate properties. These funds are popular among institutional investors looking to diversify their portfolios with real estate assets. Investors in real estate commingled funds may gain exposure to commercial properties, residential developments, and more.

2. Private equity commingled funds

Private equity commingled funds invest in privately held companies, startups, or non-publicly traded assets. These funds are often used by institutional investors and high-net-worth individuals seeking high potential returns, albeit with higher risks. Private equity commingled funds can provide access to a diverse range of investment opportunities, including venture capital and buyout strategies.

3. Fixed-income commingled funds

Fixed-income commingled funds primarily invest in a portfolio of bonds, including government bonds, corporate bonds, and municipal bonds. These funds are favored by investors seeking stable income streams and lower risk levels compared to equity investments. They are often included in retirement plans and pension funds to provide a steady income source for retirees.

Strategies in commingled funds

1. Passive management

Passive management involves tracking a specific index or benchmark, such as the S&P 500. Commingled funds using this strategy aim to replicate the performance of the chosen index by investing in a similar mix of assets. This approach often results in lower management fees and can be suitable for investors looking for broad market exposure.

2. Active management

Active management strategies involve the expertise of professional fund managers who actively make investment decisions. They aim to outperform the market or a specific benchmark by strategically selecting investments, adjusting asset allocation, and conducting extensive research. While active management can potentially generate higher returns, it may also incur higher fees.

3. Multi-asset allocation

Commingled funds employing a multi-asset allocation strategy diversify their portfolios across various asset classes, such as stocks, bonds, and alternative investments. This approach seeks to balance risk and return by spreading investments across different sectors. Multi-asset allocation strategies are popular among investors looking for a balanced and diversified portfolio.


In conclusion, commingled funds offer a flexible and cost-effective way for institutional investors to access professionally managed portfolios. With various types and strategies available, these funds can cater to a wide range of investment objectives and risk tolerances. However, it’s crucial for investors to carefully consider the advantages and disadvantages of commingled funds, as well as their suitability for their specific financial goals.

By understanding the unique features of commingled funds and how they compare to mutual funds, investors can make well-informed decisions to optimize their investment portfolios. Whether you’re interested in real estate, private equity, fixed-income, or other investment options, commingled funds provide an array of choices to align with your financial aspirations.

Frequently Asked Questions

What are commingled funds?

Commingled funds are investment portfolios that pool money from multiple investors into a single fund. This approach reduces management costs and is typically used in institutional accounts.

How do commingled funds differ from mutual funds?

Commingled funds are similar to mutual funds in that they are professionally managed and invest in various financial instruments. However, they differ in terms of SEC regulation, transparency, and availability. Commingled funds are not regulated by the SEC, are less transparent, and primarily available in institutional accounts.

What are the advantages of investing in commingled funds?

Investing in commingled funds offers advantages such as professional management, diversified portfolios, lower fees and expenses, and economies of scale. These benefits can potentially lead to better returns for investors.

What are the disadvantages of commingled funds?

Some disadvantages of commingled funds include their limited availability to individual retail investors, lower transparency due to the lack of ticker symbols and public trading, and the fact that they are not SEC-regulated. Additionally, they can be less liquid than mutual funds.

Can illegal commingling occur with these funds?

Yes, illegal commingling can occur when an investment manager combines client money with their own or their firm’s funds, violating the terms of a contract. Investment managers have a fiduciary responsibility to manage assets according to specific standards and guidelines, and assets meant to be managed separately should not be commingled.

Key takeaways

  • Commingled funds pool money from multiple investors into a single fund, reducing management costs.
  • They share similarities with mutual funds but are not regulated by the SEC.
  • Advantages include professional management, diversified portfolios, and lower fees.
  • Disadvantages encompass limited availability and lower transparency.
  • Illegal commingling can occur when an investment manager combines client and personal funds.
View article sources
  1. Commingling of Funds – Office of Justice Programs
  2. B Commingled Funds –
  3. RCW 43.33A.170: Commingled trust funds—Participation … –