There are two ways to run money for other people. You can open a separate account for each client and manage them one at a time, or you can pool everyone into a single vehicle and manage one portfolio. The first is a separately managed account, an SMA. The second is a hedge fund.
The choice is not cosmetic. It determines how your clients are taxed, what fees you can charge, how many investors you can realistically serve, and how much of your week goes to operations instead of strategy. This guide covers how each structure works, the six differences that matter, and a plain rule for choosing.
Every client owns a separate account. You manage each one individually.
Everyone owns interests in one vehicle holding one portfolio.
What a separately managed account is
An SMA is a brokerage account that belongs to your client. The client opens it, funds it, and owns every security inside it directly. You take trading authority over the account, usually through a limited power of attorney, and manage it for a fee.
Direct ownership is the point. The client sees every position, can impose restrictions on what you buy, and keeps individual tax treatment. You can harvest losses against their specific tax lots, and their broker issues a 1099 at year end. Liquidity is whatever the underlying securities offer, which for public markets means daily.
The cost of that customization is minimums. SMA managers typically require $100,000 to $250,000 per account, because a small account creates the same operational work as a large one while paying a fee on a much smaller number.
One thing an SMA does not get you around is registration. Managing accounts for compensation makes you an investment adviser under Section 202(a)(11) of the Investment Advisers Act, and most states require you to register before taking your first paying client. If you are still weighing that question, start with whether you can legally manage other people's money at all.
What a hedge fund is
A hedge fund pools capital from multiple investors into one legal entity, usually a limited partnership or an LLC. Investors buy interests in the entity, you run a single portfolio inside it, and every investor holds a slice of the same book.
Nobody owns the underlying securities directly. Gains, losses, and expenses flow through the partnership, and each investor receives a Schedule K-1 at tax time reporting their share. Liquidity is whatever the fund documents say it is, typically monthly or quarterly redemption windows with notice periods.
The structure runs on two exemptions. Section 3(c)(1) of the Investment Company Act keeps a private fund outside mutual fund regulation as long as it has no more than 100 beneficial owners and never offers publicly. Rule 506(b) of Regulation D lets the fund raise from an unlimited number of accredited investors, plus up to 35 sophisticated investors who are not accredited, without registering the offering with the SEC. The fund files a Form D within 15 days of its first sale, plus notice filings in the states where its investors live.
The six differences that matter
The minimum investment row explains most manager behavior. SMA minimums are set by economics: below six figures, the fee does not cover the work. Fund minimums are set by the manager, because adding an investor to a pooled vehicle adds a subscription document and a K-1, not a new portfolio.
One portfolio instead of forty accounts
Scale is where the structures separate. Say your strategy attracts 40 clients.
As an SMA manager, every trade becomes 40 tickets or one allocation split fairly across 40 accounts. Every rebalance runs 40 times against 40 different cost bases and cash balances. Clients who joined in March hold a different book than clients who joined in September, and the performance gap between them is yours to explain, account by account.
The same 40 clients in a fund hold one portfolio. One set of trades, one set of books, one performance number that every investor shares. The administrative load grows with paperwork, not with portfolios.
Fees are not the same either
SMAs typically charge a flat percentage of assets, commonly around 1 percent a year. Performance fees are legal but restricted. Rule 205-3 under the Advisers Act limits them to qualified clients, meaning at least $1.1 million under management with you or more than $2.2 million in net worth, thresholds the SEC adjusts for inflation every five years. Most SMA clients do not clear that bar.
Hedge funds run on 2 and 20: a management fee around 2 percent of assets plus 20 percent of profits, taken as a performance allocation to the general partner. Investors accept it because it is the standard, and it is why a fund with modest assets can still pay its manager well after a strong year.
When each structure wins
Run SMAs when
- You serve a few clients with high net worth
- Each client needs a customized portfolio
- Tax loss harvesting is a priority
- Clients insist on owning securities directly
Start a fund when
- You want to scale past a handful of investors
- You run one strategy with conviction
- You want minimums low enough to grow
- You want one portfolio and one set of books
The setup cost gap has closed
The SMA business was always cheap to enter: a state adviser registration, a compliance manual, custodian paperwork. The fund business was not. A traditional hedge fund launch runs $50,000 to $100,000 or more in legal and setup fees for the entity, the PPM, the partnership agreement, and the filings. That number pushed a generation of managers into SMAs by default, and the real cost of starting a hedge fund is worth understanding before you assume it still applies.
It mostly no longer does. Hedgia forms the fund entity, generates the PPM, LPA, and subscription documents, files the Form D and state Blue Sky notices, runs investor onboarding and KYC, and opens the fund bank account, all for $0 upfront. Funds launch in days in the 8 states where Hedgia is live, hold up to 100 investors each, which is the full Section 3(c)(1) allowance, and can accept minimums as low as $5,000.
A plain decision rule
Count your likely clients and look at their balances. Fewer than ten clients, seven figures each, portfolios shaped around individual tax situations: run SMAs. That is exactly what the structure is built for.
One strategy and the ambition to take it past a handful of investors: pool it. A fund gives you one portfolio to run, K-1 economics, a standard performance fee, and room for 100 investors. The $50,000 barrier that used to guard that door is gone.